8 July 2026

The National Labour Inspectorate with new powers regarding civil law contracts and B2B contracts

On 8 July 2026, new regulations come into force amending the manner in which the National Labour Inspectorate monitors civil law contracts. Key aspects of the reform are as follows:

  • Two-stage reclassification procedure: first, inspectors issue an initial notice to convert a contract; then, if not heeded, a binding administrative decision establishing the existence of an employment relationship is issued.
  • Assessment of the actual nature of a working relationship: labour inspectors have the power to unilaterally reclassify civil law contracts as employment contracts; their assessment is based on the actual nature of a working relationship, rather than on the content of a written contract or its formal provisions.
  • Higher financial penalties: fines range from PLN 2,000 to PLN 60,000, and in the case of serious breaches, up to PLN 90,000.
  • Right of appeal: the employer may appeal to a labour court within one month; however, lodging an appeal does not automatically suspend enforcement of a reclassification decision.

In practice, situations where working arrangements that involves direct supervision and ongoing issuing of instructions, fixed working hours and a fixed place of work, exclusive use of the engaging party's equipment, integration into internal reporting structures, or economic dependence on a single client are particularly at risk of reclassification.