Some time ago, the Prime Minister has suspended  work on the amendment to the Act on the National Labour Inspectorate (Państwowa Inspekcja Pracy) . On social media, he stated that allowing an official to change the form of employment without consulting the employer or the worker, and without a court ruling, is a bad idea. At the same time, he announced that the government would seek better ways to protect employees.

However, a few days ago press reports revealed that work on the reform will continue and is likely to proceed at an accelerated pace, as Poland must account for the National Recovery and Resilience Plan (NRRP) funds by August.

Although the new draft bill has not yet been published, it can be expected that the regulations will be more lenient than those previously announced.

However, although currently the National Labour Inspectorate is not entitled to administratively reclassification of civil law contracts (such as contracts of mandate or B2B arrangements) into employment contracts

the existing risks remain in force!

• Contractors may still challenge the type of contract in place and seek recognition of an employment relationship (and our firm represents clients in such cases).
• Labour inspectors may continue to question the nature of contracts and refer such matters to labour courts.
• The Social Insurance Institution (ZUS) and the tax authorities may also continue to examine the actual nature of cooperation and issue decisions resulting in the obligation to pay additional taxes and social security contributions.

What should be done?

Implementation delay is a good moment to calmly and without time pressure review the contracts of mandate and B2B agreements currently used within the company.

In practice, this makes it possible to:

• confirm that the adopted model of cooperation is safe and consistent with business realities,
• identify areas of potential risk and take appropriate remedial measures before any inspections,
• prepare the company for a swift response when the draft return in a revised form.

As part of our labour law and employment tax practices, we offer reviews and risk assessments of civil law contracts and develop recommendations tailored to the specific nature of the company’s business and the industry in which it operates.

Find more articles in PRO HR January 2026.