Poland's Labour Inspectorate Targets Sham Contracts, Chief Says No Attack on B2B

Poland’s New Crackdown on Disguised Employment

Poland’s labour inspectorate (PIP) has begun enforcing new powers designed to stamp out “junk contracts” — civil-law agreements that in reality function as full employment. In the first three days after the reform took effect on 8 July, the PIP received 70 complaints, barely a week later the chief inspector Janusz Krasoń confirmed the vast majority had already triggered inspections.

In an interview with Business Insider Poland, Krasoń stressed that the state will not treat any employer differently — public hospitals, state-owned companies and private firms will all face the same scrutiny. He also moved to assuage fears that the drive targets legitimate B2B arrangements, insisting that “we will eliminate junk contracts, but this is not an attack on B2B.”

Until year-end, inspections will be launched solely on the back of worker complaints. From 1 January 2027 a new inter-agency data-exchange system with the Social Insurance Institution (ZUS) and the National Revenue Administration (KAS) will start feeding risk-based analysis into the process, allowing the PIP to proactively select employers for audit. The infrastructure has already been tested by exchanging 17,000 randomly selected records, a milestone required by the EU’s KPO plan.

Workers who believe they are falsely classified can file a complaint and request anonymity. Inspectors are obliged to protect the whistleblower’s identity and, once on site, will examine not only the specific contract flagged but also other agreements in the firm. Krasoń acknowledged that sectors notorious for dodgy contracts — couriers, security guards, cleaners — are under the microscope, but promised each case will be judged on its factual working conditions, not just paperwork.

What the PIP's New Powers Mean for Polish Employers and Workers

A Complaint-Driven Start, Then Algorithmic Targeting

For the remainder of 2026 the PIP will rely entirely on complaints. That is a deliberate choice, according to Krasoń, while expert teams build the algorithms and guidelines for the future data-driven system. The tie-up with ZUS and KAS—tested successfully in July—will eventually let the authorities cross-reference tax, social-security and employment records to spot patterns of bogus self-employment. The first real data flows are pencilled in for the start of 2027, meaning the second half of next year could bring a wave of inspections that are not triggered by any individual tip-off.

Defining the Line: Genuine B2B vs. Sham Employment

Krasoń repeatedly drew a bright line: the reform is about how work is actually done, not the label on the contract. A programmer who owns their own know-how, sets their hours and works from a sailing boat has nothing to worry about. But if a contractor turns up every day at 8 a.m., sits in a designated desk, takes instructions from a manager and is assessed on task completion, the PIP sees a hidden employment relationship. The test under Article 22 of the Labour Code will be whether the characteristics of employment outweigh the trappings of self-employment. Healthcare professionals are covered by a separate legal basis — Article 5 of the Medical Activity Act — that expressly permits individual practice through sole proprietorship, so the inspectorate will approach those cases with particular care.

Sectors Most Exposed: Couriers, Security, Cleaning, and Healthcare

While Krasoń avoided naming specific companies, he acknowledged that ZUS data points to heavy misuse of civil-law contracts in guarding, cleaning, driving and courier work — often paying minimum rates while enforcing rigid schedules. The PIP expects many firms in these segments to self-correct simply because the threat of inspection now exists, much as late-payment penalties in the past dramatically improved wage punctuality without mass enforcement.

The Public Sector Won't Be Shielded

Krasoń made clear that state-owned enterprises, municipal services and hospitals will receive no special forbearance. Inspections already planned for 2026 cover, among others, healthcare entities for health and safety. If during those visits labour inspectors spot contracting patterns that resemble employment, they will widen the probe. Public-sector employers that have leaned on civil-law contracts to bypass hiring freezes or budget caps face the same risk of a 60,000 złoty fine per infringement as any private business.

Fines of Up to 60,000 PLN and Voluntary Compliance

Where an inspector decides a contract should be employment, the first step is an order to convert it. Krasoń expects most companies to comply willingly, because that allows them to negotiate the terms of the employment relationship themselves. Only if they refuse does the PIP issue a formal decision, which carries a fine of up to 60,000 PLN. The chief is betting that the threat alone will spur a wave of voluntary corrections, the most cost-effective path for both businesses and the enforcement budget.

How Businesses Can Prepare for the Sham Contract Inspections

For Polish employers, the window between now and the end of 2026 offers a chance to get ahead of the new regime. Here is what to do right now:

• Audit all civil-law contracts. Examine whether the day-to-day working reality matches the contract's name. Do people work fixed hours, at a designated site, under direct supervision? If so, the agreement may look like a sham to an inspector.
• Take voluntary action before a complaint arrives. The PIP chief expects many firms to convert problematic contracts proactively. Doing so now not only avoids a potential 60,000 PLN fine but also lets the company shape the new terms — something that becomes much harder once an inspector issues an order.
• Protect the distinction for genuine B2B relationships. Ensure self-employed contractors retain real autonomy: no rostered shifts, no mandatory attendance, no line-manager instructions on how to do the work. Document that autonomy clearly.
• Assume an inspection may be broader than the complaint. If one worker files a tip-off, the inspector can review every civil-law agreement at the premises. Model that scenario in your internal readiness checks.
• Safeguard whistleblower anonymity. Remind managers that workers are entitled to request confidentiality and that inspectors are bound by law to protect it. Discussing or pressuring suspected complainants will only compound the risk.