HR and payroll legislative updates: Q3/2026

In the third quarter of 2026, the topics covered include the expanded powers of the State Labour Inspection to determine the existence of an employment relationship, new workplace temperature limits, and increased penalties for breaches of employee rights. These regulations may have a direct impact on employers’ obligations and the organisation of work.

Regulations concerning the working environment and corporate governance also remain a key area of change. The adopted “Women on Boards” provisions are intended to improve gender balance on the governing bodies of the largest public companies, while the new anti-bullying regulations clarify employers’ obligations relating to prevention, reporting violations, conducting investigations, supporting individuals affected by undesirable behaviour, and raising awareness.

The newsletter also covers the planned PIT and CIT reform from 2027, including changes to PIT thresholds and rates, an increase in the CIT rate for companies with annual revenue exceeding PLN 200 million, an increase in the solidarity levy, and the reinstatement of the revenue threshold for eligibility to use the lump-sum tax on recorded revenue. Given the scale of these changes, we encourage organisations to review their current practices, internal procedures, and compliance arrangements in light of the new requirements.

The most important updates in payroll and HR:

 1. State Labour Inspection

On 8 July 2026, an amendment to the Act on the State Labour Inspection (Journal of Laws of 2026, item 473) entered into force, expanding the powers of labour inspectors to combat cases of sham civil-law employment. Pursuant to Article 11(1)(7a) of the Act on the State Labour Inspection, a labour inspector may issue an administrative decision confirming the existence of an employment relationship where the parties have entered into a civil-law contract but the actual conditions under which the work is performed correspond to the characteristics of an employment relationship set out in Article 22 § 1 of the Labour Code. Such a decision may be issued if the inspected entity has previously failed to comply with an instruction to remedy the infringement consisting in the failure to conclude an employment contract where the relationship between the parties is predominantly characterised by the features of employment.

2. Working during hot weather – regulatory changes

On 10 July 2026, the Journal of Laws (item 927) published a Regulation of the Minister of Family, Labour and Social Policy amending the general occupational health and safety regulations. The new § 30a introduces maximum permissible workplace temperatures and additional obligations for employers during hot weather.

From 11 January 2027, the temperature at the workplace may not exceed:

• 35°C in work premises,
• 32°C for outdoor work requiring considerable physical effort.

Once these limits are exceeded, work may not be performed. Employers will therefore be required to take appropriate organisational or technical measures to ensure safe working conditions.

3. Higher penalties imposed on employers for infringements of employee rights

Under the Act of 11 March 2026 amending the Act on the State Labour Inspection and certain other acts (Journal of Laws, item 473), employers’ liability for offences involving infringements of employee rights has been increased. The amendments include Article 282 of the Labour Code, under which the fines imposed for the most serious breaches of labour law have been raised. The purpose of the amendment is to make employee protection more effective and to strengthen the deterrent effect of sanctions imposed on employers. Following the amendment, the penalties range from PLN 2,000 to PLN 60,000 (previously from PLN 1,000 to PLN 30,000). In addition, the fine for the offence specified in Article 282 § 3 of the Labour Code has been increased from PLN 1,500–45,000 to PLN 3,000–90,000.

4. “Women on Boards” Act adopted by the Sejm – greater gender balance on the governing bodies of public companies

The Sejm of the Republic of Poland has adopted an amendment intended to ensure greater gender balance on the governing bodies of the largest public companies, including State Treasury-owned companies. The regulations apply to large listed companies with their registered office in Poland where at least one share is admitted to trading on a regulated market in an EU Member State. In line with EU standards, the regulations will cover companies employing at least 250 employees whose annual turnover exceeds EUR 50 million or whose annual balance sheet total exceeds EUR 43 million. Micro, small and medium-sized enterprises are fully exempt from the application of this Act.

5. New anti-bullying regulations

On 4 August 2026, the Act of 19 June 2026 amending the Labour Code and the Code of Civil Procedure was published in the Journal of Laws (Journal of Laws of 2026, item 1046). Its purpose is to make the protection of employees against workplace bullying, discrimination and other forms of violation of dignity in the workplace more effective. The new regulations are intended to make it easier for employees to pursue claims while clarifying employers’ obligations to counteract undesirable conduct in the work environment.

The new regulations impose more specific obligations on employers with regard to preventing workplace bullying and discrimination. Merely having a formal procedure in place will no longer be sufficient. Employers will be required to take genuine preventive measures and respond to reported infringements.

In practice, this will require employers to:

·        implement procedures to prevent workplace bullying and discrimination,

·        define rules for reporting undesirable conduct,

·        take investigative action after receiving a report,

·        support persons affected by workplace bullying or discrimination,

·        conduct educational activities.

The new regulations will enter into force three months after the date of publication of the Act, i.e. on 5 November 2026. However, employers will have six months from the effective date of the Act to prepare and implement the required procedures and internal regulations.

6. Proposed tax reform – changes to PIT and CIT from 2027

The government has presented proposed changes to the tax system that would take effect from 2027. The proposal provides for raising the first PIT threshold to PLN 130,000 while retaining the 12% tax rate. At the same time, a new 24% rate would be introduced for income between PLN 130,000 and PLN 150,000, while income exceeding PLN 150,000 would continue to be taxed at 32%.

The cost of the reform is to be partly offset by changes affecting businesses. The proposal provides for an increase in the CIT rate from 19% to 22% for companies with annual revenue exceeding PLN 200 million, an increase in the solidarity levy to 5%, and the reinstatement of the EUR 250,000 revenue limit for eligibility to apply the lump-sum tax on recorded revenue