From July 2026, Państwowa Inspekcja Pracy (PIP) can reclassify B2B and civil‑law agreements as employment contracts if they display “employment‑like” features. This means that PIP can issue a binding decision turning a B2B or umowa zlecenia/o dzieło into a full employment if the inspector during the audit determines things like subordination, fixed hours or integration into the employer’s organisation.
 
The test for reclassification is not based on the label on the contract, but on the substance of the relationship. PIP will mirror the criteria long used by the Supreme Court in determining whether a genuine employment relationship exists, even if the parties call it something else.

Key red flags: “employment‑like” features

The new framework will treat the following as core indicators of an employment‑like relationship: 
  • Subordination and instructions:
    If the company gives detailed, binding instructions on how and when the work is to be performed, and the contractor has little or no room to decide their own methods, this strongly suggests subordination.
  • Fixed or rigid working hours:
    Requiring the contractor to work at set times, in line with the company’s schedule, or to be available during fixed hours is a classic employment‑like pattern.
  • Control over organisation and performance of work:
    Determining place of work, tools, procedures, deadlines, and performance standards, as well as frequent monitoring or supervision, points away from genuine self‑employment.
  • Integration into the employer’s organisation:
    Treating the contractor as part of the internal team - issuing an email address, access to internal systems, inclusion in internal meetings, performance reviews, or “team‑building”‑type activities - reinforces the impression of an employment‑like relationship.
 
What Polish‑site employers should do now
 
If your company operates in Poland and relies on B2B or civil‑law‑contractor models, July 2026 is not a distant theoretical deadline - it is a trigger date for enforcement risk. Here are the actions that need to be taken:
 
1. Review all B2B and civil‑law‑contractor arrangements
2. Identify “employment‑like” patterns
3. Adjust contracts, structures, and working practices
4. Document independence of your contractors
 
 
Agenda:

1. Brief overview of the 2026 labour‑law shake‑up in Poland

2. What Changes From July 2026?

3. What Turns a B2B into Employment? Key Indicators
 
  • Core criteria from Article 22 of the Labour Code.
  • Practical examples

4. From B2B to Employment: Typical Risk Scenarios
 
  •  Typical flexible business model in Poland:
    • Long‑term B2B contractor integrated into the org chart.
    • B2B treated as de‑facto full‑time staff.

 5. What You Should Do Now - A Compliance Checklist
 
  • Internal audit of all B2B / civil‑law contracts:
  • Pragmatic steps in the organization

6. Tax and Social‑Security Traps If B2B Is Reclassified

7. Q&A: How to Keep B2B Legally Sound Under the New System

8. Closing - Action Plan for Polish‑Based Businesses


Our webinar will be available on YouTube on our channel: https://www.youtube.com/@wozniaklegal

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