
Warsaw law firm Woźniak Legal has issued a practice note reminding companies that, from 1 July 2026, labour inspectors will gain statutory powers to convert civil-law service contracts (B2B agreements, umowy zlecenia, umowy o dzieło) into standard employment contracts if day-to-day reality resembles subordinate work. The alert, published on 7 April, stresses that reclassification decisions will be immediately enforceable, exposing firms to back-payments of social-insurance, tax, paid leave and overtime. The change stems from the December 2025 amendment to the Act on the State Labour Inspectorate, itself part of Poland’s broader immigration and labour-market reform package. Law-makers argue the measure will curb bogus self-employment, often used to engage non-EU nationals without meeting work-permit salary thresholds or paying full ZUS contributions. For global-mobility teams the stakes are high. Many multinationals second IT, marketing and engineering specialists to Polish entities under contractor-of-record models. If inspectors find ‘employment-like’ traits – fixed hours, hierarchical supervision and integration into organisational structures – the relationship will be deemed employment irrespective of contractual labels. That, in turn, requires a work permit or intra-company-transfer (ICT) permit and could trigger fines of up to PLN 30,000 per worker. Woźniak Legal advises a three-step compliance roadmap: (1) audit all contractor engagements; (2) remove or mitigate red-flag indicators such as employer-provided equipment and mandatory office attendance; (3) migrate high-risk contractors onto proper employment contracts and, where applicable, initiate work-permit applications early, as voivodeship offices already report lead times of 8–12 weeks.
At this juncture, many employers are turning to specialist visa facilitators to handle the surge in permit filings. VisaHQ, for example, offers an end-to-end service for Polish work-permit and ICT applications, guiding HR teams through document collation, voivodeship office procedures and post-approval registration; more information is available at https://www.visahq.com/poland/
Failure to act could also affect posted-worker notifications elsewhere in the EU, because authorities share inspection data through the Internal Market Information System (IMI). HR directors are therefore urged to brief line managers and update budgeting models to reflect higher social-security costs from mid-2026.
At this juncture, many employers are turning to specialist visa facilitators to handle the surge in permit filings. VisaHQ, for example, offers an end-to-end service for Polish work-permit and ICT applications, guiding HR teams through document collation, voivodeship office procedures and post-approval registration; more information is available at https://www.visahq.com/poland/
Failure to act could also affect posted-worker notifications elsewhere in the EU, because authorities share inspection data through the Internal Market Information System (IMI). HR directors are therefore urged to brief line managers and update budgeting models to reflect higher social-security costs from mid-2026.