On 8 July 2026, the most significant changes in years to how Poland’s National Labour Inspectorate (PIP) operates came into force (Act published as Dz.U. 2026 item 473). The reform aims to more effectively counter situations where people working under conditions typical of an employment relationship are engaged on civil-law contracts or as self-employed (B2B), even though the rules say they should have an employment contract.

Importantly, the reform does not ban B2B cooperation or civil-law contracts. They remain a legal and widely used form of cooperation. What changes is how the long-standing rules are enforced.

Not sure whether your B2B or civil-law contracts are safe? Check in a few minutes with the free B2B Contract Risk Test by easybooks.

The key change – new PIP powers

Until now, PIP could point out irregularities and refer cases to the labour court. From 8 July 2026, a district labour inspector can issue an administrative decision establishing an employment relationship and ordering the conversion of an incorrectly concluded contract into an employment contract. Previously, only the courts had this power.

This does not mean automatic challenges to all B2B or civil-law contracts. A decision can be issued only after an inspection confirms that the actual conditions of cooperation meet the criteria of an employment relationship under Article 22 of the Labour Code – which, notably, has not changed.

When can cooperation be reclassified as employment?

The risk of a challenge rises mainly when a person:

• performs the work personally,
• remains under the direction or supervision of a manager,
• works at a place and time set by the company,
• is paid based on working time,
• cooperates exclusively with one entity.

In such cases the contract’s name is irrelevant – what counts is the actual nature of the relationship. The more of these elements occur together, the higher the risk.

Want to know how many of these apply to your company? Take the B2B Contract Risk Test – answer a few questions and see your risk level.

How does the procedure work?

The new rules set out a multi-stage process.

1. Inspection. It can be triggered by a complaint, by analysing data from ZUS (social security) and the National Revenue Administration (KAS), or as part of PIP’s planned activities. A novelty is the option to conduct part of the inspection remotely.

2. Order to remedy irregularities. If the inspector finds irregularities, they first issue an order to remedy them. The employer is given time to voluntarily adjust the cooperation model.

3. Administrative decision. Only if the order is not carried out can the district labour inspector issue a decision establishing an employment relationship.

Both the employer and the worker can appeal to the labour court within 30 days. As a rule, filing an appeal suspends the decision – unless it has been given immediate enforceability.

Higher fines and more effective inspections

The reform also introduces:

• higher penalties for labour-law breaches,
• broader data sharing between PIP, ZUS and KAS (including risk-based targeting using data such as from the national e-invoicing system, KSeF),
• the option to obtain an individual interpretation from the Chief Labour Inspector (a PLN 40 fee),
• risk-based inspection plans.

This should let the inspectorate identify incorrect employment models more effectively, while law-abiding companies should be inspected less often.

Note: the PIP decision applies going forward – but ZUS and KAS do not

This is one of the most important, often overlooked aspects of the reform. The PIP decision establishing an employment relationship applies going forward (from the date it is issued). However, ZUS and KAS act independently and, under their own powers, can pursue unpaid contributions and taxes up to five years back. A single PIP inspection can therefore trigger contribution and tax proceedings for prior years.

There is also an anti-retaliation rule: terminating a B2B contract during an inspection may result in the employment relationship being deemed established retroactively from the inspection start date.

You have until 8 July 2027 – a 12-month amnesty

The reform provides a 12-month amnesty (from 8 July 2026 to 8 July 2027) during which companies can voluntarily put their contracts in order without the risk of a fine. It is a real window to make changes safely – but only for those who act before an inspector knocks. Once an inspection begins, the room for manoeuvre shrinks dramatically.

What should employers do?

For most companies the reform is not a revolution, but it should prompt a review of civil-law and B2B contracts. Pay particular attention to contractors who:

• work exclusively for one entity,
• work fixed hours,
• are subject to ongoing supervision,
• use the company’s tools and infrastructure.

Elevated risk applies especially to IT, logistics, e-commerce, construction, marketing and consulting.

Check your B2B contract risk – start with the free easybooks test

Don’t wait for an inspection. The best way to reduce risk is to audit your contracts while the amnesty lasts. Start with a quick self-assessment:

👉 Take the free B2B Contract Risk Test – answer a few short questions and check whether your cooperation model is ready for the PIP reform.

If the test flags a risk, the easybooks team can run a full contract audit, adjust your documentation and procedures, and safely reorganise your employment model before the amnesty window closes. Get in touch with easybooks and ensure compliance with the new rules.

Frequently Asked Questions (FAQ)

Does the PIP reform ban B2B contracts? No. B2B cooperation and civil-law contracts remain legal, as long as they reflect a genuinely independent relationship between the parties.

Can PIP convert my B2B contract into employment on the spot? Not on the spot. First there is an inspection and an order to remedy irregularities. Only if that order is ignored can the district inspector issue a decision – which can be appealed to the labour court.

Does the PIP decision apply retroactively? The PIP decision itself applies going forward. However, ZUS and KAS can independently pursue arrears up to five years back.

How long does the amnesty last? Until 8 July 2027 – during this period you can voluntarily put your contracts in order without the risk of a fine.