ZUS Overhauls Enforcement Rules Amid 3.5 Million Executive Titles and Nearly 10 Billion PLN in Arrears

The Social Insurance Institution is overhauling its debt collection by appointing its President as the sole national enforcement authority to streamline a massive backlog of millions of cases.

ZUS Changes Enforcement Rules

ZUS is preparing a change in the method of recovering overdue contributions and other receivables. The President of the Institution is set to take over the role of the sole enforcement body nationwide, replacing 43 branch directors due to massive disparities in the number of cases handled. In 2025 alone, ZUS issued over 3.4 million executive titles concerning receivables worth nearly 9.7 billion PLN.

Current Branch Model to Be Replaced

Currently, the tasks of the administrative enforcement body regarding monetary receivables belonging to ZUS are performed by the directors of 43 institution branches. Their jurisdiction was defined in a 2016 regulation by the Minister of Finance, meaning individual branches conduct enforcement proceedings in assigned areas. The proposed regulations aim to completely change this model.

Centralized Authority for Flexible Management

Once the new regulations enter into force, the President of ZUS will become the enforcement authority, able to execute receivables across the entire country. This change is intended to allow more flexible management of the institution’s cases and resources, addressing the current system’s uneven distribution of duties among branches.

Scale of Enforcement and Massive Backlogs

The scale of enforcement conducted by ZUS is enormous, with the institution issuing 3,467,713 executive titles in 2025 covering 9,682,256,471 PLN in social insurance contributions, derivative receivables, and unduly collected benefits. Branches in Wrocław, Warsaw II, Gdańsk, Warsaw III, and Poznań I issued the highest number of titles in 2025, creating vastly uneven workloads.

Severe Workload Disparities Among Branches

According to the bill’s justification, the current solution does not ensure an even distribution of work, leaving branch directors with over 15.4 million executive titles to process at the end of 2025. The heaviest burdens were recorded in units such as ZUS Warsaw II with about 950,000 titles, Warsaw I with over 910,000, Warsaw III with nearly 788,000, and Gdańsk with over 1 million titles, compared to much lower figures in Biłgoraj and Piła.

Flexible Case Allocation and Staff Authorization

The new regulations are designed to give the President of ZUS the ability to flexibly divide tasks between institutional units so that enforcement cases do not have to be handled exclusively by the territorially competent branch. The President will also be able to authorize staff members to perform specific enforcement actions on their behalf through individual names, specific positions, or internal organizational regulations.

No New Obligations for Entrepreneurs

The planned change primarily concerns the organization of work within ZUS and does not introduce new types of arrears or new obligations for contribution payers. The enforcement proceedings will simply be led by the President of ZUS operating as the competent authority nationwide instead of specific branch directors.

Greater Control and Uniformity Standards

According to the justification, centralizing the enforcement function aims to improve the uniformity of the institution’s operations and facilitate control over ongoing proceedings. Supervision over proceedings conducted by the President of ZUS will be exercised by the directors of tax administration chambers, and the President will be able to independently control the correct implementation of enforcement measures applied to debtors, excluding banks.

Continuity of Ongoing Proceedings and Implementation Timeline

The change does not mean starting all proceedings from scratch, as transitional provisions dictate that ongoing enforcement cases will be continued by the President of ZUS, who will step into all rights and obligations while previous actions remain valid. The draft provides a 12-month vacatio legis to give ZUS time to prepare organizational changes.

Legal Basis

Draft Act amending the Act on Administrative Enforcement Proceedings in Administration and Certain Other Acts (no. UD405)