ZUS Work Seniority Certificates in Employee Personnel Files: Part A or Part B?

Payroll and HR professionals debate whether employment seniority documents provided by workers during ongoing employment should be filed in part A or part B of personnel files.

The Dilemma of Filing Seniority Documents

Employers face the question of which section of personnel files should house documents provided by employees to count additional periods of professional activity toward their work seniority. Although supplementing work seniority during employment has occurred previously, the current scale of the phenomenon is significantly larger.

New regulations effective from January 1, 2026, under Articles 302(1) and 302(2) of the Labor Code, regulate the inclusion of previously uncounted professional activity periods into employment tenure. Budget sector applications began on this date, while private sector applications started in May. Practical application has proven more complicated than theory during the initial weeks.

Business Activity and Contracts Impact Work Seniority

Article 302(1) of the Labor Code regulates other periods counted toward employment tenure, most commonly business activity and contract mandates, alongside a broader range of professional activities described in detail. Paragraph 1 specifies that tenure includes periods where an individual conducted non-agricultural business or cooperated with such a person, provided pension, disability, or accident insurance contributions were paid.

Specified business activities encompass standard non-agricultural ventures as well as those conducted by creators, artists, freelance professionals, single-person LLC partners, general partnership partners, limited partnership partners, professional partnership partners, simple joint-stock company shareholders providing work or services, limited joint-stock partnership general partners, and operators of public or non-public schools or educational forms under the Education Law.

Company Seniority May Also Change

Additionally, Article 302(2) of the Labor Code dictates that employment periods include mandate contracts, service provision agreements, agency agreements, cooperation with contractors, agricultural production cooperative membership, and agricultural circle cooperative membership, provided the individual was subject to pension and disability insurances.

Special regulations govern counting these periods toward seniority with a specific employer, known as company seniority, which affects notice periods and severance pay. Article 302(1) paragraph 8 clarifies that if work within these indicated periods was performed for the given employer, these periods count toward tenure with that employer, excluding specific business suspension periods for personal child care.

Seniority Documentation in Personnel Files

The primary form of documentation is certificates issued by the Social Insurance Institution (ZUS), though obtaining them is not always possible if social contributions were not mandated. In such cases, employees may confirm professional activity through other reliable documents, sparking debates among HR professionals regarding storage locations in personnel files.

Social media HR groups debate whether these documents belong in part A, because they concern pre-employment professional activity, or part B, because they were delivered to the employer during ongoing employment. Employers maintain separate personnel files consisting of five parts, where part A covers pre-employment job application data and medical referrals, while part B covers the establishment of the employment relationship and employment progress.

Since part A stores documents gathered in connection with job applications, documents gathered at later stages must not be placed there. When documents are delivered during the employment relationship due to regulatory changes, the employer must place them in part B of the personnel files.

Legal Basis

Articles 302(1) and 302(2) of the Labor Code of June 26, 1974.

Regulation of the Minister of Family, Work and Social Policy of December 10, 2018, on employee documentation.