Electronic occupational medicine certificates

On April 17, 2026, an amendment to the Regulation of the Minister of Health (Journal of Laws 2026, item 456) introduces the possibility of issuing electronic medical certificates, expanding the digitization of HR processes. This is an important change for employers, HR departments, and HR professionals, as it impacts the flow of HR documents within a company. 

Changes for employers from April 17, 2026

What will you learn from this article? 

Amendments to regulations, a step towards HR digitalization 

On April 2, 2026, the Regulation of the Minister of Health of March 20, 2026, amending the Regulation on conducting medical examinations of employees, the scope of preventive healthcare for employees, and medical certificates issued for purposes provided for in the Labour Code, was published in the Journal of Laws. The new regulations enter into force on April 17, 2026. 

This change is part of a broader process of digitizing employee and healthcare documentation. Following the introduction of electronic employee applications, the next step is the digitalization of occupational health records. 

Learn more about the digitization of employee documentation, read the article: Deregulation of HR and payroll regulations 

Electronic medical certificates – what does their introduction mean in practice? 

The most important change is the possibility of issuing medical certificates in electronic form. 

This means that: 

• the document will be saved in the Medical Information System (SIM), 

• the employee will receive access to the decision via the Online Patient Account (IKP), 

• the need to transfer paper documents between the employee and the employer will disappear. 

In accordance with the regulation, a medical certificate prepared in the form of: 

• electronic – recorded and stored in the Medical Information System, 

• paper – the doctor conducting the preventive examination gives it to the examined person and the employer. 

It is worth adding that the medical certificate is issued in paper form in the event of lack of access to the IT system, i.e. SIM, as well as in relation to officers of the Internal Security Agency, the Foreign Intelligence Agency, the Central Anticorruption Bureau, the Military Counterintelligence Service and the Military Intelligence Service, as well as professional soldiers appointed to official positions in the Military Counterintelligence Service and the Military Intelligence Service. 

Paper certificates are still possible – important information for companies 

Despite digitalization, the legislator has retained the option of using paper documents. 

The decision may be issued in paper form: 

• when the IT system (SIM) is unavailable, 

• at the request of the employee. 

According to the provisions of new regulation, “In the case of a medical certificate issued in electronic form, the data and information covered by the medical certificate are transferred to the examined person from the Medical Information System: 

1) to the Online Patient Account (IKP); 

2) at her/his request, in the form of a printout of the certificate signed by the doctor issuing the certificate with the doctor`s own signature.”

What will the circulation of electronic certificates look like? 

Electronic certificates will be: 

• examinations. 

According to the amended provisions: “The basic unit of the occupational health service in which the physician performed the preventive examination shall forward the medical certificate to the employer within the time limit and in the manner specified in the agreement concluded with this basic unit of the occupational health service .” 

Scope of data in the certificates 

Another significant change is the new template for medical certificates. The scope of data that will be included in such reports has been defined. The new regulations clarify the scope of information provided to employers. Employers will only receive data necessary to assess the employee’s fitness for work, including: 

• about the ability or inability to perform work, 

• on suspicion of an occupational disease, 

• about an accident at work or occupational disease, 

1. on recommendations for the employer resulting from the decision to transfer to another position regarding the need to adapt a specific job position in order to reduce occupational risk 

2. about threats to the employee’s health occurring at a specific workplace. 

Health-promoting recommendations – a new element of prevention 

If a physician determines the need for health-promoting measures, they may issue individual medical recommendations addressed directly to the employee. These recommendations will not be forwarded to the employer. 

According to the regulation: “If the physician conducting a preventive examination determines that it is appropriate for the examined person to undertake health-promoting activities, he or she issues individual recommendations that also take into account non-occupational health aspects. Recommendations are prepared in paper or electronic form.” 

This is an important step towards preventive healthcare and supporting employee health. 

Read also: Check-ups, or returning to work after a long sick leave 

New solutions and benefits for employers and HR departments 

The new regulations bring practical improvements. Key benefits include: 

Transition period – 6 months for adaptation 

The digitization of employee medical records is to be implemented gradually. The regulations provide for a six-month transition period. 

During this time, it will be possible to apply the existing rules. 

Employers therefore have time to: 

• updating HR procedures, 

• adjustment of contracts with occupational medicine units, 

• possible transition to an employee e-file to avoid having to print out a medical certificate and sign the paper document with the employer’s or an authorized person’s signature to confirm the compliance of the printout with the electronic document. 

Summary – what should employers do? 

Changes in occupational health examinations are the next stage in the digitalization of HR processes. Electronic certificates will simplify document flow and increase employee data protection. Also read: HR and Payroll – A digital revolution in process management  

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