Since 8 July 2026, Poland’s National Labour Inspectorate (PIP) has had genuine tools to convert sham civil law contracts into employment contracts. We covered the new powers in detail in our article on the 2026 reform of the Labour Inspectorate.

This article is about something else: a window that is closing. Parliament gave businesses twelve months to regularise their contracts voluntarily. That window shuts on 8 July 2027, after which the right to the amnesty expires.

The name of the contract does not decide – the working arrangement does

During an inspection, PIP looks at how the work is actually performed, not at the heading on the document. What matters are the features set out in Article 22 § 1 of the Labour Code:

• subordination – work performed under the direction of the hiring party,
• place and time determined by the hiring party,
• personal performance – no genuine right of substitution,
• payment for availability rather than for a result.

Where those features are present, calling the arrangement “B2B” or a “contract of mandate” changes nothing. The Labour Code itself has not changed; what changed is the speed and effectiveness with which existing rules can be enforced.

The reverse point deserves equal emphasis, because it is often lost: the reform does not outlaw self-employment or B2B cooperation. Properly structured civil law contracts remain entirely legal. The target is employment disguised as a business relationship – and telling one from the other starts with how your employment contracts and cooperation agreements are documented.

What an inspector can do

The procedure has two stages.

Stage one – the inspector issues an order to remedy the breach, setting a deadline either to conclude an employment contract or to restructure the cooperation so that it no longer displays the features of employment.

Stage two – if the order is not carried out, the district labour inspector may issue an administrative decision establishing that an employment relationship exists, or refer the case to the labour court.

Three details matter a great deal in practice:

• The decision takes effect from the date it is issued (ex nunc). To capture the entire past period of cooperation, PIP still has to bring a court action seeking a declaration that an employment relationship existed.
• The employer has 30 days to appeal, and the labour court then has 30 days to hear the case.
• Inspections may be conducted remotely, and case selection draws on data cross-referenced from the social security institution (ZUS) and the National Revenue Administration. An inconsistency between the contract, the ZUS registration and the tax filing is itself a trigger.

Employers also gained a preventive tool: an application to the Chief Labour Inspector for an individual interpretation (a PLN 40 fee), binding on PIP bodies. For cooperation models that are genuinely hard to classify, this is a sensible step.

What it costs

Reclassification triggers two independent streams of consequences.

Penalties. The fine for the offence under Article 281 § 1 point 1 of the Labour Code ranges from PLN 2,000 to PLN 60,000, rising to PLN 90,000 for a repeat offence. An inspector may also impose an on-the-spot fine of up to PLN 5,000, or PLN 10,000 on repetition.

Arrears and employee claims. Usually the heavier cost:

• backdated social security contributions (contributions already paid under the civil law contract are credited against those due),
• corrections to tax settlements,
• payment in lieu of untaken annual leave,
• overtime pay,
• other employment-related entitlements.

The scale of these corrections often surprises employers, which is why the exposure is worth quantifying before any decision is taken. Recalculating historical payroll for a reclassified contractor is rarely a five-minute exercise.

The amnesty: what it covers and what it does not

The Act provides a twelve-month protection period running from 8 July 2026 to 8 July 2027.

An employer who, within that period and voluntarily – before any inspector intervenes – concludes an employment contract where the relationship genuinely has the features of employment, will not face liability for the offence committed to date.

And now the critical caveat: the amnesty covers the fine only. It does not write off social security arrears or tax liabilities. ZUS and the tax administration act under their own powers and can pursue amounts due for earlier periods regardless of whether the company relied on the amnesty.

There is also a side effect worth understanding. Voluntarily converting a contract is a clear signal that the previous arrangement was incorrect. For PIP it closes the matter; for the social security and tax authorities it may open one. This is not an argument against using the amnesty – it is an argument for quantifying the consequences before the conversion, not after.

For completeness: the Act has been referred to the Constitutional Tribunal under subsequent review. This does not suspend the provisions, which remain in force.

Not sure whether your B2B contracts would survive an inspection? Write to us and we will review them with you →

A contract audit, step by step

The earlier an issue is found, the more options remain. Once an inspection has begun, room for manoeuvre shrinks sharply – and terminating a contract mid-inspection is often ineffective.

Where to start:

1. Identify contractors who work exclusively for you. No other clients is the first red flag.
2. Check who is subject to your rotas and time records. If a B2B contractor is scheduled like an employee, your own documentation makes the case.
3. Review substitution clauses – can the contractor send someone else, and have they ever done so?
4. Establish whose tools are used and who carries the commercial risk.
5. Reconcile the data across the contract, the ZUS registration and the tax filing.
6. For borderline cases, consider an individual interpretation from the Chief Labour Inspector.
7. Keep the documentation of any voluntary conversion – it is your evidence of relying on the amnesty.

Evidence counts, not declarations. A clause stating that the contractor organises their own work means nothing if practice says otherwise. This is groundwork that sits naturally within ongoing HR and payroll services.

Where the review shows that genuine employment is the honest answer but you have no Polish entity to employ through, an employer of record arrangement is often the cleanest way forward.

Book a conversation and plan your contract audit before the amnesty period expires →

Summary

The PIP reform did not make B2B cooperation or contracts of mandate illegal. What it changed is how effectively inspections can be enforced – and it gave employers a time-limited window to put their own house in order.

That window closes on 8 July 2027. Until then, the company decides on its own terms and at its own pace. After that date, an inspector may decide for it.

Frequently asked questions

Are B2B contracts now illegal in Poland? No. Self-employment and B2B cooperation remain lawful. The reform targets only arrangements where a civil law contract substitutes for a genuine employment relationship.

When does the amnesty end? On 8 July 2027. After that date the right expires.

Does the amnesty cancel social security arrears? No. It covers liability for the offence – the fine – only. Amounts due to ZUS and the tax office must be settled separately.

Can I check in advance whether my model is safe? Yes. You can apply to the Chief Labour Inspector for an individual interpretation describing how the cooperation actually works. The fee is PLN 40 and the interpretation binds PIP.

Can I appeal against an inspector’s decision? Yes, within 30 days. The labour court then has 30 days to hear the case.

Can an accounting firm help with the audit? Yes – both on the HR side and in calculating the social security and tax consequences of a possible reclassification.

Need support?

If you engage people on contracts of mandate or work with B2B contractors and are not certain your model would withstand an inspection, get in touch.

At Easybooks we review contracts against the statutory features of employment, flag areas of elevated risk, and calculate the real financial consequences of a potential reclassification – across social security, tax and employee entitlements. That way, the decision on whether to use the amnesty rests on numbers rather than instinct.