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New Powers of the Polish Labour Inspectorate and B2B Contracts in Poland: What awaits employers and contractors from 2026? | News Flash

December 22, 2025
Accace - New Powers of the Polish Labour Inspectorate and B2B Contracts in Poland

As Poland approaches 2026, HR departments and compliance teams are intensively analyzing government legislative work affecting the Polish labor market. A central topic is the ongoing amendment of the Polish Labour Inspectorate (PIP) Act, focusing on the new powers of the Polish Labour Inspectorate and B2B contracts in Poland. This draft legislation, aligned with milestones of Poland’s National Recovery Plan (Krajowy Plan Odbudowy), introduces significant changes in verifying employment relationships, including the potential reclassification of civil law contracts.

Recent updates indicate a shift from the most stringent measures proposed in the original draft, with attempts to incorporate market feedback and address concerns about B2B contracts and their relationship with employment contracts.

Understanding the New Powers of the Polish Labour Inspectorate in relation to B2B contracts in Poland

The planned regulations aim to equip the Polish Labour Inspectorate (PIP) with more effective tools to verify employment bases, with special attention to self-employment (B2B) arrangements. The legislative intent is to reduce irregularities in the Polish labor market and ensure compliance with conditions tied to the National Recovery Plan funding.

Concerns for employers regarding the New Powers of the Polish Labour Inspectorate

The initial draft of the law regarding new powers of the Polish Labour Inspectorate and B2B contracts in Poland, reviewed by the Standing Committee of the Council of Ministers in late November 2025, caused concern among Polish businesses. It proposed granting inspectors the authority to convert civil law contracts, including B2B agreements, into employment contracts via immediately enforceable administrative decisions.

A major risk for Polish entrepreneurs was the potential retroactive application for up to three years, which would require settling outstanding obligations, including social security contributions and taxes. Consequently, many companies—especially those relying on B2B cooperation with specialists—undertook audits to identify and mitigate legal risks.

Standing committee of the Council of Ministers Meeting and updates on PIP Powers

According to information from the Standing Committee meeting on 4 December 2025, the draft law was significantly revised. Although the final text has not yet been published, preliminary information suggests that some market concerns were incorporated, and the originally strict enforcement procedure has been softened. Key provisions now include:

  • Priority for corrective measures – inspectors will first issue directives to align contracts with legal requirements if irregularities are detected.
  • Respect for contractual parties’ choices – the decision on whether to convert a B2B contract into an employment contract or modify a civil law agreement will primarily rest with the contracting parties.
  • Administrative decisions as a last resort – conversion decisions will only be applied when parties fail to reach an agreement or continue violating regulations, with the option for judicial review.

Legal and Financial Consequences – A Prospective Perspective

A significant announced change is the elimination of automatic retroactive effect of conversion decisions by labor inspectors. According to government representatives:

  • Conversion decisions will have legal and financial effects—including social security and tax obligations—only from the moment of issuance (ex nunc).
  • Claims concerning previous periods will require a court ruling.

Summary

Although the official draft has not yet been published, the direction of the changes reflects a balance between market interests and regulatory goals. Further legislative work is expected in the first quarter of 2026.

However, businesses in Poland should note that the relaxation of inspection procedures does not exempt them from ensuring that B2B contracts comply with the Polish Labor Code. This period is ideal for conducting legal audits and analyzing employment structures before the new regulations take effect.

How Accace Legal can support you

Accace Legal offers comprehensive support to Polish companies preparing for the new powers of the Polish Labour Inspectorate and B2B contracts in Poland. Our services include:

  • Legal audits of B2B and civil law contracts
  • Risk assessment of potential contract reclassifications
  • Advice on adapting collaboration models to comply with Polish law

With our support, companies can minimize legal and financial risks and prepare effectively for the implementation of new PIP regulations.

Contact us to learn how we can help your organization navigate these upcoming changes.

Michał Mostrąg
Senior Associate | Accace Poland
Get in touch with us
Agnieszka Samborska
Legal Adviser and Partner | Accace Poland
Book a meeting with Agnieszka
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