The Polish labor market is preparing for major changes. Starting July 8, 2026, new rules will come into force in the country aimed at eradicating the practice of hidden employment. The Labor Inspectorate will have the right to forcibly reclassify civil law agreements into official employment contracts if the actual working conditions indicate the existence of an employment relationship.

Two-stage control model and verification criteria

The new supervision system is based on a two-stage model. If violations are detected during an audit, the inspector issues an order to the employer to rectify them. Ignoring these requirements may lead to an administrative decision on the forced conversion of the contract or a lawsuit.

The main criterion for assessment will not be the name of the document, but the real essence of the cooperation. Inspectors will focus on three key elements:

  • Personal performance of duties by the employee;
  • The presence of management or supervision by the client;
  • A fixed schedule and place of work.

If these signs are present, the contract must be formalized as an employment contract.

Digitalization and automatic detection of schemes

To increase the effectiveness of control, the state is implementing systems for automatic data analysis. Authorities will exchange information with the tax service and the social insurance fund. This will allow for the rapid detection of suspicious schemes, such as the mass replacement of staff positions with B2B contracts or long-term cooperation via invoices with a single client.

Risks for foreign workers

Although the reform is aimed at regulating the labor market and protecting workers' rights, experts warn of possible negative consequences for foreigners. Tomasz Bogdewicz, General Director of Gremi Personal, stated in a comment to RBC-Ukraine that the main risk lies not in the inspections themselves, but in the reaction of employers.

Companies that massively use mandate contracts (umowa zlecenia) or B2B schemes may begin to reduce staff, change schedules, or transfer workers to contractors to reduce costs and legal risks. In particular, this could lead to a refusal to hire foreigners.

The expert emphasizes that automatic legalization of every contract will not occur. Conditions will be assessed individually. For Ukrainians, the reform may provide more guarantees, but at the same time increase the risk of losing their jobs with unscrupulous employers. Those whose right to stay in the country is tied to a specific employer are particularly vulnerable.

What workers should do

In the event of contract termination, workers will have to urgently seek new legal grounds for employment and carefully monitor deadlines for notifying state authorities. Also, Ukrainians with temporary protection status must remember the need to update their data in the PESEL registry. Without this, refugees risk losing their UKR status and access to social rights.