Poland’s B2B reclassification reform: what changed and what to do before July 2027

If your company works with contractors in Poland under a B2B or civil-law agreement, the rules around that arrangement changed on 8 July 2026. The Polish Labour Inspectorate (PIP) can now decide on its own that a contract is really employment without a court hearing first. And the window to fix this without a fine closes on 8 July 2027.

This is not a hypothetical risk but a live enforcement power that PIP is actively using. Here is what changed, what the transition period actually protects you from, and what to check before the deadline.

What changed on 8 July 2026

The amendment to the Act on the National Labour Inspectorate was signed by the President on 2 April 2026, published in the Journal of Laws on 7 April 2026, and took effect on 8 July 2026. Before this, if PIP suspected that a B2B or civil-law contract was actually employment in disguise, the matter had to go through a labour court. Courts are slow, and the burden of proof made cases hard to bring at scale.

Under the new law, PIP can issue an administrative decision reclassifying the contract directly based on a presumption of employment. If the working conditions look like employment, meaning fixed hours, direction from a manager, work at the company’s premises, and no real business risk carried by the contractor, the inspector can treat the relationship as employment regardless of what the paperwork says.

One procedural safeguard exists: before issuing a reclassification decision, the inspector must first order the company to remedy the situation voluntarily by offering the worker an employment contract. If the company complies, PIP cannot issue a reclassification decision for that case.

What PIP looks at

The reform does not change the legal definition of employment in Poland, but it changes how quickly that definition can be enforced. The factors that determine whether a relationship is really employment are the same ones Polish courts have used for years:

• Fixed working hours set by the company rather than the contractor
• Direct supervision from a manager with instructions on how and when work is done
• Work performed at the company’s premises using the company’s equipment
• No independent business risk carried by the contractor, meaning they invoice one client, cannot subcontract, and have no real chance of profit or loss from how they run the engagement

A contractor who sets their own schedule, works from wherever they choose, serves multiple clients, and carries genuine commercial risk is unlikely to be reclassified. A former employee who now invoices the same company for the same desk and the same manager is exactly the type of profile this reform targets.

What the 12-month adjustment period covers, and what it does not

Companies that voluntarily convert a B2B or civil-law contract into an employment contract before 8 July 2027 will not be fined by PIP for the past misclassification. That is the extent of the amnesty. It is important to be precise about what it does not cover, because this is where companies get caught off guard.

• It does not cancel back social security contributions (ZUS) owed for prior periods, which can be claimed for up to five years
• It does not cancel back income tax liabilities
• It does not remove a worker’s right to claim unpaid leave, overtime, or other entitlements that would have applied had they been employed
• It only protects against fines issued by PIP specifically, which can otherwise reach PLN 90,000 per case

In other words, converting the contract stops the clock on PIP fines. It does not erase what has already accrued. The longer a misclassified relationship continues, the larger that backdated exposure gets, so waiting out the amnesty period is rarely the cheaper option.

The preventive ruling option

If you genuinely believe a contractor relationship is structured correctly and want certainty rather than an audit, you can apply to the Chief Labour Inspector for a written ruling on whether a specific arrangement qualifies as employment. The application costs PLN 40, and a ruling should be issued within 30 days. It is binding on PIP and is shared with both ZUS and the tax authorities.

The ruling only protects you if day-to-day practice matches what was described in the application. If the contractor’s actual working conditions later change from what you submitted, the ruling stops offering any protection.

What to do before 8 July 2027

• Audit every B2B and civil-law contract in Poland against the four factors above, not just the wording of the contract itself
• For arrangements that clearly function as employment, convert them now rather than waiting closer to the deadline because backdated ZUS and tax exposure grows every month
• For arrangements you believe are genuinely self-employed, consider requesting a preventive ruling to lock in that position
• Where you want to convert a contractor without opening a Polish entity, an EOR can issue a compliant employment contract and take on the payroll, ZUS registration, and ongoing compliance

How Go-EOR handles a conversion

Go-EOR operates its own legal entity in Poland, so converting a contractor into an employee does not require you to register a company first. We draft the Polish employment contract, register the employee with ZUS, and run payroll while you continue directing the day-to-day work exactly as before. For companies managing this transition ahead of the July 2027 deadline, the process typically takes a matter of days once the employment details are confirmed.

Does the amnesty cancel back taxes and ZUS contributions?

No. The amnesty, which runs until 8 July 2027, only protects against fines issued directly by PIP. Back social security contributions and income tax can still be claimed for up to five years, and a worker can still bring claims for unpaid leave or overtime.

What is the maximum PIP fine if I do not convert in time?

Fines under the reformed law can reach PLN 90,000 per case, in addition to the tax and ZUS exposure that sits outside the amnesty.

Can I get certainty on a specific contractor before PIP inspects us?

Yes. You can apply to the Chief Labour Inspector for a preventive ruling on a specific arrangement. It costs PLN 40, is generally issued within 30 days, and is binding on PIP as long as actual practice matches what was submitted.

Does this reform apply outside Poland?

The administrative reclassification power is specific to Poland. Lithuania, Latvia, and Estonia enforce worker misclassification through their own labour inspectorates and courts, and the underlying risk, treating an employee-like relationship as a contractor arrangement, applies across all four markets.

Working with contractors in Poland who look more like employees? Get in touch with Go-EOR and we will walk through what a compliant conversion looks like for your specific setup.