Starting July 8, 2026, the National Labor Inspectorate will implement a two-stage procedure requiring inspectors to issue directives to fix employment irregularities before moving to formal contract reclassification or litigation.
New Inspection Procedure
From July 8, 2026, labor inspectors will shift their enforcement strategy regarding civil law contracts and B2B agreements. Inspectors will no longer begin with administrative penalties, but will first issue an order for the employer to rectify irregularities while the inspection is still ongoing.
If a company ignores these directives, authorities may initiate procedures to reclassify the civil law agreement into a standard employment contract. This approach aims to achieve compliance quickly without resorting to formal administrative or judicial proceedings.
Assessment Criteria for Employment
Inspectors will rely on Article 22 of the Labor Code to determine if a contract reflects an actual employment relationship. This assessment considers factors such as working under employer supervision, set hours and locations, and the personal performance of assigned duties.
The Chief Labor Inspector, Marcin Stanecki, emphasized that these directives are designed to encourage voluntary compliance. While employers are not legally obligated to follow the inspector’s recommendation, doing so remains the most efficient way to resolve potential disputes regarding contract status.
Administrative and Legal Consequences
Should a business ignore an inspector’s directive, the case may escalate. Inspectors can request an administrative decision from the district labor inspector to formally reclassify the contract, or they may refer the matter to a labor court.
Both employers and employees will have the right to appeal administrative decisions. Appeals to the labor court generally suspend the execution of an order, unless the decision is granted immediate enforceability. Starting in July 2026, companies will also be able to request binding interpretations from the Inspectorate regarding complex contract arrangements.
Educational Tools for Employers
The National Labor Inspectorate plans to support this transition with educational initiatives. A dedicated checklist is being developed to help employers assess whether their civil law contracts comply with current legal standards.