Determining the date when the obligation to establish PPK begins
All companies will be obligated to create and administer the PPK, including companies that employ workers on contracts of employment and those that use civil law agreements:
- starting from 1 July 2019, the obligation to establish the PPK will apply to entities employing at least 250 persons as of 31 December 2018;
- starting from 1 January 2020, the obligation to establish the PPK will apply to entities employing at least 50 persons as of 30 July 2019;
- starting from 1 July 2020, the obligation to establish the PPK will apply to entities employing at least 20 persons as of 31 December 2019;
- starting from 1 January 2021, the obligation to establish the PPK will apply to other entities, including publicly financed ones.
When determining the number of persons employed, you should take into account not just employees within the meaning of the Labor Code, but also persons employed on the basis of civil law agreements (contracts of mandate, contracts for services, agency contracts), outworkers, members of farmer’s cooperatives or farmer association cooperatives, as well as members of supervisory boards who are remunerated on account of performing this function. In order for the abovementioned individuals to be counted among the employed persons for PPK purposes, they must be subject to compulsory pension and disability insurance in Poland