Poland – employment law developments

In recent months, Polish employment law has undergone extensive reform, with several legislative amendments and new regulatory obligations entering into force across key areas of workforce management.

1. Act on Collective Bargaining Agreements and Collective Arrangements

The new provisions on collective agreements came into force on 13 December 2025, introducing an electronic system for submitting notifications and modifying the rules governing the registration of collective bargaining agreements. They also provide greater flexibility in their content, including the ability to regulate matters not regulated by law and extend their scope to individuals working under civil law contracts.

2. Transparency and equality in the recruitment process

As of 24 December 2025, employers became subject to new obligations due to the partial implementation of Directive (EU) 2023/970 on pay transparency and equal pay.

Job candidates must be informed about remuneration offered for the position, including all components and benefits, either as a specific amount or a range, based on objective and gender-neutral criteria. Relevant collective bargaining agreements or remuneration regulations must also be disclosed, where applicable. Information must be provided in paper or electronic form at the job advertisement stage, prior to the interview or before the establishment of the employment relationship. Additionally, job advertisements and job titles must be gender-neutral, recruitment processes must be non-discriminatory and employers are prohibited from requesting information on candidates’ previous remuneration.

3. Change to the deadline for payment of cash equivalent for unused annual leave

According to the Act of 4 December 2025, amending the Labour Code Act and the Act on the Company Social Benefits Fund, the rules governing the payment of cash compensation for unused leave have been modified. Until now, the Labour Code did not expressly specify the deadline for payment of cash equivalent for unused annual leave. As of 27 January 2026, such equivalent must be paid on the regular payday. If the regular payday falls before the termination of employment, the equivalent must be paid within 10 days following the termination.

4. Change in the form of selected actions under employment law

On the basis of the Act of 4 December 2025, the form of certain actions within the scope of employment law was also amended.

As of 27 January 2026, certain actions under employment law will no longer be required exclusively in written form and may be carried out either in paper or electronic form. This applies, in particular, to information on employee monitoring, transfers of undertakings, consultations with trade unions on termination of employment, work schedules, working time arrangements, notifications to employment inspectors, unpaid leave applications and employer instructions on OHS.

5. Changes in the calculation of length of service

As of 1 January 2026, the new rules for calculating length of service entered into force; however, they apply to private‑sector employers only as of 1 May 2026. Periods counted towards length of service now include, among others, non-agricultural business activity, mandate and agency contracts, cooperation periods, childcare-related suspensions of activity and certain periods of work abroad.

Employees have 24 months from the date the Act enters into force to submit the relevant documentation in order for these periods to be counted towards their length of service. Accordingly, private-sector employees must submit their documentation by 1 May 2028, whereas public-sector employees must do so by 1 January 2028. The amendments may result in longer holiday entitlement, longer notice periods and higher severance payments.

6. Minimum wage regulation

Under the Regulation of the Council of Ministers, as of 1 January 2026 the minimum monthly wage amounts to PLN 4,806 gross and the minimum hourly rate for certain civil law contracts is PLN 31.40 gross.

7. Draft bill on strengthening equal pay enforcement

On 16 December 2025, a draft bill fully implementing Directive (EU) 2023/970 was published. It aims to strengthen enforcement of equal pay through transparency, objective job evaluation criteria and new reporting obligations.

Employers will be required to establish transparent remuneration structures and, depending on workforce size, submit regular pay-gap reports. Employees will gain access to gender-disaggregated pay information and protection against retaliation. Sanctions for non-compliance may range from PLN 3,000 to PLN 50,000.

The draft bill is likely to be subject to further amendments. However, it is anticipated that the Act will come into force on 7 June 2026. Reporting obligations are expected to apply from 2027 for employers with at least 150 employees and from 2031 for employers with 100–149 employees.