Poland

Impact date: 12 December 2025 The Ministry of Family, Labor and Social Policy has drafted an amendment to the Regulation on health and safety dated 20 June 2025, which will enable employees to confirm completion of initial health and safety training not only with a traditional signature on paper or a qualified electronic signature, but also by e-mail or instant messaging. The employer will be then required to attach such confirmation to the training card and make an appropriate note. The amendment was published in the Journal of Laws on 27 November 2025.

Impact date: 13 December 2025 On 5 November 2025, the Polish Parliament passed a law on collective bargaining agreements, which was signed by the President on 27 November 2025. This concluded parliamentary work on a legal Act aimed at implementing the EU directive on adequate minimum wages in the European Union. The deadline for implementing the directive into Polish law expired on 15 November 2024.

The new regulations are intended to facilitate the conclusion, registration, and application of collective bargaining agreements. A key change compared to previous regulations is the introduction of electronic notifications of concluded agreements, which will be registered in the National Register of Collective Bargaining Agreements. The Act also expands the group of entities that can conclude a company agreement, allowing a cross-company trade union organization to participate in such an agreement. The new regulation give parties greater flexibility in setting agreement terms – before the expiry of a fixed-term collective bargaining agreement, the parties may decide to extend its term for an indefinite period, which is not possible under the current regulations. In the event of a dispute between a trade union and an employer during negotiations on the content of an agreement, the law now provides for the possibility of engaging an impartial mediator to assist in resolving the conflict.

Impact date: 24 December 2025

The adopted regulation only partially implements the provisions of the Directive on pay transparency. Work on the comprehensive implementation of the Directive on pay transparency is in progress. On 18 June 2025, the President signed an amendment to the Labor Code which partially implements the Directive concerning pay transparency (Article 5 of the Directive). The new provisions will be effective from 24 December 2025.

Below are the key changes employers should be aware of:

• Candidates must be informed of the proposed remuneration (either the initial amount or the salary range)
• Candidates must be informed about the provisions of the collective bargaining agreement or regulations concerning remuneration (all components) and other work-related benefits that they can expect from their future employer
• The above information should be provided: (i) in the job advertisement, or (ii) before the interview, or (iii) before the employment relationship is established
• The above information should be delivered in paper or electronic form, in advance, so that the candidate has time to familiarize themselves with it and ensure informed and transparent negotiations
• Candidates may not be asked about their current or previous salaries; however, the regulations do not prohibit asking about salary expectations
• Job advertisements and job titles must be gender-neutral

Impact date: The planned date of entry into force of the new regulations is 1 January 2026. However, the draft law has not yet been submitted to the Parliament. The Government published a draft amendment to the Act on the National Labor Inspectorate (PIP), which provides for a number of new powers to be granted to the PIP. The key change is the introduction of the potential for labor inspectors to issue administrative decisions transforming incorrectly concluded civil law contracts into employment contracts. The decision will be immediately enforceable but may be appealed.

The newest version of the draft law provides that an inspector's decision confirming the existence of an employment relationship may cover a period of up to three years retroactively.

The draft law also provides for a twofold increase in the maximum fine imposed by the PIP to PLN 60,000.

Impact date: 1 January 2026 for employers in public sector and 1 May 2026 for employers in private sector. The Ministry of Family, Labor and Social Policy has prepared a draft amendment to the Labor Code, changing the rules for calculating length of service, on which some employee entitlements depend (e.g. holiday entitlement or the amount of the jubilee award). On 17 October 2025 the President signed a draft amendment.

According to the draft, length of service will include, among other things, periods of non-agricultural economic activity, periods of cooperation with a person conducting such activity, periods of suspension of economic activity for the purpose of personal care for a child, periods of performance of a contract of mandate or a contract for the provision of services (B2B) and an agency contract. The periods for which social security contributions were paid (if there was an obligation to pay them in a specific situation) will be confirmed by certificates issued by the Social Insurance Authority (ZUS).

Impact date: Ongoing – advanced work in the Parliament. If passed, new regulations are expected to be effective from 1 January 2026, but the provisions providing that work for one employer will be possible during incapacity for work for another employer are to come into force 12 months after the publication of the Act in the Journal of Laws. The Ministry of Family, Labor and Social Policy has prepared a draft law amending the law on the social insurance system and other related laws. The draft provides, among other things, for an amendment to the Act on cash benefits from social insurance in the event of sickness and maternity. This will provide the Social Insurance Authority (ZUS) with new, more effective tools to control the correct use of sick leave.

A new feature is the extension of checks on the correct use of sick leave and on persons who have lost their sickness insurance entitlement. The checks will cover sick leave due to incapacity for work and sick leave due to the need to provide personal care. The inspector will be entitled to enter the place where the check is carried out and to identify the person being checked, solely for the purpose of establishing their identity. In addition, they will be able to request and obtain information from the person being inspected, their contribution payer or attending doctor, as well as access the data of the insured person and contribution payer collected by the Social Insurance Authority (ZUS) in their accounts, but only if this is justified by the purpose of the inspection.

A significant change will be that a person employed by two employers/contribution payers at the same time will be able to ask their doctor to issue only one sick leave certificate instead of two. This will mean a departure from the current rule applied by ZUS, under which any gainful employment for one contribution payer during the period of receiving sickness benefits from employment with another contribution payer deprives the insured person of the right to benefits for the entire period of sick leave.

Impact date: Ongoing. Planned adoption by the Council of Ministers – Q2 2026. On 25 November 2025, key measures of a draft law on strengthening the enforcement of the right to equal pay for women and men for equal work or work of equal value were presented. The draft law aims to implement Directive (EU) 2023/970 into Polish law, but the exact provisions of the draft law are not yet available.

Key measures:

• Mandatory job evaluation for all employers, regardless of headcount
• Employees will gain the right to access information on pay-setting criteria, rules for salary increases, and average pay levels broken down by gender
• Employers with at least 100 employees will be required to periodically report a range of indicators related to pay gaps
• If the pay gap within a given category exceeds 5% without objective justification, the employer will be obliged to conduct a joint pay assessment with employee representatives

Impact date: Ongoing. On 6 November 2025 a draft amendment to the Labor Code regarding bullying / workplace harassment (mobbing) was proposed.

The new definition suggests that mobbing consists of persistent harassment of an employee that is repetitive, recurring, or constant. The new draft clarifies now that mobbing does not include incidental behaviors, even if they constitute a violation of an employee's individual rights.

Mobbing can be manifested in the following ways occurring individually or in combination:

• Humiliation or debasement
• Intimidation
• Lowering the employee's job performance evaluation
• Unjustified criticism, humiliation, or ridicule
• Hindering the employee's ability to achieve work results, complete tasks, utilize their skills, communicate with colleagues, or access necessary information
• Isolating the employee or excluding them from the team
• Persistent harassment

Under the new draft, all employers, regardless of the number of employees, will be required within 6 months to establish procedures and preventative measures to prevent violations of dignity, the principle of equal treatment in employment, discrimination and bullying.

The new draft also provides for an increase in compensation of a minimum of six times the minimum wage.

Impact date: Ongoing. On 21 November 2025, a draft law on regulations prohibiting the organization of unpaid internships was presented. This is part of a broader initiative at European level to adopt a directive limiting unpaid internships and minimizing the risk of replacing employment relationships with internships.

Some of the most important guiding principles of the draft law include:

• An obligation to pay a monetary benefit of at least 35% of the average wage in the first quarter of the previous year, as published in the Polish Monitor
• Internship working time will be set at no less than four hours per day and no more than eight hours per day, and on average 40 hours in an average five-day workweek, within a settlement period not exceeding three months
• An entitlement to paid time off for interns: one day during the first three months of the internship and two days in subsequent months for each month worked

The maximum duration of an internship will be six months.

The draft law excludes, among other things, internships and work placements required to practice regulated professions, as well as work placements undertaken by students as part of their studies.

Impact date: Awaited. On 29 July 2025, the Government adopted a draft amendment to the Labor Code and the Act on the Company Social Benefits Fund concerning the simplification of the cash equivalent for unused holiday leave upon termination of an employment contract. The proposed changes set the date for the payment of the cash equivalent for unused holiday leave as the same day on which remuneration is paid.

The draft also provides for a change in the rules for employee representation in matters relating to the Company Social Benefits Fund (ZFŚS). Provisions of the remuneration regulations concerning the amount of the contribution to the Fund, or the decision not to establish the Fund, will require agreement with at least two employees selected by the staff to represent their interests.

The proposed legislation is currently proceeded by the lower chamber of Polish Parliament (Sejm).

Impact date: Awaited. 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.