Labor Inspectorate Reform in Poland: Will B2B Contracts Be Converted into Employment Contracts?

National Labour Inspectorate Reform Gains Momentum

The Polish Ministry of Family, Labour and Social Policy has finalized a draft law reforming the National Labour Inspectorate (PIP). The proposal, now included in the government’s legislative agenda, is set to significantly strengthen the Inspectorate’s authority.

But what exactly will change?

Key Changes Proposed in the PIP Reform

Under the draft legislation, the Labour Inspectorate will gain broader enforcement powers, including:

• Reclassification of contracts – PIP inspectors will have the authority to issue binding decisions recognizing an employment relationship in place of a disputed civil-law contract (including B2B), without referring the case to court.

• Immediate legal effect – such decisions will take immediate effect under labor law, while tax (PIT) and social security (ZUS) consequences will be postponed until the appeal deadline or, in case of appeal, until the case reaches the labor court.

• Stronger data exchange – improved information-sharing between PIP, ZUS and the National Revenue Administration (KAS) to support more effective inspections.

• Remote inspections – introduction of electronic documentation and the ability for inspectors to conduct online audits.

• Risk-based control plans – annual and multi-year inspection strategies prepared by the Chief Labour Inspector, based on risk analysis.

• Higher penalties – at least a twofold increase in fines for labor law infringements, intended as a deterrent mechanism.

Why Does This Matter for Employers?

These reforms are part of the milestones within Poland’s National Recovery Plan (KPO) and are designed to modernize PIP while providing stronger protections for employees.

For employers, however, the changes mean:

• The need to review existing employment structures – especially if both employment contracts and B2B agreements are used.

• Increased compliance risks – as PIP gains the authority to redefine B2B contracts as employment relationships.

• The importance of being prepared for potential remote inspections and enhanced inter-agency oversight.

Timeline for the Reform

The draft law is scheduled to be adopted by the Council of Ministers in Q4 2025. Businesses should begin preparing now to mitigate compliance risks and ensure their HR structures are aligned with the upcoming regulations.

Need Expert Guidance?

If you have questions about the new powers of the National Labour Inspectorate or want to assess whether your company’s current employment model may trigger compliance risks, contact our People Tax Advisory team for professional support.