Nowe uprawnienia Państwowej Inspekcji Pracy od 2026 r. - New powers of the National Labor Inspectorate from 2026
14.04.2026 Labour law

New powers of the National Labour Inspectorate from July 2026 – the Act signed and announced.


The expansion of the National Labour Inspectorate’s (PIP) authority will soon become a reality. On April 7, 2026, the PIP reform law was published in the Journal of Laws. District PIP inspectors will be authorized to issue administrative decisions regarding the conversion of civil law contracts into employment contracts. However, this will not be an action taken by the inspector alone, but rather the result of a multi-stage process that should ensure the protection of all stakeholders.

The National Labor Inspectorate (PIP) reform – a bill announced and referred by the President to the Constitutional Tribunal. What changes will it bring for employers? 

On April 2, 2026, the President signed the National Labor Inspectorate (PIP) reform bill, simultaneously referring it to the Constitutional Tribunal for review. On April 7, the new regulations were published in the Journal of Laws , and they will enter into force three months after that date, on July 8, 2026. 

What does this mean for employers and how to prepare for the changes?

PIP will gain greater control powers and tools to enforce labour law more quickly

The new regulations are intended to allow labour inspectors to determine the existence of an employment relationship if a given cooperation agreement actually meets the requirements of Article 22 §1 of the Labour Code – that is, when an individual performs work of a specified type under supervision, at a specified time and place, for remuneration. In the event of an inspection, the employer will first receive an order to remedy the violations, and if the order is not followed, they may receive an administrative decision establishing an employment relationship. The decision will not be retroactive. 

What risks does the employer face?

In practice, the new PIP rights may mean for employers: 

  • the obligation to register the employee with the Social Insurance Institution (ZUS) – payment of ZUS contributions and PIT advances, 
  • new employee claims – including for leave, overtime pay, severance pay,
  • financial sanctions for violation of labour law,
  • difficulties in using a flexible employment model , e.g. in B2B cooperation,
  • litigation in situations where inspectors’ decisions will have to be challenged.

For many organizations, changes may have serious budgetary and image consequences, especially if the scale of cooperation based on civil law contracts is large.

B2B contracts – what should you do today to reduce the risk of your contract being challenged?

It is worth using the time before the new regulations come into force to organize cooperation models in order to reduce the risk of PIP questioning contracts. 

Key activities include: 

Review of applicable civil law contracts (contracts of mandate, contracts for specific work, B2B) in terms of the presence of elements characteristic of an employment relationship. 

Assessment of the practice of performing contracts – whether the actual circumstances of cooperation do not indicate subordination in the principal-contractor relationship. 

Modification of contract provisions and cooperation principles to emphasize their civil law nature and separation from the employment relationship. 

Preparation of internal procedures and training for people managing teams or contractors. 

New PIP entitlements – how can we help? 

The TGC Corporate Lawyers and Crowe team supports employers in preparing for change by: 

  • audit of civil law contracts – identification and assessment of the risk of recognizing them as an employment relationship, 
  • legal and tax advice – development of recommendations regarding the content of contracts and cooperation practices, 
  • preparing the organization for a PIP inspection – including a review of procedures, documentation and internal communication rules, 
  • advice on various employment models – tailored to business needs and industry specifics. 

What is the difference between an employment contract and a B2B contract?

The fundamental difference concerns the nature of the dependence and responsibility of the parties

An employment contract assumes subordination – the employee performs tasks under the employer’s direction, at a designated time and place, using tools provided by the company. The employer is responsible for organizing the work and pays remuneration regardless of results.

A B2B contract is a business cooperation – a person running a business operates independently, bears the economic risk of this activity, decides on the time and place of performing tasks, may provide services to many clients and is responsible for the results of his or her work.

If a B2B contract in practice resembles an employment relationship, e.g. there are fixed hours, supervision by a supervisor, work at the company’s headquarters, no risk on the part of the contractor, the National Labor Inspectorate may recognize such a relationship as employee employment and transform the concluded civil law contract into an employment contract.

Checklist for employers – are your B2B contracts secure? 

Does every civil law contract have a clearly defined scope of services, result and method of settlement 

Does the employee independently decide on the place, time and manner of performing work?  

Is he/she not subject to ongoing management, evaluations or instructions from superiors typical of an employment relationship? 

Is the remuneration dependent on the effect or the number of services provided , and not on attendance at work? 

Does the associate have the ability to provide services to other clients and does he or she actually use this opportunity? 

Does the company have documentation confirming the nature of the cooperation (contract, reports, invoices, correspondence)?

Does the collaborator have his/her own work tools (computer, telephone, software, licenses)? 

Does the contract clearly state that the contractor bears the economic risk (e.g. liability for errors, material costs)? 

Does the contract include provisions on independent organization of work and responsibility for the result

Do managers in the organization understand the differences between B2B and employment relationships and are able to enforce them in practice? 

Does the company periodically audit civil law contracts and update their content in accordance with applicable regulations? 

If the answer to any of these questions is “no”, it is worth considering an audit and correction of the rules of cooperation. 

B2B contract and employment contract – employers’ most frequently asked questions

1. When can a B2B contract be considered an employment relationship? 

2. What is the risk to the company if the contract is transformed by PIP? 

3. How can I check if my B2B contracts are secure? 

4. Can the B2B model be maintained after the PIP reform? 

Do you need support with employee contracts? 

We support employers in preparing for upcoming changes.  
 
We provide: 

  • audit of civil law contracts and risk identification, 
  • recommendations for changes in contracts and cooperation models.


Magdalena Wilkoszewska Director of The Labour Law Department, Attorney-At-Law
TGC Corporate Lawyers
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