Poland

Impact date: 20 June 2026. Full implementation of the expanded version of the e-Umowy system, incorporating all the newly introduced features, is scheduled to take place within three years.

On 20 June 2026, an amendment to the Act on the ICT system for the administration of certain contracts and certain other acts came into force.

Since 7 January 2026, the Praca.gov.pl portal has been hosting the free e-Umowy system, which enables the electronic conclusion and management of certain types of contracts (including employment contracts and contracts for specific tasks). Users can use the system to prepare documents using the templates provided, affix a trusted, personal or qualified digital signature to them, and store all documentation in one place.

Until now, the group of entities authorized to use the system was limited – only individuals, farmers, micro-entrepreneurs and entities employing no more than 9 people could make use of the contract-conclusion facilities. Under the amended provisions, any entity may use the system, regardless of its legal form or scale of operations, including larger employers with more than 9 employees.

The amendment also extends the system’s functionality to cover agreements ancillary to the employment relationship, such as non-competition agreements, agreements on professional development, and agreements on employees’ financial liability, as well as voluntary service agreements. In addition, a mechanism has been provided for transferring contracts originally concluded by other means into the system – the parties will be able to register an existing contract in e-Umowy without the need to re-sign it. Employers will be able to maintain employee records in electronic form directly within the system.

Impact date: 18 August 2026

On 18 August 2026, provisions transposing EU regulations on ensuring gender balance on company boards (the so-called ‘Women on Boards’ Directive) into the Polish law came into force.

Large listed companies will have to ensure that the under-represented gender (i.e. the one holding no more than 49 per cent of positions) accounts for a proportion as close as possible to 33 per cent of all seats on management and supervisory boards combined. The new obligations also include adopting a gender balance policy and publishing an annual report on gender representation on the company’s governing bodies.

Companies will also be required to establish clear, objective and non-discriminatory rules for the selection of candidates before the recruitment process begins. Where candidates’ qualifications are comparable, priority will be given to a person belonging to the gender that has been under-represented to date. Individuals whose recruitment rights have been breached will be entitled to claim compensation in court (in an amount not less than the monthly minimum wage). If a rejected candidate demonstrates that their qualifications are equivalent, the burden of proof that no discrimination took place will rest with the company.

The President of Poland has referred the bill to the Constitutional Tribunal for subsequent review.

Impact date: The draft legislation is at the committee stage in the Sejm following its first reading (on 11 June 2026). It has not yet been adopted by Parliament or signed into law, as committee work is still ongoing. 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: The Act entered into force on 8 July 2026. On 21 July 2026, the Act was referred by the President of Poland to the Constitutional Tribunal for a subsequent constitutional review. However, the Act remains in force pending the Tribunal’s decision.

Labour inspectors have been granted new powers to reclassify B2B arrangements, mandate contracts, and other civil law contracts as employment contracts.

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 Chief Labour Inspector (GIP) has issued the first individual interpretations regarding the application of labour law provisions to determine whether the legal relationship described in the application constitutes an employment relationship within the meaning of the Labour Code. The interpretations are, for the most part, unfavorable to the applicants – out of eight cases, the Chief Labour Inspector accepted three models of cooperation and challenged five as exhibiting the characteristics of an employment 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: 11 August 2026 On 11 August 2026, most of the provisions of the Act on Artificial Intelligence Systems came into force. Its purpose is to establish a national institutional and procedural framework for the enforcement of the provisions of the EU Regulation on Artificial Intelligence (the so-called AI Act) in Poland. In particular, the Act specifies: the supervisory authority, the notifying authority, complaint and appeal procedures, rules for reporting incidents, mechanisms to support innovation, and rules for imposing penalties for breaches of the Regulation.

The most significant institutional change is the establishment of the Commission for the Development and Safety of Artificial Intelligence (KRiBSI) as the national supervisory authority for the AI market. The Commission comprises: the President of the Office of Competition and Consumer Protection (UOKiK), the President of the Office of Electronic Communications (UKE), and representatives of the Polish Financial Supervision Authority (KNF) and the National Broadcasting Council (KRRiT). A Public Council on Artificial Intelligence will operate under the Commission.

The AI Act is of significant importance in the field of labour law. AI systems used in recruitment or employee management are classified as high-risk systems within the meaning of the Regulation, which means there is an obligation to carry out a conformity assessment and obtain CE marking before their implementation.

Impact date: The new definition of mobbing will take effect upon the law’s entry into force on 5 November 2026. However, employers will be granted a six-month transition period to amend their work regulations to comply with the new provisions or, where applicable, to adopt separate anti-mobbing regulations (small employers).

The legislative work on the Act of 19 June 2026 amending the Labour Code and the Code of Civil Procedure regarding the anti-harassment aspects is now completed.

The Act simplifies the definition of mobbing, stating that the defining feature of such behavior is the persistent harassment of an employee. The new definition excludes sporadic behavior and recognizes mobbing as a recurring, repeated or persistent phenomenon. It has been clarified that mobbing may originate from a line manager, a colleague, a subordinate, an individual or a group of people. Acts of mobbing are classified as physical, verbal or non-verbal, with the point being made that ordering or encouraging such behavior also constitutes a mobbing.

A new feature is the introduction of a minimum threshold for remedy for suffering mobbing, meaning that an employee will be able to claim a remedy in court amounting to no less than six times the minimum wage. If mobbing has caused harm, an employee will also be able to claim compensation. Furthermore, employers with at least ten employees will be required to formally implement and communicate to their staff internal policies aimed at preventing mobbing, discrimination and other breaches of the principle of equal treatment.

Impact date: The Regulation will come into force on 11 January 2027.

On 27 June 2026, a regulation by the Minister for Family, Labour and Social Policy was published, introducing, for the first time in the Polish law, maximum permissible temperatures in the workplace. Previous health and safety regulations specified only a minimum temperature (14°C for work premises in general, 18°C for office work), but did not set an upper limit.

Under the regulation, work must not be carried out if the temperature in work premises exceeds 35°C, or if, in the case of outdoor work involving strenuous physical exertion, it exceeds 32°C, unless technological considerations prevent this. Work will have to be suspended for as long as the temperature, due to weather conditions, exceeds these thresholds.

In the case of work carried out indoors, once the temperature exceeds 28°C, or 25°C in the case of heavy physical labour, the employer is required to take specific measures, i.e. to implement technical solutions to lower the temperature, such as air conditioning, ventilation, or implementing organizational measures to minimize the impact of temperature on health, e.g. additional breaks or shift work. In the case of work carried out outdoors, once the temperature exceeds 25°C, the employer is obliged to implement appropriate organizational measures to minimize the impact of temperature on health.

Employers will be required to consult on these organizational measures with employees through the health and safety committee, or, where there is no obligation to establish such a committee, with employee representatives, and after consulting the doctor responsible for the employees’ preventive healthcare.

Impact date: The draft has been included in the government’s legislative agenda and has been put out for public consultation. The expected date for the draft’s adoption by the Council of Ministers is the fourth quarter of this year.

The Ministry of Family, Labour and Social Policy has published the first draft bill on the performance of work via digital labour platforms, dated 6 August 2026. The draft bill transposes the Directive on so-called platform work into Polish law.

As expected, the draft introduces a rebuttable legal presumption of the existence of an employment relationship. A significant difference compared with the Directive is that the presumption applies not only to the relationship between the platform and the person performing platform work, but also directly to intermediaries, which is a broader approach than that adopted in the Directive. The procedure for invoking the presumption is to take the form of proceedings before the State Labour Inspection (PIP), which may be initiated in two ways: (i) at the request of the platform worker or their representative, who submit an application to the PIP demonstrating the likelihood of an employment relationship, or (ii) ex officio, where circumstances established in the course of a PIP inspection indicate the likelihood of an employment relationship between the platform or intermediary and the platform worker. Once proceedings have been initiated, the platform and the intermediary have 14 days from the date of service of the notice to rebut the presumption. If the presumption is not rebutted or if a party waives the right to rebut it, the district labour inspector issues a decision confirming the existence of an employment relationship, with the employment contract deemed to have been concluded on the date the decision is issued. An appeal against the decision may be lodged with the labour court within one month. The draft bill also provides for the possibility of invoking the presumption directly before the labour court.

The presumption will not have retroactive effect, it will apply only to legal relationships established after 2 December 2026.

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: 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 on consultation phase.

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 draft law has completed the consultation phase and is currently being revised to reflect the comments and feedback received.

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.