New Labour Code Enforcement: Disguised B2B Contracts Now Subject to Admin Review
As of 8 July 2026, Poland's labour inspectors gained new enforcement powers to reclassify B2B contracts as hidden employment without court involvement, affecting contractors and foreign workers relying on civil-law arrangements.
Poland did not make B2B contracts illegal in 2026—they never were. What changed on 8 July 2026 is enforcement. Article 22 of the Kodeks pracy (Polish Labour Code) has long prohibited disguising an employment relationship under a civil-law contract. The new rule gives regional labour inspectors (pracownicy PIPu) the power to make that finding by administrative decision, without going to court.
What Constitutes Disguised Employment?
Under Article 22 of the Kodeks pracy, any work performed under an employer's direction, at a place and time the employer sets, is employment — regardless of the contract's name. If an inspector finds that a B2B contract (umowa zlecenia) or contractor arrangement actually meets these criteria, they can now issue an administrative decision converting it to an employment contract retroactively.
The Timeline and Grace Period
The enforcement began on 8 July 2026. There is a voluntary compliance window until 8 July 2027, during which employers can voluntarily regularise questionable arrangements. After that date, penalties apply. The administrative decision is not immediately enforceable for most independent contractors, but the legal reclassification carries serious consequences for tax, social insurance (ZUS), and labour-rights implications.
Impact on Foreigners and Contractors
Foreign nationals working on B2B or civil-law contracts should review their arrangement closely. If you work under fixed hours, at a location set by the client/employer, and under their direct control, your contract may be reclassified as employment. This is actually protective — you gain statutory employee rights (sick pay, holiday, severance) and ZUS coverage — but it affects tax treatment and may change your work-permit requirements if you are not EU. Many non-EU workers have relied on declarations (for Ukrainian, Belarusian, Georgian nationals) or work permits tied to "employment" status; a reclassification could require updating your permit or residence documentation. If you are a contractor serving multiple clients with genuine independence, the new rule should not apply. Consult an employment lawyer (prawnik) if your status is unclear.
Sources
Independent app, not a government. General information, not advice. The official source:
