Poland

Impact date: 1 January 2026 for employers in public sector and 1 May 2026 for employers in private sector. New rules for calculating length of service are now in force.

Under the new rules, if an employee wishes to include certain periods of employment, e.g. under civil law contracts, in their total length of service with an employer - on which certain employee entitlements (such as amount of vacation days) depend - they must request a certificate from the Social Insurance Institution (ZUS). The employer should verify this certificate.

In light of the new rules, ZUS has launched the “Stażowe” service. This tool allows employers to confirm the authenticity of certificates issued by ZUS at the employee’s request and to quickly verify whether the document is valid.

The service has been available since 31 March 2026 at zus.pl (Search engines and services → Verification of the authenticity of ZUS certificates issued at the request of USP / eZUS).

Impact date: 17 April 2026 On 17 April 2026, the Minister of Health’s regulation on preventive medical examinations for employees came into force.

One of the main changes to the regulations is the introduction of electronic medical certificates. Until now, certificates were issued exclusively in paper form, whereas from now on they may be drawn up electronically, recorded in the Medical Information System and made available to the employee via the Online Patient Account. The option to use a paper-based document template has also been retained – where the electronic format is not available or at the patient’s request.

The regulations also provide for new templates for medical certificates – separate for each type of examination (initial, periodic, follow-up). The scope of information in the medical certificate provided to the employer has also been clarified (depending on the type of certificate).

Impact date: 1 July 2026 On 24 March 2026, the President of the Republic of Poland signed an amendment to the Act on Cash Benefits from Social Insurance in the Event of Illness and Maternity, introducing digitization of applications for the granting and payment of social security benefits.

The amendment differentiates the procedure for submitting benefit applications depending on whether the benefit is paid by ZUS or by the contribution payer (employer), and introduces the option to submit such applications electronically (e.g. via the ZUS PUE platform or ePUAP). Applications and supporting documents, including medical certificates, may also be submitted in electronic form (e.g. as scans), and benefit payers will be entitled to process payments on the basis of electronically submitted applications.

Impact date: The Act will enter into force on 8 July 2026. Employers are preparing for the new powers of the State Labour Inspectorate (PIP).

According to the new Act, if an inspector finds that a contract/service is being performed under conditions characteristic of an employment relationship, the inspector will first issue an order to remedy the violation. If the order is not properly executed, the case will be referred to the district labour inspector. The inspector will be able to issue a decision confirming the existence of an employment relationship or, alternatively, refer the case to the competent labour court for a ruling on the existence or content of the employment relationship.

The parties will be able to appeal against the administrative decision of the State Labour Inspectorate to the labour court.

In addition, employers will be able to apply for binding individual interpretations to the Chief Labour Inspector as to whether a given legal relationship is performed under an employment contract. If the facts established during an inspection differ from those described in the request for interpretation, the competent State Labour Inspectorate authority will be entitled to assess the actual nature of that legal relationship.

The new law provides fines up to PLN 90,000. Companies that voluntarily convert civil-law contracts with employment characteristics into employment contracts by July 2027 will not face penalties under the Labour Code.

Impact date: 2026 According to an announcement by the President of the Central Statistical Office dated 19 February 2026, the amount of PLN 7,848.60 should be used to determine the contribution to the Company Social Benefits Fund (ZFŚS) in 2026.

Accordingly, the basic contributions to the Company Social Benefits Fund (ZFŚS) in 2026 are:

• per employee working under normal conditions – 37.5% of the base amount, i.e., PLN 2,943.23
• per employee performing work under special conditions or of a special nature – 50% of the base, i.e., PLN 3,924.30
• per juvenile employee:

***First year of study – 5% – PLN 392.43 ***Second year of training – 6% – PLN 470.92 ***Third year of training – 7% – PLN 549.40

The basic deduction may be increased by:

• 6.25% – for each person with a moderate or severe disability, i.e., PLN 490.54
• 6.25% – for each pensioner receiving social assistance, i.e., PLN 490.54

Impact date: Parliamentary stage. The draft provides for the Act to enter into force 14 days after its publication. The exclusion of allowances from the minimum wage is to take effect on a one-time basis as of 1 January 2027. Work is currently underway on a draft legislation regarding the minimum wage.

The main objective is to align the minimum wage with the base salary. This means that no allowances, bonuses, or awards, i.e., discretionary or variable benefits, will be included in the minimum wage.  The minimum wage is intended to reflect a fixed, guaranteed portion of an employee’s salary, independent of performance or the employer’s bonus policy. The draft also includes a provision under which interest for late payment of wages will be calculated automatically, without the employee having to file a claim. The amendment introduces a new type of offense into the Criminal Code of the failure to pay wages for a period of at least three months.  This act is punishable by a fine, restriction of liberty, or imprisonment for up to two years, and also introduces a new misdemeanor into the Labor Code of paying wages lower than the minimum wage established under separate regulations.  This act is to be punishable by a fine ranging from PLN 1,500 to PLN 45,000.

Impact date: Ongoing. Early 2027. The previous draft act assumed entry into force of the provisions on 7 June 2026. The new version of the draft provides for a 6-month vacatio legis. On 4 May 2026, a new draft Act on strengthening the application of the right to equal pay for men and women for equal work or work of equal value, dated 29 April 2026, was published on the Polish Government Legislation Centre website. This draft replaces the previous version dated 12 December 2025.

The draft clarifies the method of calculating the number of employees for the purposes of gender pay gap reporting – based on annual full-time equivalents.

According to the directive, employees will be entitled to request information on individual and average pay levels (including hourly pay levels) – the draft clarifies that this data will cover the 12-month period for which remuneration was paid preceding the month in which the request was submitted.

The role of the equality body is to be fulfilled by a newly established collegiate body – the Commission for Combating Discrimination in Employment.

Along with the new draft law implementing the Pay Transparency Directive, a draft regulation has been released. The regulation specifies the detailed information regarding the indicators included in the report on the gender pay gap, the method for calculating the indicators, and the formula for their calculation. In reports on the gender pay gap, employers will be required to provide, among other things, two indicators: the annual and hourly pay gaps. The regulation is set to enter into force 14 days after its publication.

Impact date: Ongoing. The draft Bill is now subject to the works in the Sejm (lower chamber of Polish Parliament), before the second reading. On 17 February 2026, the Council of Ministers adopted a draft amendment to the Labour Code and the Code of Civil Procedure.

The draft simplifies the definition of mobbing, emphasizing persistent harassment of an employee as a feature determining the existence of mobbing. The new definition excludes incidental behavior and recognizes mobbing as a recurring, repeated or constant phenomenon. It has been clarified that mobbing can come from a superior, colleague, subordinate, individual or group of individuals. Mobbing actions are classified as physical, verbal or non-verbal, emphasizing that ordering or encouraging such behavior also constitutes mobbing. The definition has been made independent of the perpetrator's intent or the occurrence of an effect, while emphasizing that justified behavior expressed in an appropriate form, such as accountability for entrusted work or criticism of it, is not considered mobbing.

A new feature is the introduction of a minimum threshold for compensation for mobbing, which means that an employee will be able to claim compensation in court in an amount not lower than six times the minimum wage. Employee will be also able to claim damages.

Employers with at least nine employees will be required to formally implement and communicate internal rules to prevent mobbing, discrimination and other violations of the principle of equal treatment.

Impact date: The draft is currently under consideration by the Council of Ministers. On 21 April the Ministry of Family, Labor, and Social Policy has published the latest version of the draft law on internships. The new law, which comprehensively regulates the rules governing internships, implements the EU recommendation on a strengthened quality framework for internships into Polish law.

The most significant change compared to the original draft is the increase in the remuneration to be paid to interns, from 35% to 65% of the minimum wage. In the case of minor interns (interns who are under 18 years of age but have completed secondary school and fulfill their educational obligation by participating in the internship), they are entitled to a cash allowance of no less than PLN 250.

The provision establishing a mandatory day of leave for an intern for every 30 calendar days of the internship (and two days off for every subsequent 30 days beyond 90 days) has also been removed from the original draft.

The Act also provides that if an internship is performed under conditions characteristic of an employment relationship, it is deemed to be performed under an employment contract, regardless of the contract’s title. At the same time, certain provisions of the Labor Code (including those regarding retirement severance pay, survivor’s benefits, and unpaid leave) do not apply to an internship agreement treated as an employment contract. Unlike the original version of the draft, the provision stating that matters not regulated by the Act on Internships would be governed by the Civil Code has been removed.

Impact date: The work on the draft regulations is still ongoing. Due to objections raised in relation to other issues covered by the amendment, the draft will soon be referred again for public consultation and inter-ministerial consultation. After that, the draft Bill will be resubmitted for consideration by the Standing Committee of the Council of Ministers. The Ministry of Infrastructure has presented draft regulations on mileage allowances, which regulate the rules for reimbursement of costs incurred when using private vehicles for business purposes.

The draft regulations specify the maximum reimbursement rates depending on the type of vehicle - passenger car, motorcycle, and moped - as was the case previously. A new feature is the inclusion of the type of drive system - combustion, hybrid, electric, or hydrogen - and engine power instead of displacement. The new amounts are to be more in line with the actual operating costs of different vehicles. Previously, the lack of rates for hybrid and electric cars meant that many companies had doubts about the travel allowances to which their employees were entitled.

Impact date: Ongoing. The regulation is currently being worked on by the Council of Ministers and the exact schedule for work on the regulation is not known. On 23 January 2026, the Ministry of Family, Labour and Social Policy published a draft amendment to the Regulation on entitlements of employees of state or local government budgetary units in respect of business travel.

The new regulations provide for an increase in the (daily) allowance for the duration of a business trip within the country from PLN 45 to PLN 60. The higher allowance will affect other benefits, including the lump sum to cover the costs of travel by local means of transport and the lump sum for accommodation. In addition, the proposed regulations provide for an increase in allowances and accommodation limits for foreign travel to countries such as the Czech Republic, Germany, France, Spain, the United Kingdom and the United States.

Transitional arrangements are also provided for business trips commenced before that date and not completed on the date of entry into force of the amendments. In such cases, the amounts due will be determined proportionally:

• for the time of travel prior to the date of entry into force of the regulation according to the previous rates, and
• for the time of travel from the date of entry into force of this regulation according to the new rules

Although the regulation applies to public sector employees, it also applies directly to private employers who do not regulate the rules for paying allowances in the company law (in a collective labour agreement or remuneration regulations). Pursuant to Article 775 of the Labour Code, private employers may not set allowances for business trips at a lower rate than that specified in the regulation.

Impact date: The changes are expected to take effect 14 days after they are announced. On 28 April 2026, the Council of Ministers adopted a draft law amending the Act on Employee Capital Plans. The draft aims to simplify the state’s interaction with employers regarding Employee Capital Plans (PPK). The current paper-based requests to enter into a PPK management agreement are to be replaced by electronic versions sent to the employer’s account at the Social Insurance Institution (ZUS). The requests will be signed electronically and will be deemed delivered on the date they are viewed in the ZUS account or 14 days after they are made available. At the same time, employers will still have 30 days to enter into a PPK management agreement, counting from the date the notice is delivered.