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Effective from 2026, Poland’s National Labour Inspectorate (PIP) will be given new powers to reclassify civil law contracts—including B2B arrangements and personal service contracts (Pol.: “umowa zlecenia”)—as contracts of employment. While the purpose of the developments is to safeguard workers, the lack of clear criteria for assessing whether a self-employment arrangement is bogus raises concerns, especially among companies that rely on flexible collaboration models, such as those in the IT, gamedev, retail, consulting, or creative industries.
A draft amendment to the Act on the National Labour Inspectorate and other related laws has been placed on the government's legislative agenda and released for public consultation.
According to the proposal, the PIP will be authorized to reclassify civil law contracts as employment contracts if, in the PIP inspector’s opinion, the terms of cooperation meet the criteria of an employment relationship. Importantly, such decisions will be enforceable immediately.
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The risk that the development carries is that it may have retroactive effect, which means that companies could face substantial additional costs if a working relationship in the past is deemed to have qualified as employment. This could impact operating expenses and future revenues.
To streamline the PIP’s operations, a dedicated data exchange channel is to be launched between the PIP, the Social Insurance Institution (ZUS), and the National Revenue Administration.
These changes are expected to come into force in 2026.
Flexible employment models gaining market recognition
As the labour market continues to evolve, flexible collaboration models are becoming increasingly valued. In the past, personal service contracts or B2B arrangements were often associated with abuse and the “outsourcing” of full-time employees to act as sole traders. Today, they represent one of the most widespread forms of cooperation and offer both parties attractive solutions alongside standard employment relationships.
This can be seen from the findings in the third edition of the EY & GIGLIKE survey: GIGbarometer 2025 – The Flexibility Barometer of the Labour Market. One of the key findings is that flexibility-based collaboration models, including B2B arrangements, are not a passing trend—they are a lasting shift in how work is organized.
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