New National Labour Inspectorate (PIP) Powers - What Will Change for People on B2B Contracts?

Reform of the National Labour Inspectorate (PIP) - a Breakthrough for the B2B Market in Poland

On 12 March 2026, the Senate of the Republic of Poland adopted without amendments the revision of the Act on the National Labour Inspectorate (PIP). The vote ended with 57 votes in favour, 1 against and 31 abstentions. The act now goes to the President's desk, and once signed it will open the way to one of the most far-reaching changes in Polish labour law in recent years.

The reform concerns primarily people working under civil-law contracts and as sole proprietors (so-called B2B) whose cooperation with the commissioning entity in reality bears the hallmarks of an employment relationship. The new rules give labour inspectors tools that will allow them, by way of an administrative decision, to convert such sham contracts into full employment contracts.

Passing this regulation is one of the so-called milestones of the National Recovery Plan (KPO), on which the payment of further EU funds to Poland depends. This means the pressure to actually implement the new rules is exceptionally strong, both politically and financially.

What Will the Contract Conversion Procedure Look Like? Step by Step

The revision introduces a multi-stage, graduated procedure whose aim is, first of all, to resolve the situation amicably. Only when milder measures fail will the inspector resort to powers of enforcement.

Stage 1 - Hearing the Parties and the Labour Inspector's Instruction

If a labour inspector finds that the legal relationship between the parties is dominated by the features of an employment relationship (including work performed under direction, at a place and time set by the principal, for remuneration), they must first hear both parties. They then issue an instruction concerning the operation of the civil-law contract or the non-conclusion of an employment contract.

Stage 2 - The Parties' Response to the Instruction

After receiving the instruction, the parties have several options:

• Concluding an employment contract - if the employer and the employee decide to sign an employment contract and the inspector approves this step, the proceedings end with no further administrative action.
• Modifying the civil-law contract - the parties may restructure their relationship so as to eliminate the elements characteristic of an employment relationship (e.g. abolish the obligation to perform the work personally, introduce flexible timing for carrying out assignments). The inspector will assess whether the changes are sufficient.
• No response or a negative assessment by the inspector - in this case the matter moves to the next stage.

Stage 3 - Administrative Proceedings or a Court Claim

If the instruction is not complied with, or the inspector negatively assesses the changes introduced, the regional labour inspector opens administrative proceedings. These proceedings may end in:

• a decision establishing the existence of an employment relationship, or
• a claim brought before the court seeking a declaration of the existence or content of an employment relationship.

Importantly, during the proceedings the intention of the parties will be taken into account, provided it is not contrary to the law or to principles of social coexistence and does not aim to circumvent labour law provisions.

Appealing Against a Decision - What Should a Business Owner Know?

One of the most important elements of the new regulation, and at the same time one of the biggest concessions to businesses compared with the original draft, is the appeal mechanism:

• The deadline for appeal is 30 days from service of the regional labour inspector's decision.
• The appeal is lodged with the court, which should consider it within one month.
• Lodging an appeal suspends enforcement of the decision - until the court issues a final ruling, the inspector's decision is not enforceable. There is therefore no immediate enforceability clause, which caused the greatest controversy during the legislative process.

An exception applies to people covered by special protection against notice or termination of an employment contract - for example pregnant women. In their case, the decision may be given immediate enforceability before the appeal is decided.

Transitional Period - 12 Months to Regularise the Situation Voluntarily

The legislator has provided a significant incentive for entities that have so far relied on sham civil-law contracts or B2B contracts. An entity that, within 12 months of the act's entry into force, voluntarily concludes an employment contract with a person with whom it has a relationship bearing the features of employment will not be held liable under the Labour Code.

This is a kind of amnesty - a chance to put relationships in order without financial or legal consequences. It is worth treating it as an opportunity for an internal audit of all contracts with people working on a B2B or commission basis, before the new PIP powers take full effect.

What Else Does the Revision Change? Remote Inspections, Data Exchange and Higher Penalties

The PIP reform is not only about converting contracts. The revision also introduces a number of solutions strengthening the inspection apparatus:

• Remote inspections - labour inspectors gain the ability to carry out inspections without physically attending the business owner's premises, which will significantly speed up and simplify inspection activities.
• Data exchange between the Social Insurance Institution (ZUS), PIP and the National Revenue Administration (KAS) - these bodies will share information for the purposes of risk analysis and ongoing inspections. This means that inconsistencies between tax returns, ZUS contributions and the nature of the work performed will be easier to detect.
• Higher penalties for offences against employee rights - the revision tightens sanctions, which is intended as an additional deterrent.

After 12 months from the entry into force of the provisions, the minister responsible for labour will prepare an assessment of how the act operates and present it to the Marshal of the Sejm, the Social Dialogue Council and the Labour Protection Council.

When Will the New Rules Come into Force?

The act will come into force 3 months after its publication in the Journal of Laws (with certain exceptions for individual provisions). This means that, assuming the President signs it and it is published without delay, the new regulations could start to apply as early as summer 2026. Adding the 12-month transitional period, business owners realistically have a little over a year to fully adapt their cooperation models.

What Should You Do Now? Contact Our Firm

The new PIP powers mean a fundamental change in the legal environment for thousands of Polish companies using the B2B model. Whether you are a business owner engaging collaborators on contracts or a person providing services as a sole proprietor, you should now:

• carry out an audit of your current contracts for features of an employment relationship,
• assess the legal risk associated with your existing cooperation model,
• consider using the 12-month transitional period and regularising the situation voluntarily,
• prepare for the possibility of a remote PIP inspection and data exchange with ZUS and KAS.

Do not wait for a labour inspector's visit. Contact our firm - we will help you analyse your contracts, assess the risk and plan a safe transition to the new rules. Call or write to us today to arrange a consultation.