[Poland] Deregulation of HR and payroll regulations

On January 27, 2026, amendments to the Labour Code came into force, directly impacting human resources and payroll in businesses. The rules for paying compensation for unused vacation leave are changing, and employee documentation is moving toward full digitization.

New rules for paying holiday pay – what are they?

From the point of view of processing of human resources and payroll, the key change introduced by the new regulations is the standardization of the deadline for payment of the compensation for unused leave. The amendment, article 171 of the Labour Code, abolishes the obligation to pay the leave equivalent precisely on the date of termination of the employment contract.

What are the new deadlines for paying the equivalent?

General rule. The equivalent is paid on the standard salary payment date (in accordance with Article 85 of the Labour Code). This allows for the benefit to be included in a single payment cycle, without the need to create separate transfers.

Exception. If the standard payment date falls before the termination of employment, the employer has 10 days from the termination of employment to pay the equivalent.

Holidays. If the 10-day period falls on a holiday, the money must be paid on the preceding day.

This change reduces the risk of errors, which often resulted from rushing and lack of complete data on the employee’s last day of work.

Digitization of employee documentation – what is changing?

The new regulations introduce the concept of “paper or electronic form” into the Labour Code, replacing the previous term “in writing” (quote from the Act: the words “in writing” are replaced by the words “in paper or electronic form” ). The aim is to adapt the law to current business realities.

What does this mean in practice?

Importantly, maintaining electronic form no longer requires a qualified electronic signature each time. An email or HR notification will suffice, as long as it allows for the sender’s identification (e.g., through name and surname or work profile). See how e-files are changing the face of employee documentation: Employee e-files

Catalogue of activities – amendment

The amendment covers a number of key HR processes. From January 27, 2026, employers and employees can communicate electronically on the following matters:

Working time. Preparing work schedules, requests for individual schedules, shortened workweeks, work at weekends, and flexible working hours. Check out: Working time settlement – RCP system

Leave and overtime. Requests for unpaid leave and requests to take time off for overtime or personal leave.

Relations with trade unions. Consultations regarding the intention to terminate an employment contract (Article 38 of the Labour Code).

Occupational health and safety and information. Providing information on monitoring, Occupational Health and Safety instructions, and the terms of the workplace’s transition to a new employer.

Are these changes beneficial for companies?

The introduced regulations are a step towards deregulation and digitalization of HR and payroll regulations. For organizations with high staff turnover, the new rules for compensation payments mean an end to the administrative chaos of having to adjust pay to the date of termination of an employee’s contract.

In turn, the digitalisation of many employee applications and the addition of the concept of “paper or electronic form” in the regulations instead of the usual written form removes legal doubts regarding the validity of e-mails and workflow systems, which translates into a more efficient workflow of documents and information within the organization, and indirectly also affects and reduces costs related to, among others, the need to archive paper documentation.

For HR and payroll departments, these changes are certainly in the right direction. However, they require actions to adapt current processes within companies, including the need to update internal regulations and adapt existing HR and payroll systems.

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