A draft amendment to the Act on the National Labour Inspectorate (PIP), included in the government’s legislative agenda in August, is currently under review. The Ministry of Family, Labour and Social Policy proposes granting PIP the authority to reclassify improperly concluded civil law contracts into employment contracts. Employers are most concerned about this new power, though the Chief Labour Inspector has assured that it will be used with caution. Inspectors would also gain access to data from the Social Insurance Institution (ZUS) and the National Revenue Administration (KAS) and be allowed to conduct remote inspections.
Stronger Enforcement Tools
The strengthening of PIP’s competences is one of the milestones in Poland’s National Recovery and Resilience Plan (KPO). The reform would allow data exchange between PIP, ZUS, and KAS for inspection and risk analysis purposes.
“This will help us better target inspections, making them more effective. With access to this data, we will be able to carry out risk analyses and identify entities that are likely violating labour law,” said Marcin Stanecki, Chief Labour Inspector, in an interview with Newseria.
The amendment also introduces remote inspections, enabling inspectors to request documents and conduct online hearings. The aim is to improve efficiency while reducing the burden on businesses.
“Remote checks will let us receive documents electronically and avoid long on-site visits. Inspectors will even be able to view working conditions live online to verify occupational safety. Inspection protocols will be signed electronically, reducing formalities for employers, who will still retain the right to submit objections,” Stanecki explained.
Reclassification of Civil Contracts
A major change is giving PIP the power to reclassify civil contracts, including B2B agreements, into employment contracts by administrative decision. Currently, if inspectors determine that a civil contract in reality meets the criteria of an employment relationship, they can recommend changing the legal basis, file a lawsuit in a labour court, or initiate misdemeanor proceedings. Under the new law, they would instead issue an administrative decision.
According to Statistics Poland (GUS), as of March 2025, more than 1.4 million people in Poland were employed under contracts of mandate and similar civil law agreements—an increase of 5.5% year-on-year.
“I can assure you this tool will be used prudently. There will be a two-stage appeal process: the decision will first be issued by a regional inspector, with the possibility of appeal to the Chief Inspector and then to a labour court. Honest employers using civil contracts properly have nothing to fear—we are targeting only those cases that circumvent labour law,” Stanecki said.
PIP has long sought such powers, describing contract reclassification as a long-awaited reform.
Potential Scale and Employer Penalties
Currently, about 50,000 complaints are filed annually regarding civil law contracts. PIP expects this number to grow significantly once the reform is in place.
If an inspection finds irregularities and a contract is reclassified, the employer will be required to pay back-dated social security contributions and taxes, as well as update employment records, settle overtime, and grant unused vacation.
The amendment also doubles fines: using a civil contract in place of an employment contract could result in penalties of up to 60,000 PLN, in addition to the costs of reclassification.
Budget and Timeline
The draft provides for a 10% increase in PIP’s budget. The government plans to adopt the amendment in the fourth quarter of 2025, with implementation scheduled for early 2026.
