HR and payroll legislative updates: Q2/2026

1. Changes in the determination of employment periods included in the calculation of length of service.

On 1 January 2026, the Act of 26 September 2025 amending the Act – Labour Code (Journal of Laws of 2025, item 1423) entered into force. This Act changes how the so-called general length of service and company length of service (Article 302 [1] of the Labour Code) will be determined. Under the new law, the employment period on which employee entitlements depend will also include, among other things, periods of non-agricultural business activity conducted by a natural person, as well as periods when they act as a cooperating person with an individual conducting such activity, provided that contributions to pension, disability, or accident insurance were paid. 

Moreover, the length of service will also encompass, inter alia, periods when the natural person (and a cooperating person) performed work under a contract of mandate or other service performance contract governed by the provisions applicable to contracts of mandate or agency agreements, periods when the natural person was a member of agricultural production cooperative or farmer units’ cooperative, where such a person was covered by pension and disability insurance, as well as periods of work performance on a basis other than an employment relationship conducted abroad. The periods stipulated in the Act must be confirmed by a certificate obtained from ZUS. 

The Act entered into force on 1 January 2026 for entities in the public finance sector, while the remaining employers will be subject to the amended law starting on the first day of the month following the lapse of 6 months from the day when the Act is published, i.e. on 1 May 2026.

2. e-Delivery

As of 1 January 2026, e-Delivery has become the primary tool for exchanging correspondence between public authorities, citizens, and businesses. Public offices are required to use e-Delivery for all outgoing correspondence. In most cases, ePUAP is no longer an effective communication channel. 

An application for a free e-Delivery mailbox can be submitted online, with identity verification via Trusted Profile, mObywatel, or online banking. Individuals without an e-Delivery mailbox will receive correspondence in paper form through a hybrid service (PUH). 

3. Proposed minimum wage rates for 2027

Discussions on the level of the minimum wage for 2027 have begun. The government, represented by the Ministry of Family, Labour and Social Policy, proposes a rate of PLN 4,927 gross. Meanwhile, the social partners, including trade unions, are calling for a significantly higher amount — around PLN 5,200 gross.

Should you wish to discuss the above-mentioned changes, please contact the Payroll & HR Department of Forvis Mazars.