Just over a month was enough for the National Labor Inspectorate (PIP) to begin using its new powers in practice. The PIP received hundreds of complaints regarding the improper use of civil law contracts, inspectors launched over 100 inspections, and has already issued 121 written orders confirming employment under an employment contract. At the same time, businesses are increasingly amending disputed contracts and requesting individual interpretations from the PIP.
On July 8, 2026, they entered into force regulations significantly expanding the National Labor Inspectorate's ability to inspect civil law contracts, including B2B cooperation. The definition of an employment relationship itself has not changed. The actual working conditions and the conditions arising from Article 22 § 1 remain decisive. Labor CodeHowever, the tools that the National Labor Inspectorate (PIP) can use to respond when a contract of mandate, a service contract, or a B2B contract actually resembles employee employment have changed.
The first data published by the National Labour Inspectorate show that the new regulations are not just a solution functioning on paper.
The number of complaints has increased significantly
Według data published by PIP on August 18, 2026, Only from July 8 to August 13, the Inspectorate received 690 complaints and applications regarding the incorrect choice of the civil law form of employmentSince the beginning of 2026, there have already been 1794 such cases. For comparison, in the same period in 2025, there were 619.
This represents a nearly threefold increase in the number of reports year-on-year. The vast majority concern the improper application of a mandate contract or a service contract, to which the provisions on mandate apply. However, it is impossible to identify a single industry that the National Labor Inspectorate (PIP) focuses its attention. Complaints concern both small businesses and large entities, the private and public sectors, as well as services, trade, and manufacturing. The PIP also cites healthcare providers, restaurant chains, the security industry, and individuals performing work via digital platforms.
A complaint alone, of course, does not automatically reclassify the contract. Some reports also concern employment relationships that ended before the new regulations came into force or contain formal deficiencies. The new procedure can primarily be applied to relationships that existed at the time the new regulations came into force. In cases of previously terminated employment relationships, determining the existence of an employment relationship generally remains the domain of the labor court.
Over 100 inspections and 121 challenged employment cases
The large number of complaints quickly led to inspections. On July 8, inspectors initiated over 100 inspections regarding the replacement of employment contracts with civil law contractsAccording to data presented on August 18, 35 of these inspections have already been completed.
Even more significant is the number of legal remedies issued. Inspectors issued 121 written orders confirming employment under an employment contract in situations where they deemed the use of the civil law form to be inappropriate. At the time of publication, none of these cases had yet progressed to the next stage, i.e., administrative proceedings before the district labor inspector.
The scale of activity is particularly interesting when compared to the PIP's previous capabilities. Throughout 2025, the Inspectorate inspected 48,677 civil law contracts and questioned 2119 of them for being concluded under conditions indicating the existence of an employment relationship. However, only 18 lawsuits involving 35 individuals were filed with the courts. The reform, therefore, did not change the basic criteria for contract evaluation, but it significantly shortened the path from identifying irregularities to taking action to correct them.
First the order, then the decision
The new PIP operating model has been constructed in two stages. The inspector determines that the individual is performing work under conditions appropriate for an employment relationship. does not yet mean the automatic issuance of a decision transforming the contract.
First, the inspector hears the parties and may issue an order to bring the employment into compliance with the law. The intention of this solution is to allow the employer and the employee to voluntarily regulate the situation during the inspection phase.
Only if the order is not carried out can the case be referred to the district labor inspector. After analyzing the material collected during the inspection, he may issue a decision confirming the existence of an employment relationship or file a lawsuit to determine the existence or content of an employment relationshipThe latter option is particularly important when the employment relationship is to be established with an effect relating to an earlier period.
Decisions of the District Labor Inspector may be appealed to a court through the authority within one month of receipt of the decision. Generally, a decision does not become enforceable until the appeal period has expired or the court proceedings have been legally concluded. Exceptions may apply, for example, to individuals who are subject to special protection against termination of their employment.
Companies change contracts even before the order is issued
The first weeks of the new regulations' implementation also demonstrate another effect of the reform. Some entrepreneurs aren't waiting for formal challenges to their employment model.
PIP reported that From July 8 to August 6, inspectors obtained information about 201 cases of voluntary change of an existing civil law contract to an employment contractThe changes occurred even before the inspector completed his detailed findings and initiated formal legal action.
These data demonstrate that the impact of the reform is not limited to the number of decisions ultimately issued by the National Labor Inspectorate. The control itself and the potential for implementing new instruments may encourage businesses to review their cooperation model in advance and voluntarily address any identified irregularities.
PIP examines the actual method of cooperation, not just the content of the contract
From the entrepreneurs' point of view, the key question remains, which may actually lead to questioning the order or B2B.
The reform did not introduce a new definition of the employment relationship. The National Labor Inspectorate (PIP) emphasizes that the manner in which duties are actually performed remains paramount. Risk increases particularly when the contractor works at a designated time and place, is subject to the ongoing management of the other party, receives instructions regarding how the work is performed, is organizationally integrated into the company structure, cannot freely use substitutes or subcontractors, and does not bear any real economic risk.
Merely concluding an extensive B2B contract will not guarantee the security of cooperation. PIP clearly states that contractual provisions or the contractor's declaration that he consciously chose B2B and does not want an employment contract are not enough, if the actual manner of performing duties corresponds to employee employment.
Less obvious elements of the collaboration can also be significant. The National Labor Inspectorate (PIP) cites, as an example, days off granted to contractors on terms similar to those of statutory vacation. If, for example, a co-worker has exactly 20 or 26 days off and must obtain their supervisor's consent to use them each time, this may be one argument in favor of an employee-like relationship. However, this is not a stand-alone premise. Each case should be assessed based on the overall terms of the collaboration.
Individual interpretations show that entrepreneurs are also taking advantage of the new regulations.
The reform also provided entrepreneurs with a new tool to mitigate risk. From July 8th, you can apply to the Chief Labor Inspector for individual interpretation regarding whether a specific form of cooperation constitutes an employment relationship within the meaning of Article 22 § 1 Labor CodeThe interpretation may apply to both the existing cooperation model and a solution planned for the future.
However, initial data shows that this is not an instrument that automatically confirms the correctness of the B2B application. Currently, there are The first 9 individual interpretations In four cases, the Chief Labor Inspector agreed with the employer that the relationship described was of a civil law nature. In the remaining five cases, he found that, despite the applicant's contrary position, the presented circumstances indicated an employment relationship.
The application costs 40 PLN., and the interpretation should be issued no later than 30 days from receipt of the complete application. However, the protection resulting from the interpretation is closely related to the factual circumstances presented by the entrepreneur. If the actual working conditions differ from those described in the application, a positive interpretation will not secure a different model of cooperation.
Importantly, the interpretation is binding on the National Labor Inspectorate (PIP) authorities, and the entrepreneur who complies with it benefits from the protection provided by law. The issued interpretation is simultaneously forwarded to the Social Insurance Institution (ZUS) and the National Revenue Administration.
PIP inspections may look different than before
The changes affect not only the authority to challenge contracts. The reform also expanded the possibilities of conducting inspections and selecting entities for review.
PIP may use the exchange of data with ZUS and KAS, which are intended to help identify enterprises with an increased risk of violationsThe Inspectorate has also gained greater capabilities to conduct its activities remotely. Among other things, the Inspector can request electronic transmission of documents, reports, and calculations, conduct online transmissions, and conduct some evidentiary activities via electronic means of communication.
The scope of entities that may be subject to the Inspectorate's scrutiny has also changed. The National Labor Inspectorate (PIP) indicates that an inspection of the proper application of civil law contracts may also cover an entrepreneur who is not formally an employer because it does not employ anyone under an employment contract.
B2B has not been banned, but it is worth checking what it looks like outside the contract
The first few weeks of the new regulations' implementation do not mean the end of mandate contracts or B2B cooperation. Such forms remain permissible if they reflect the actual nature of the relationship between the parties.
However, the risk associated with incorrectly classifying cooperation has changed. The National Labor Inspectorate (PIP) has received new tools to more quickly respond to cases where a formal civil law contract is performed under the terms of an employment relationship. Initial data indicates that the Inspectorate intends to actively utilize these new capabilities.
For entrepreneurs, the best time to verify is not just the beginning of the inspection. It's worth checking not only content of concluded contracts, but above all a real way of organizing cooperation with people employed on a contract or B2B basis, including the method of issuing instructions, determining the time and place of performing duties, the possibility of using substitution, liability rules, accounting for absences, and the scope of independence and economic risk on the contractor's part. These elements may be of greatest importance when the correctness of the adopted employment model is verified by the National Labor Inspectorate.
