A year of revolution in HR. What changes for employers in 2026?

The year 2026 brings a series of significant amendments to labour law for employers in Poland. These changes could significantly impact the daily functioning of HR, personnel, and payroll departments. It’s time to review HR systems, work regulations, and employment strategies. This is not only a legal requirement but also an opportunity for more modern and transparent HR and payroll management.

The new reality of seniority – what will change?

Let’s imagine Mr. Darek, who ran his own business for 10 years and then worked abroad for four years on contracts before finally taking up full-time employment with your company. Until now, from an employment law perspective, he was considered a “young” employee with only a few months of experience and lacking many rights. This will change from January 1, 2026.

The amendment to the Labour Code is a revolution in calculating length of service. It comes into effect on January 1, 2026.

• What’s changing? The list of periods included in seniority, which determines leave entitlement and seniority benefits, has been significantly expanded.
• What does an employer need to include? Periods of conducting business activity (B2B), performance of contracts of mandate and service contracts, and even documented paid employment abroad (even part-time).
• A challenge for HR. Employees have 24 months to document these periods (e.g., with a certificate from the Social Insurance Institution). For employers, this means adapting their seniority calculation processes and potentially higher employment costs for some employees, which must be reflected in budgets for 2026. The short vacatio legis means there isn’t much time for this task.

We also wrote about changes in the rules for calculating length of service here.

New way of filing ZUS applications, i.e. simplifying bureaucracy

Employers, do you remember those hundreds of folders with paper copies of ZUS (Social Insurance Institution) reports that had to be stored, even though they were sent electronically? It was double the work and a significant logistical burden, especially for large companies. However, that’s now a thing of the past.

The amendment to the Act on the Social Insurance System, adopted at the end of 2025, completely abolishes the obligation to archive paper copies of ZUS notifications for 5 years if they were submitted electronically (repeal of Article 36, Section 8 of the Act on the Social Insurance System).

• A benefit for employers. This real simplification means lower printing and storage costs, as well as a reduced risk of documentation errors. The entire document will be available digitally in the ZUS system.
• Important. However, the employer must ensure appropriate data security and backup procedures in its system.

Transparency of remuneration at the recruitment stage

Pay transparency is arguably one of the most emotive topics for every employer. Regulations on pay transparency during the recruitment process come in force on December 24, 2025, and regulations on pay gap reporting, stemming from an EU directive, are expected to be in place by June 2026.

When planning employment, the employer must inform the candidate in advance, in the job advertisement, before the job interview or before entering into an employment relationship, about:

• proposed remuneration,
• its starting salary or salary range,
• criteria that influence the final salary amount.

The employer must also provide:

• Neutrality in job postings. This means that all recruitment communications, including job titles, must be gender neutral. It’s important to emphasize that the entire recruitment process must be conducted in a non-discriminatory manner, which is a fundamental requirement for ensuring equal opportunities for all candidates.
• Prohibition on asking about previous salaries. According to the amended regulations (amendment to Article 221 §1 item 6 of the Labour Code), employers are obligated to refrain from collecting information regarding a candidate’s salary, both in their current and previous employment relationships. This information has been permanently excluded from the list of data that employers are authorized to inquire about in connection with a candidate’s previous employment history.

We wrote more about pay transparency at the recruitment stage here.

Increase in the minimum wage and flexibility of holiday pay

The package of changes is complemented by two cost and procedural modifications that directly affect companies’ budgets and financial liquidity.

1.     Minimum wage increase in 2026

As of January 1, 2026, the minimum remuneration for work will increase to PLN 4,806 gross per month, and the minimum hourly rate to PLN 31.40 gross. This seemingly simple change will entail:

• The need to verify and increase the salaries of some of the staff.
• Increased costs related to social security contributions, sickness benefits, severance pay and allowances that are dependent on the minimum wage.

You can read more about the minimum wage increase here: Minimum wage increase in 2026. What does it mean for employers and the labour market?

2.     Compensation for leave with greater freedom

Previously, compensation for unused leave had to be paid on the day of contract termination. The new regulations introduce greater flexibility:

• New Rule. The employer may pay the equivalent together with the final salary, i.e., on the standard salary payment date for a given month (e.g., by the 10th day of the following month).
• Benefit: No more rushed calculations on the day an employee leaves, and less risk of error.

Read also: Working hours in 2026 – what should an entrepreneur know?

The biggest risk, i.e. the new powers of the National Labour Inspectorate

While the simplifications in the Social Insurance Institution (ZUS) are encouraging, labour law experts point to one change that could be costly and risky for businesses: the planned expansion of the powers of the National Labour Inspectorate (PIP).

The bill assumes that the National Labour Inspectorate (PIP) will be able to reclassify civil law contracts into employment contracts. PIP decisions are to be immediately enforceable, which radically increases risk and reduces legal predictability for entrepreneurs. This means an urgent need to verify all B2B contracts and mandates for their actual “civil law” validity.

In summary, around 2026 will be a time of intense work for every HR department. On the one hand, regulations are becoming fairer and more transparent, but on the other, they bring with them significant new obligations and risks, especially in the area of non-full-time employment contracts.

We wrote more about the revolution in PIP entitlements here: Revolution in employment, or new PIP entitlements in 2026. Want to know how to adapt your work regulations and internal HR procedures to these changes?