Poland

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: 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: On 7 January 2026, the President of Poland signed an amendment. New regulations will be effective from 27 January 2026. Provisions relating to when a person works for two employers and receives sick leave at one of them and can still work with their other employer, come into force at the beginning of next year, i.e. 1 January 2027. 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: 27 January 2026 On 7 January 2026, the President of the Republic of Poland signed an amendment to the Labour Code and the Act on the Company Social Benefits Fund.

Under the new regulations, the equivalent for unused holidays must be paid on the salary payment date, together with the last salary. If the salary payment date falls before the termination of the employment relationship, the equivalent must be paid within ten days from the date of termination or expiry of the employment relationship.

They also introduce the possibility of using electronic forms (i.e., e-mail, SMS messages, instant messaging, HR software) to perform selected activities related to labor law. Until now, the acceptable form was written or an equivalent electronic form, including, among others, a qualified electronic signature. This will apply, among other things, to providing employees with information about monitoring in the workplace, providing information about the conditions of the transfer of the workplace to another employer, consulting a trade union on the intention to terminate an employment contract, requesting time off for overtime worked, and requesting unpaid leave.

The amendment also concerns regulations on employee representation in matters relating to the company social benefits fund. Under the new provisions, the employer is required to agree on the remuneration regulations and the Company Social Benefits Fund regulations with employees (at least two) selected by the staff to represent their interests. The previous regulations specified only one representative.

Impact date: On 20 February 2026, the draft was submitted to the Sejm. Most of the provisions are to enter into force three months after their publication in the Journal of Laws. On 17 February 2026, the Council of Ministers adopted a draft amendment to the Act on the State Labour Inspectorate (PIP) and certain other acts. This is the next stage of the planned reform of this institution.

According to the new draft, 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. The proposed provisions are intended to oblige courts to grant security in situations where the validity of the claim is obvious, with the court having three days to consider such security.

In addition, there are plans to introduce a procedure whereby the Chief Labour Inspector will issue binding individual interpretations 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 draft law also provides for an increase in the maximum fine imposed by the employers up to PLN 90,000.

Impact date: Most of the provisions of the Act entered into force on 5 March 2026. On 19 February 2026, the President of the Republic of Poland signed the Act of 23 January 2026 on the expiry of measures resulting from the Act on assistance to Ukrainian citizens in connection with the armed conflict in that country and on amendments to certain other Acts. The Act provides for the gradual expiry of some of the provisions of the so-called Ukrainian special Act and introduces the application of general rules relating to persons enjoying temporary protection in the European Union, regardless of their nationality, to Ukrainian citizens. The Act also extends the validity of visas and residence permits of Ukrainian citizens until 4 March 2027.

The Act also addresses the employment of Ukrainian citizens in the territory of the Republic of Poland. The provisions governing the employment of Ukrainian citizens under temporary protection have been clarified and transferred to the Act on the conditions for the admissibility of employing foreigners in the territory of the Republic of Poland. The Act provides, similarly to the Act on assistance to Ukrainian citizens in connection with the armed conflict in that country, that the entity entrusting work will be obliged to notify the authorities of the entrusting of work to a foreigner benefiting from temporary protection in the Republic of Poland. A new notification of entrusting work to a foreigner will be required in the event of:

• a change in the type of contract between the entity entrusting work to a foreigner and a Ukrainian citizen
• a change in position or type of work performed
• a reduction in working time or the number of hours worked per week or month specified in the notification, or
• a reduction in the monthly or hourly rate of remuneration specified in the notification

Contrary to the provisions of the Act on the conditions for the admissibility of entrusting work to foreigners on the territory of the Republic of Poland, failure to notify in relation to Ukrainian citizens will not render the entrusting of work illegal. Failure to comply with the notification obligation will be punishable by a fine of between PLN 1,000 and PLN 3,000.

Impact date: Ongoing. The draft law has been submitted for inter-ministerial consultation, public consultation and review. Planned adoption by the Council of Ministers – Q2 2026. The planned date for entry into force of the new regulations is 7 June 2026. On 16 December 2025, the Government Legislation Center published a draft Act on strengthening the application of the right to equal pay for women and men for equal work or work of equal value. The draft law aims to implement Directive (EU) 2023/970 into Polish law.

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, individual salary level and average salary levels broken down by gender for categories of employees performing the same work as them or work of equal value to their work
• employers with at least 100 employees will be required to periodically report a range of indicators related to pay gaps (for smaller entities this will be optional)
• 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
• employers will be obliged to implement corrective measures resulting from the joint pay assessment (if applicable)

Impact date: Ongoing. The draft Bill will now be submitted to the Sejm. The new regulations are to come into force 21 days after their publication in the Journal of Laws. 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. In addition, 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: Ongoing. The draft law has been submitted for inter-ministerial consultation, public consultation and review. 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 work week, 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: 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.