New regulations on the Government Legislation Centre website
On September 1, 2025, the Government Legislation Centre (RCL) published a draft amendment to the PIP Act. The government recognized that existing measures to combat so-called “fictitious contracts” and “false self-employment” are insufficient. The aim of the reform is to provide better protection for people who effectively work as employees but are formally employed under other arrangements. The new regulations will come into force on January 1, 2026, and will also apply to contracts concluded before that date. Inspections initiated earlier will continue under the current rules.
Current situation
Currently, a PIP inspector can:
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issue a recommendation or order to change a contract,
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apply to the labour court to determine the existence of an employment relationship,
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impose a fine or submit a request for punishment under Article 281 §1 point 1 of the Labour Code.
However, these procedures are lengthy and often ineffective due to evidentiary difficulties.
Administrative decision on employment relationship
The most significant change will be the possibility for a regional labour inspector to issue an administrative decision stating that a person is, in fact, performing work under the conditions defined in Article 22 §1 of the Labour Code. In practice, this means that an inspector will be able to convert a civil law contract into an employment contract if they determine that the worker operates under the employer’s direction, at the location and times specified by the employer. The decision will include, among other things: type of contract, start date, working hours, place of work, and salary (at least the minimum wage).
Appeal system
An appeal against the inspector’s decision can be submitted to the Chief Labour Inspector within 7 days. In case of further dispute, the matter can then be referred to a labour court within a month. A new feature will be so-called self-review: the Chief Labour Inspector will be able to amend the decision if the appeal is deemed justified.
Immediate enforceability
The inspector’s decision will be immediately enforceable. Despite the appeal, the employer will be required to:
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pay the salary,
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maintain employee records,
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register the employee with ZUS and pay contributions,
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ensure full employee rights, including leave entitlement.
Remote inspections and inter-agency cooperation
The amendment allows for remote inspections using videoconferencing and recordings. Inspectors will be able to interview witnesses online.
Cooperation between PIP, ZUS, and the National Revenue Administration will also be strengthened — data will be shared to identify companies for inspections based on risk analysis.
New obligations and penalties
PIP will be required to prepare annual and multi-year inspection plans. Financial penalties will also increase significantly:
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fines for violations of employee rights up to PLN 60,000 (currently PLN 30,000),
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administrative penalties up to PLN 5,000, and in case of repeat offenses, up to PLN 10,000.
Purpose of the reform: combating “false self-employment”
The government argues that the changes aim to curb the misuse of civil law contracts and so-called self-employment, which are often used to circumvent labour law and social security costs. The new powers of PIP are intended to accelerate the state’s response in situations where a person effectively works as an employee but is formally treated as a contractor or self-employed.
