Poland
New rules for employing foreigners
Impact date: 1 June 2025, although some of the provisions introduced by this Act will come into force on other dates. On 1 June 2025, the Act of 20 March 2025 on the conditions for admitting foreigners to employment in the territory of the Republic of Poland came into force and replaces the regulations on the employment of foreigners, which were previously contained in the Act on employment promotion and labor market institutions.
The new Act abolishes the obligation to conduct a labor market test. This required companies to prove that there were no available candidates from Poland nor the EU, while maintaining the possibility for the competent district administrator to determine those professions and industries where it is permissible to restrict the employment of foreigners and for how long. The Act introduces electronic issue of work permits for foreigners. Mandatory grounds for refusing a work permit are specified when the employer's company was established, or operates mainly to facilitate, the entry of third-country nationals. In addition, the Act makes it easier to monitor entities employing foreigners, including by abolishing the obligation to give advance notice of inspections. Fines for illegal employment of foreigners are increased from PLN 3,000 to PLN 50,000 per case.
Also, from 1 August 2025, employers hiring foreign workers who have been granted a work permit by the provincial governor (wojewoda) are required to submit a copy of the employment contract with the foreign worker via an updated ICT system. Importantly, according to the new regulations, this must be a copy of the contract drawn up in Polish. The tool for submitting copies of contracts is available at www.praca.gov.pl.
Employer implications/action needed Employers should adjust their operations to the new provisions.
Employer risk N/A
New regulations for employment agencies
Impact date: 1 June 2025, although some of the provisions introduced by this Act will come into force on other dates. On 1 June 2025, the Act of 20 March 2025 on the conditions for admitting foreigners to employment in the territory of the Republic of Poland came into force.
The Act replaces the existing regulations on the registration and operation of employment agencies, including temporary employment agencies. The Act introduces numerous changes with regard to the registration of employment agencies in the National Register of Employment Agencies (KRAZ). Applications for entry in the register will be submitted exclusively via an ICT system. The application must be accompanied by certificates - rather than submitted upon request by the registration authority as was previously the case - confirming, among other things, that there are no outstanding tax or social security liabilities, and that the individuals managing the entity intending to operate an employment agency have no criminal record.
The registration fee is also changing (from PLN 200 to PLN 1,000) as is the deadline for registration (and changes to the register) – from seven days to 14 days. A significant change applies to employment agencies that intend to conduct business activity in the field of job placement and temporary work for foreigners who require a work permit or a declaration of entrusting work to a foreigner, referred to in Article 6 of the Act of 20 March 2025 on the conditions for the admissibility of entrusting work to foreigners in the territory of the Republic of Poland. Under the new provisions, such activity may be conducted after two years from the date of entry in the register of employment agencies and the provision of services not related to the employment of foreigners.
Employer implications/action needed Clients operating as employment agencies should adjust their operations to the new provisions.
Employer risk N/A
New regulations concerning monitored redundancies
Impact date: 1 June 2025 On 1 June 2025, the Act of 20 March 2025 on the conditions for admitting foreigners to employment in the territory of the Republic of Poland came into force.
The Act has amended some of the provisions relating to so-called monitored redundancies.
The Act clarifies the definition of a monitored dismissal, specifying that it is a situation where an employer intends to dismiss at least 50 employees within three months for reasons related to the workplace. In such a case, the employer is obliged to take measures to ensure that employees have access to labor market services in the form of various programs aimed at enabling the dismissed employees to continue their employment after their dismissal. The provisions in force from 1 June 2025 clarify the procedure to be followed by employers in the event of monitored redundancies.
In the case of monitored redundancies, after prior consultation with the district labor office, the employer shall provide employees who are to be made redundant, who are in the process of being dismissed, or who have been dismissed, with assistance in the form of, among other things, job placement, career guidance, training, confirmation of acquired knowledge and skills, and obtaining documents confirming the acquisition of knowledge and skills, which shall be provided in the form of special, dedicated programs. The programs may be financed by bodies or by the employer and relevant public administration bodies, or based on an agreement between organizations and legal persons with the participation of the employer.
Employer implications/action needed N/A
Employer risk N/A
Pay transparency
Impact date: The new regulations will come into force six months after their announcement in the Journal of Laws. On 23 June 2025, an amendment was published in the Journal of Laws. The regulations will come into force on 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. Adoption of the new draft in this regard is expected in the fall of 2025. On 18 June 2025, the President signed an amendment to the Labor Code which partially implements the Directive concerning pay transparency.
According to the Act, employers will be required to inform candidates (in paper or electronic form) of the amount or range of remuneration and other benefits (monetary and non-monetary) associated with the job position offered. This information must be provided in the job advertisement and, if not provided earlier, before the interview or the signing of the contract. If the employer is covered by a collective agreement or remuneration regulations, they will be required to indicate the relevant provisions in this regard. Advertisements must be gender-neutral and the entire recruitment process must be conducted without discrimination. The amendment also stipulates that employers may not request information about a candidate's current or previous remuneration.
Employer implications/action needed Employers should adjust recruitment practices to the new regulations and apply them from 24 December 2025.
Employer risk Potential allegations of non-compliance with regulations and potential equal treatment claims.
Changes in the rules for calculating length of service
Impact date: On 24 June 2025, the Council of Ministers adopted and submitted to the lower chamber of Parliament (Sejm) the above draft amendment to the Labour Code.
The amendment is to enter into force on 1 January 2026. The Ministry of Family, Labour and Social Policy has prepared a draft amendment to the Labour 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).
According to the draft, the length of service will include, among other things, periods of non-agricultural economic activity, periods of cooperation with a person conducting such activity, or 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).
Employer implications/action needed Employers should monitor the development of the draft amendment.
Employer risk N/A
No e-cigarettes in the workplace
Impact date: 5 July 2025 On 5 July 2025, an amendment to the Act on the protection against the health effects of tobacco and tobacco products dated 21 May 2025 came into force.
The Act now also covers nicotine-free products, i.e. all devices that generate vapor, regardless of their nicotine content, including their components. The amendment confirms that smoking both traditional and electronic cigarettes is prohibited on the premises of the workplace, unless the employer designates a special area for this purpose.
Employer implications/action needed Employers may need to amend their health and safety regulations and other work regulations that are in force.
Employer risk N/A
Documenting the right to maternity benefit and funeral benefit
Impact date: 6 August 2025 On 6 August 2025, two regulations came into force that make it easier to grant the right to maternity benefit for the period of maternity leave or to funeral benefit in the event of a stillborn child.
Until now, the basis for obtaining leave and benefits was the preparation of a stillbirth certificate, which required confirmation of the sex of the child. Since the new regulations came into force, an abridged copy of the birth certificate (if one has been drawn up) or a stillbirth certificate issued on the basis of medical documentation by a specialist doctor or a doctor specializing in obstetrics and gynecology or a midwife is sufficient. This certificate will be issued regardless of the duration of the pregnancy.
The new regulations also introduce changes regarding applications for funeral allowances in the event of the birth of a stillborn child when no birth certificate has been drawn up. In such a situation, the application must be accompanied by a death certificate or a stillbirth certificate issued based on medical records by the above-mentioned doctors or midwives. The certificate will be issued regardless of the duration of the pregnancy. The date of death will be determined based on this document.
Employer implications/action needed N/A
Ministry announces pilot program for reduced working hours
Impact date: Applications are accepted electronically from 14 August 2025 to 15 September 2025. Employers will be notified of the results of the selection process by 15 October 2025. The pilot program is divided into three stages: preparatory (from signing the contract between the employer and the Ministry until the end of 2025), testing the proposed model of reduced working hours (throughout 2026), and conclusion (until 15 May 2027). On 28 April 2025, the Ministry of Family, Labour and Social Policy announced plans to launch a pilot program to reduce working hours while maintaining current employee remuneration and without reducing employment. The program is to be flexible and tailored to the needs of different industries and the size of enterprises.
Details of the pilot program were presented on 27 June 2025. Employers who meet the following criteria are eligible to participate in the pilot program: running a business for at least 12 months prior to the date of application, employing at least 75% of staff on the basis of an employment relationship, covering at least 50% of the workforce with the pilot program, and maintaining employment at a level of at least 90% of the initial level specified in the application, with no deterioration in the conditions of work and pay throughout the duration of the program.
The maximum value of support per pilot program is PLN 1 million, while the cost of the project per employee covered by the pilot program cannot exceed PLN 20,000. Funds allocated under the pilot program can be spent on two types of costs. The first type includes substantive costs, such as research, analyses, expert opinions on the implementation of reduced working hours, and financing the optimization and automation of processes that are key to reducing working hours (e.g., the purchase of digital tools for analyzing work efficiency). It also includes training for employees and subsidizing their remuneration during the pilot program. The second type are service costs – related to information, promotion, coordination, recruitment, monitoring, evaluation, and project settlement. The total amount of service costs cannot exceed 10% of the total program value.
Employers are free to choose the forms of reduced working hours they want to test.
Employer implications/action needed Participation in the pilot program is voluntary. Employers that decide to participate in the pilot program will have several obligations to fulfill, e.g. completing surveys by the employer and employees before the start of the pilot program, then every quarter during its duration, as well as submitting a final report after completion of the pilot program containing information on the activities carried out, solutions developed, financial information with a list of invoices, and an evaluation of the pilot program.
Employer risk N/A
Planned changes to the process of confirming health and safety training
Impact date: The new solution is expected to come into force in the fourth quarter of 2025. The Ministry of Family, Labour 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.
Employer implications/action needed N/A
Employer risk N/A
No more paper copies of social security registration forms
Impact date: Ongoing. The draft law was submitted to the lower chamber of Parliament (Sejm) on 16 July 2025 and was referred for its first reading in committee on 22 July. As part of its deregulation measures, on 15 July 2025 the Council of Ministers adopted a draft amendment to the Social Security System Act, which abolishes the obligation for businesses to keep paper copies of social security registration forms sent to the Social Insurance Authority (ZUS).
Under the current regulations, social security contribution payers must keep paper copies of applications bearing the handwritten signature of the person registered for social security (e.g. an employee) for five years.
Employer implications/action needed Employers should be aware of the abolition of the obligation to retain the above-mentioned documentation.
Employer risk N/A
Planned changes in collective agreements
Impact date: Awaited, the draft law was submitted to lower chamber of Parliament (Sejm) on 21 August 2025. On 19 August 2025, the Council of Ministers adopted a draft law on collective labor agreements, submitted by the Ministry of Family, Labor and Social Policy.
The aim of the new legislation is to simplify the process of concluding and registering collective agreements, thereby promoting their broader use. Until now, these matters were regulated by the Labor Code and the Regulation of the Minister of Labor and Social Policy of 4 April 2001, concerning the procedure for registering collective labor agreements, maintaining the register of agreements and registration files, and templates for registration clauses and cards. The need for new regulations stems from the EU Directive on adequate minimum wages (EU 2022/2041), which obliges Member States to increase the number of collective agreements.
Employer implications/action needed The draft law introduces numerous simplifications in the conclusion of collective agreements that employers should be aware of.
Employer risk N/A
New definition of bullying
Impact date: Awaited. Currently, after considering comments from previous stages, the draft has been referred for further review and public consultation, after which it will be submitted to the Permanent Committee of the Council of Ministers. On 6 July 2025, the Government Legislation Centre published a new draft amendment to the Labour Code regarding in particular a new definition of bullying. The draft differs slightly from the original version.
The new definition suggests that bullying 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.
Bullying 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
- If they take the form of persistent harassment.
Employer implications/action needed Employers should monitor the development of the draft legislation.
Employer risk N/A
Simplification of the procedure for paying the cash equivalent for unused holidays
Impact date: Awaited. On 29 July 2025, the Government adopted a draft amendment to the Labour 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 the 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).
Employer implications/action needed Employers should monitor the development of the draft legislation.
Employer risk N/A
New mileage allowances for electric vehicles
Impact date: Awaited. The Ministry of Infrastructure has presented draft regulations on mileage allowances, which regulates 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.
Employer implications/action needed Employers should apply the new mileage allowance rates once the regulations are adopted.
Employer risk N/A
End of unpaid internships
Impact date: Awaited. The Ministry of Family, Labour and Social Policy announced the start of work on regulations prohibiting the organization of unpaid internships. These measures are part of a broader initiative at European level to adopt a Directive limiting the possibility of organizing unpaid internships.
Planned changes in the control of sick leave
Impact date: Awaited. The Ministry of Family, Labour and Social Policy has prepared a draft law amending the law on the social insurance system and certain other 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 in accordance with its purpose 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.
Employer implications/action needed N/A
Employer risk N/A
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