HR Legal Update: B2B reclassification in Poland 2026

Key Changes Effective from 8 July 2026

Starting in July 2026, the Polish Labour Inspectorate (PIP) will gain new powers to reclassify civil law contracts into employment contracts. According to PIP’s announcements, inspectors are already prepared for the first inspections once the regulations enter into force. Employers and HR teams should expect increased scrutiny during the second half of 2026.

What Is Changing?

PIP will be able to independently reclassify B2B cooperation into an employment relationship through an administrative decision — without requiring a prior court judgment.

Who will be affected?

The new regulations will impact on businesses using: B2B contracts (self-employment), civil law agreements (e.g. mandate contracts), and mixed workforce models. The highest risk concerns structures where the same tasks are performed both by employees and contractors operating under B2B and civil law agreements.

What will PIP examine?

PIP will review not only contracts and documentation, but primarily the actual manner in which work is performed, like e.g.:

• supervision and reporting structures,
• level of managerial control,
• integration into internal teams,
• work organization and operational dependency.

How will the inspection process work?

The inspection procedure will follow a two-stage approach:

• Before a reclassification decision, PIP will issue an order requiring the employer to remedy violations related to (i) the functioning of a civil law / B2B contract(s) or (ii) the failure to conclude an employment contract.
• An administrative decision will be issued if the employer fails to comply with the order within the prescribed deadline unless the employer appeals.

Appeals

Companies will have 30 days to appeal the administrative decision before the court.

Potential consequences

A PIP decision may trigger consequences under labour law, tax regulations, social security, health insurance regulations, immigration issues as well as individual management liability. Under the new regulations, Polish authorities — including PIP, Social Security Institution (ZUS), and Tax Office — will be authorized to exchange information and coordinate activities regarding employment classification, payroll, tax, and social security compliance.

As a result, one inspection may trigger parallel reviews by multiple authorities, increasing both financial and operational exposure for companies using B2B and civil law contract structures.

Additional administrative fines may reach up to EUR 15,000.

Recommended actions

Companies should consider immediate audit:

• review of existing B2B and civil law contracts
• assessment of actual cooperation models
• identification of legal and operational risks
• elimination of weak compliance areas
• communication and training for managers and HR teams

Why act now?

Important! B2B contracts are still legal and may be fully valid, provided that the actual working relationship does not meet the criteria of an employment contract. There are just several weeks left for preparation.

Early analysis will help companies:

• reduce financial exposure,
• avoid sudden operational disruptions,
• implement safer cooperation models,
• prepare for inspections by PIP, ZUS and tax authorities.