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At the start of 2026, reform of the National Labour Inspectorate stirred emotions among entrepreneurs, employees and trade unions. The planned changes would give inspectors far-reaching powers, including administratively converting B2B and mandate contracts into employment contracts, with retroactive effect and immediate enforceability.
One thing is now clear: the Prime Minister has suspended the proposal in its current form. What does this mean for businesses, and can entrepreneurs rest easy?
What did the planned PIP reform involve?
The Ministry of Family, Labour and Social Policy’s proposal envisaged a fundamental change in inspection philosophy. PIP inspectors would gain the right to:
issue administrative decisions converting civil-law contracts into employment,
act retroactively,
make decisions immediately enforceable without waiting for a court ruling.
In practice, one inspection could automatically change a company’s employment model, creating obligations to pay outstanding ZUS contributions, taxes and potential employee claims.
Why was the reform suspended?
As Minister Maciej Berek confirmed to Puls Biznesu, the Council of Ministers has not approved further processing of this version. Prime Minister Donald Tusk instructed the labour ministry to prepare a new reform model without administrative powers for PIP to convert contracts.
Business organisations’ criticism was crucial. The Federation of Polish Entrepreneurs warned the proposal:
violates the constitutional freedom of economic activity,
breaches proportionality and legal certainty,
may cause chaos comparable to the Polish Deal.
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What does this mean for entrepreneurs right now?
For many companies, suspending the reform is a clear relief. However, it does not mean scrutiny of contracts has disappeared.
In practice:
there is currently no legal basis for PIP to administratively “turn” B2B or mandate contracts into employment,
PIP inspections continue under the existing framework,
labour courts still resolve disputes about the existence of employment relationships.
Importantly, the National Labour Inspectorate states that during the transition it is reducing inspection numbers, prioritising prevention and education.
The reform will return in a different form
Suspending work does not mean abandoning the proposal permanently. PIP reform remains a National Recovery Plan milestone, so Poland is still obliged to implement it. Government announcements indicate that the new concept will move away from the most controversial solutions and focus on other mechanisms strengthening labour market oversight. Closer PIP cooperation with ZUS will be crucial, particularly for risk analysis and selecting inspections where abuse is genuinely highly likely. Greater emphasis will also go to educating both employers and employees, rather than sanctions alone. Another important element will be a more precise definition of employment, reducing interpretative differences rather than introducing automatic administrative conversion decisions. Honest entrepreneurs may face less risk of random inspection, but actual, rather than merely formal, compliance of employment models with the law will matter more.
B2B and mandate contracts remain under scrutiny
The reform not taking effect does not mean anything goes in employment. PIP already examines work performed without any contract and relationships where B2B or mandate contracts effectively meet employment characteristics. Cooperation with ZUS is also developing, improving identification of higher-risk areas and targeting inspections where violations are most likely. Entrepreneurs using civil-law contracts should therefore pay particular attention not only to their wording but also to how cooperation with counterparties actually works.
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Summary
What should entrepreneurs do in 2026?
Instead of awaiting the next reform proposal, it is worth already:
examining B2B and mandate contracts for employment characteristics,
ensuring contractors’ actual independence,
organising documentation and cooperation arrangements,
preparing for inspections based on risk analysis.
PIP reform may be temporarily frozen, but the direction is clear: greater transparency, less fictitious self-employment and more employer responsibility.
If you want to check whether your employment model is secure from tax and employment perspectives, now is a good time, before the legislator returns to the subject with renewed energy.
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