Poland considers empowering labour inspectors to confirm employment status

At a glance

• A new version of the bill amending the Act on the State Labour Inspectorate (PIP) was published on 4 November 2025.
• The Polish government is considering introducing new powers for labour inspectors to determine the existence of an employment relationship.
• There have been some changes compared to the previous versions of the bill, primarily regarding the possibility of reaching a settlement during the proceedings before the labour court.
• Although these changes are still scheduled to take effect in early 2026, this now appears highly unlikely.

As noted in a previous post, the bill empowers PIP inspectors to issue administrative decisions confirming an employment relationship without referring the matter to a labour court, as was previously required. The court route remains available, but the choice of method will rest with the inspector conducting the inspection.

According to the latest version of the bill, the deadline for appealing to the Chief Labour Inspector (GIP) against a PIP inspector’s decision will be seven days from the receipt of the decision. If the appeal is dismissed, a further judicial remedy will be available, ie within one month of receiving the GIP decision, the appellant may file a claim with a district court via GIP. 

In contrast to the previous version, the latest bill gives the parties involved in the proceedings the possibility of reaching a settlement only with the approval of GIP.

In addition to these changes, the new bill also provides for a double increase in financial penalties imposed by the State Labour Inspectorate (ie from PLN1,000-30,000 to PLN2,000-60,000).

However, at this stage, there are still many doubts regarding the practical application of the bill.

Although it is still planned for the changes to enter into force at the beginning of 2026, this is rather unlikely as the bill is still subject to legislative work at the government level and has not yet been submitted to the Sejm (the lower house of the Polish Parliament) for consideration.

Despite the uncertainty about when the proposed changes will enter into force, it is advisable for employers to take appropriate steps now to review existing civil law contracts and how they are performed. In particular, employers should:

• Review the content of civil law contracts to ensure that they do not contain elements typical for an employment relationship (subordination, fixed working hours, integration into the employer’s organisation, etc).
• Examine how civil law contracts are performed in practice (in particular, whether they are performed in the same way as employment contracts).
• Consider proactive compliance measures, including legal audits and training on contract classification.