Poland: 2026, Looking Ahead

The year 2026 will bring numerous labour law reforms in Poland. Changes will affect both employer obligations and employee rights — from pay transparency, new rules for calculating length of service, and administrative reclassification of civil-law contracts, to an increase in minimum wage, reform of collective agreements, and clarification of provisions on mobbing and discrimination. Employers can also expect simplifications in HR documentation and new regulations concerning sick leave.

1. Partial implementation of the Pay Transparency Directive (EU) 2023/970

Gender-neutral job titles, mandatory disclosure of salary information to job candidates, and increased pay transparency

On 24 December 2025, amendments to the Labour Code will enter into force to increase transparency in the recruitment process and strengthen the principle of equal treatment.

After the new regulations take effect, employers will be required to:

• use gender-neutral job advertisements and job titles;
• disclose in the job posting, before the interview, or before employment begins, information about pay — its initial amount or range — based on objective and neutral criteria;
• provide information on relevant provisions of collective labour agreements or remuneration regulations (if applicable); and
• ensure that the recruitment process is non-discriminatory.

Additionally, employers will no longer be allowed to ask candidates about their previous remuneration.

The second draft act implementing Directive EU 2023/970 is under development and is expected to introduce, among other things:

• an obligation to maintain gender-neutral pay structures based on skills, effort, responsibility, and working conditions;
• the right of employees to obtain information about pay-setting principles and average pay levels within their job category (broken down by gender);
• mandatory reporting for employers with at least:
  • 100 employees – report every three years
  • 250 employees – annual report
• reports covering, among other metrics: overall gender pay gap, median pay gap, median gap in variable components, and gender distribution across pay brackets;
• a mandatory joint pay assessment with trade unions or employee representatives if a pay gap of at least 5% is found within a job category and is neither justified nor remedied within six months; and
• fines ranging from PLN 2,000 to PLN 60,000 for violations, including failure to conduct job evaluation or failure to provide required data.

2. Changes to calculating length of service

Including self-employment and civil-law contracts in length of service

New regulations will soon take effect under which periods of running a business, performing work under mandate and agency contracts, and other forms of professional activity will count towards length of service.
The aim is to equalise employee rights regardless of previous type of professional activity. As a result, more people will become eligible, for example, for extended (26-day) annual leave.
The new provisions will apply:

• from 1 January 2026 – in the public finance sector
• from 1 May 2026 – in all other sectors

The law will also apply retroactively. Earlier periods of mandates, self-employment, cooperation, or work abroad (outside an employment relationship) may be credited towards length of service, provided they are properly documented.

3. Administrative reclassification of civil-law contracts as employment relationships

Reform of the National Labour Inspectorate (PIP)

Work is underway on legislation that will allow the National Labour Inspectorate (PIP) to determine the existence of an employment relationship when the parties have concluded a civil-law contract, but the actual conditions indicate an employer–employee relationship. Although the final wording of the act remains uncertain, it is clear that the ability to determine employment status by administrative decision will be introduced. The current draft provides, among other things:

• immediate effect of a decision establishing an employment relationship — effective from delivery until overturned by the Chief Labour Inspectorate, a court, or until the employment relationship is terminated,
• the ability to determine an employment relationship retroactively for up to three years.

4. Deregulatory changes in labour law

Abolition of the written form requirement for many HR documents, new rules for payment of unused leave compensation, and changes to the Company Social Benefits Fund (ZFŚS)

On 4 December 2025, the Sejm adopted a law replacing the current requirement for written form of many HR documents with the possibility of using paper or electronic form — for example, information on monitoring, working time schedules, or trade-union consultations on termination of employment and many others. The amendment is expected to significantly simplify HR processes and the digitization of employee documentation.

Other elements of the law include:

• introduction of a new deadline for paying compensation for unused annual leave — it will be paid on the salary payment date, and if that would fall before termination of employment, then within 10 days of its end (with mandatory earlier payment if the date falls on a day off);
• new rules for agreeing matters related to the Company Social Benefits Fund — in workplaces without trade unions, agreements will be concluded not with a single selected employee but with employees elected by the workforce.

The changes are expected to enter into force at the beginning of 2026.

5. Increase in minimum wage

From 1 January 2026, the minimum wage will increase to PLN 4,806 gross, and the hourly rate for mandate and service contracts will rise to PLN 31.40. This change will automatically increase all benefits and payments linked to the minimum wage, including night-work allowance, minimum amount exempt from deductions, downtime pay, and severance pay limits.

6. Collective labour agreements

13 December 2025 – entry into force of the Act on Collective Labour Agreements and Collective Arrangements

The Act introduces, among other things:

• a broader scope of matters that may be covered by collective agreements;
• the possibility of covering persons working under non-employment arrangements;
• formal inclusion of a mediator in the bargaining process;
• creation of the National Register of Collective Labour Agreements, where agreements, arrangements, and additional protocols will be recorded; and

an obligation for the Minister of Labour to report the collective bargaining coverage rate and develop plans supporting its growth.

7. Changes regarding prevention of discrimination and mobbing

New definition of mobbing
Work is underway on a new definition of mobbing, defining it as persistent harassment that may be physical, verbal, or non-verbal in nature. Single incidents will not qualify as mobbing — conduct must be repetitive, constant, or recurring.
The draft provides that the minimum compensation for mobbing will amount to 12 times the minimum wage. Additionally, in mobbing-related proceedings, the court will also examine other violations of the employee’s personal rights.

Employers will not be liable for mobbing by co-workers or subordinates if they demonstrate that effective preventive measures were taken. If compensation is paid, the employer may seek reimbursement from the perpetrator.

The draft also clarifies statutory definitions of discrimination, adding, among others:

• discrimination by association – when unequal treatment is based on a characteristic of a person associated with the employee
• discrimination by assumption – when the employer incorrectly attributes a particular characteristic to the employee

The proposal also introduces additional obligations concerning anti-discrimination and anti-mobbing procedures and clarifies methods for preventing violations.

8. Changes to sick leave rules

Greater flexibility in issuing sick leave for people working in various forms across multiple workplaces

On 21 November 2025, the Sejm adopted a law providing for:

• the possibility, at the insured person’s request, to avoid issuing sick leave for one of the employment titles where the work can still be performed due to its nature;
• an obligation for employees to inform their employer about the period for which sick leave was issued under another employment title;
• a single benefit period, regardless of the number of titles to sickness insurance; and
• loss of entitlement to sickness benefit if the employee engages in gainful activity during sick leave or undertakes activities inconsistent with the purpose of the sick leave.

The changes are expected to enter into force at the beginning of 2026.

9. A pilot program for reduced working hours will be launched in 2026

90 employers will test various forms of reduced working hours.

On January 1, 2026, the practical stage of the reduced working hours program will begin and will last until December 31, 2026. The project aims to test one of the ways to reduce working hours on a sample of over 5,000 employees working for both private and public sector employers, who will receive remuneration not lower than that applicable on the date of commencement of the project:

• reducing the number of working days per week
• reducing the number of working hours on individual days
• reducing the number of working hours through additional days off per month
• granting additional days off in the form of vacation leave
• possibly other models tailored to the specific nature of the employer

The results of the program will be known in May 2027, when employers submit their reports on the results of the pilot program.