Poland: New PIP Powers to Reclassify B2B Contracts from 8 July 2026

From 8 July 2026, the National Labour Inspection (PIP) may reclassify civil-law agreements and B2B contracts as employment contracts where these arrangements display “employment-like” features.

Typical “employment-like” features under Polish labour law include:
 

• Subordination: where the company gives detailed, binding instructions on how and when work is to be performed, and the contractor has little or no autonomy in deciding how to carry out the work, this strongly indicates subordination.
• Fixed or rigid working hours.
• Control over how and when work is performed: determining the place of work, tools, procedures, and deadlines, as well as frequent monitoring or supervision, points away from genuine self-employment.
• Integration into the company’s organisation: treating the contractor as part of the internal team - by issuing a company email address, granting access to internal systems, involving them in internal meetings, performance reviews, or team-building activities - reinforces the impression of an employment-like relationship.
• Lack of independent business risk: a genuinely self-employed person typically bears commercial risk, whereas a contractor who effectively works as an extended employee for a single principal is more likely to be reclassified.

 
The test for reclassification is not based on the contractual label but on the substance of the relationship. PIP will apply criteria long established by the Supreme Court when determining whether an employment relationship exists, regardless of how the parties describe it.
 
What Polish-based employers should do now
 
If your company operates in Poland and relies on B2B or civil-law contractor models, it should prepare for the new reality. The key steps are as follows:
 

1. Review all B2B and civil-law contractor arrangements

 
Map current engagements: prepare a list of all B2B and civil-law contracts (including umowa zlecenia and umowa o dzieło) where the contractor performs work in Poland.
Assess whether the relationship reflects genuine self-employment by considering whether the contractor:
 

• performs work for multiple clients,
• bears their own costs and risks, and
• can organise their own working methods and schedule.

 
If the answer is “no” or “only to a limited extent,” the arrangement is likely to be treated as disguised employment under the new rules.
 

2. Identify “employment-like” patterns

 
Audit how contractors operate in practice, not only on paper. Typical warning signs include:
 

• Detailed instructions and internal orders similar to those given to employees.
• Fixed schedules aligned with the client’s internal working rhythm, rather than output- or project-based deadlines.
• Use of client-provided tools or workplace infrastructure, such as laptops, software licences, access to internal systems, or mandatory on-site presence.
• No independent business risk: the contractor primarily performs work for a single client and does not bear meaningful commercial risk.

 
Where several of these factors are present, the arrangement is likely to be considered employment-like by PIP.
 

3. Adjust contracts, structures, and working practices

 
Revise contractual terms to emphasise:
 

• independence of the contractor,
• the result-oriented nature of the engagement (rather than time-based work), and
• the contractor’s business risk and multi-client model, where this genuinely reflects reality.
• Avoid any terminology which is typical for employment relationship.

 
Redesign working practices:
 

• avoid fixed working hours, mandatory attendance, and rigid internal procedures,
• allow flexibility in how and where work is performed, where operationally feasible.

 
Restructure reporting and integration:
 

• limit contractors’ involvement in internal HR processes,
• avoid treating contractors as employees for performance management or disciplinary purposes.

 
Conclusion
 
The new framework places Polish employers in a challenging position. From 8 July 2026, PIP inspectors may issue administrative decisions reclassifying B2B contracts, umowa zlecenia, or umowa o dzieło as employment relationships. Such decisions may be challenged only by appealing to the labour court.
 
If the court finds elements such as subordination, fixed working hours, control over how and when work is performed, or integration into the employer’s organisation, it is likely to uphold the inspector’s decision.
 
Woźniak Legal has the expertise and experience in employment matters to support you at every stage - from contractor classification compliance programmes to drafting and implementing new documentation- helping to minimise risks, including hidden liabilities and regulatory exposure.