Why Auditing Polish B2B Contracts Matters (and What to Do Now)?

From 8 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.

Hallmarks of subordination:
 

• 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.

 
The companies based in Poland should do the audit of all civil law contracts before 8 July 2026.