Publication date: May 11, 2026
Labor law is a key area of the legal system, directly impacting the professional and social situation of millions of employees and employers. Dynamic changes in the labor market, technological progress, and economic conditions necessitate adapting legal regulations to new realities. Recently, we have observed increased legislative activity in this area, not only in Poland but also in the EU. The Labor Code is amended almost annually. This year, 2026 will be no different. This time, however, the amendments will affect a very large portion of society and will address issues such as seniority, salary transparency, recruitment neutrality, and even the gender pay gap. Therefore, for context, it is worth reviewing the new regulations that entered into force at the end of 2025, and then moving on to those that await us this year. At the end of this article, we will also highlight possible legal changes that have been announced for a long time. Their implementation is highly probable and could bring significant changes. Therefore, it is worth being aware of them.
Collective labor agreements
The Act on Collective Bargaining Agreements and Collective Agreements entered into force on December 13, 2025. The new regulations eliminate the current registration of agreements by District Labor Inspectorates and the Ministry and introduce the National Register of Collective Bargaining Agreements (KEUZP), which will record all collective agreements and agreements. All regulations are transferred from the Labor Code to the new Act of November 5, 2025, on Collective Bargaining Agreements and Collective Agreements. The changes are intended to facilitate the conclusion and registration of collective agreements, streamline procedures, and support social dialogue between employers and trade unions through, among other things, an open catalog of matters regulated by collective agreements, the possibility of concluding them for a fixed or indefinite period, and simplifying the procedure for extending a multi-employer agreement. It is worth noting that agreements, additional protocols, and collective agreements will be registered in an electronic system, not in paper form. The agreement will come into effect on the date specified therein, but not earlier than the date of proper notification to KEUZP. During the transition period (since there is a two-year deadline for establishing the KEUZP) before the KEUZP is fully operational, new agreements and protocols are submitted electronically to the Ministry of Family, Labor, and Social Policy. The act promotes mediation, allowing for the use of a mediator or expert during negotiations. The new regulations allow for broader regulation of issues such as work -life balance, gender equality, anti-mobbing procedures , and the use of artificial intelligence (AI) in the workplace. The principle of benefit (the provisions of the agreement cannot be less favorable than the Labor Code) and the principle that the agreement automatically becomes part of the employment relationship have been maintained.
Pay transparency and neutrality in recruitment
As of December 24, 2025, changes to job advertisements and the recruitment process itself came into effect. This means that job advertisements must use gender-neutral job titles. This means that both the job advertisement and the job title should not suggest the candidate’s gender. For example, when hiring an administrative assistant, the job advertisement should indicate that the position is being sought for administrative work or an administrative assistant. Additionally, candidates must know the salary for the position they are applying for (either in the form of a salary range or a specific amount). This information should be included in the advertisement or at the latest before the interview. This remuneration includes all its components, including annual bonuses (wage-related) and a company laptop (non-wage-related). Art. 221 of the Labor Code, which prevents employers from asking about job candidates’ salary histories (current and past earnings), while employees gain the right to information about the average salary levels of employees performing the same work or work of equal value, broken down by gender. The regulations are intended to impact the recruitment process, making it more transparent and clear, and also to prevent the pay gap from shifting between companies. From the employer’s perspective, this will mean changes to job ad templates, recruitment processes, mandatory salary disclosure (including all elements), and the risk of claims or compensation for non-compliance with the new requirements.
Seniority and minimum wage
From January 1, 2026, the rules for calculating length of service are changing. In accordance with Article 302¹ § 1-7 of the Labor Code, length of service will include not only periods of employment under an employment relationship, but also numerous forms of professional activity and the status of individuals performing work outside of an employment contract. If these periods overlap, the most favorable period for the employee will be included. This provision comes into effect on January 1, 2026, for entities operating in the public finance sector, and on May 1, 2026, for other employers. Length of service will include: mandate contracts, service contracts, performance of an agency contract, being a collaborator with a person performing the previously mentioned activity, membership in an agricultural production cooperative, and membership in a cooperative of agricultural circles, if covered by pension and disability insurance during these periods. Gainful employment abroad on a basis other than an employment relationship will also be included. The changes will result in, among other things, longer leave (from 20 to 26 days after reaching 10 years of service), higher severance pay, seniority or anniversary bonuses, and a longer notice period. The seniority allowance will only be valid upon confirmation through appropriate documentation. The employee has 24 months to do so, and after that time, the employer will not be obligated to include it. Pursuant to Article 302¹, Sections 11–13 of the Labor Code, the method for confirming periods of professional activity that are to be included in the length of service depends on the type of activity performed. Legislators have introduced three separate types of certificates issued by the Social Insurance Institution (ZUS). Effective January 1, the minimum wage will also increase to PLN 4,806 gross, while the minimum hourly rate for individuals accepting contracts or providing services will be PLN 31.30. The increase in the minimum wage also affects other rates when calculating salaries and benefits, so it is worth paying attention to this, for example, the maximum statutory severance pay is PLN 72,090 gross.
Change in sick leave
From January 1, 2026, the issue of sick leave will also change, most importantly, expanding the scope of the Social Insurance Institution (ZUS). Due to the abuse of sick leave, more inspections will be introduced. The amendment introduces new provisions, allowing employees to combine sick leave with work for another employer in justified cases. Furthermore, during sick leave, employees will be able to perform minor tasks, such as answering the phone, replying to emails, or signing documents. The payment of sick leave benefits will also change and will apply from the first day of sick leave. As a result, the obligation to pay the employee’s salary and settle the claim with the Social Insurance Institution (ZUS) will be transferred to ZUS itself, while the employer will be released from this obligation. The issuance of ZUS medical certificates will be accelerated through reorganization and standardization. The procedure for issuing certificates will be supported by medical assistants, and the deadlines will be significantly shortened, and in justified cases, a nurse or physiotherapist will be able to issue a certificate. ZUS will also be able to request medical documentation from doctors and facilities and verify the validity of care allowances. Under the new regulations, if a person taking sick leave is employed, they may lose their entitlement to sickness benefits for the entire sick leave period. However, the legislature has provided an important exception. If an employee has two employment contracts and the sick leave is valid only with one employer, they can continue working for the other employer without fear of losing their entitlement to benefits. The condition is that the duties of the second job do not interfere with treatment or delay recovery.
The increasing digitalization of labor law and changes in holiday pay
As of January 27, 2026, the written form requirement for certain labor law documents will be abolished. In practice, this means that written form will no longer be required for information about workplace monitoring, notification of the transfer of a workplace or part thereof, notification to a trade union of the intention to terminate an employee’s employment contract and reasoned objections from a trade union, employee requests regarding the introduction of certain working time systems, requests for an individual work schedule, requests for time off for overtime, requests for remote work, and occupational health and safety procedures related to risk assessment and the provision of instructions. As a reminder, written form requires the document to be signed with a handwritten signature or a qualified electronic signature compliant with the EU eIDAS regulation. Once the changes come into effect, the documents indicated above can be prepared in paper or electronic form. The electronic form will include both documents with a qualified electronic signature (electronic form as defined in Article 78¹ of the Civil Code) and emails, provided they enable the identification of the person submitting the declaration. Until now, the deadline for paying compensation for unused vacation leave was not explicitly stipulated in applicable regulations. However, following the changes, employers will be obligated to pay this compensation on the last salary payment date or within 10 days of the date of termination of employment (if the salary payment date falls before the date of termination). Changing the compensation payment deadline will allow employers to avoid potential errors in calculating the compensation amount, which they will be able to calculate after the termination of employment and will reduce the burden on employers by reducing the number of payments for salary or vacation compensation. The project also ensures greater employee representation in matters related to the company social benefits fund at employers without trade unions.
Pay Transparency Directive
Poland has until June 7, 2026, to implement the provisions of Directive 2023/970; the amendment to the Labor Code represents the first step in this direction. The directive includes, among other things, the obligation to report the gender pay gap, initially in large companies with over 250 employees. If the gap exceeds 5% and is not justified by objective criteria, the employer will be required to conduct a pay assessment in conjunction with trade unions or employee representatives. The amendment to the Labor Code represents the first step towards implementing Directive 2023/970 in Poland. Furthermore, a pay structure must be introduced within companies, which means tables classifying positions within specific pay groups. Ultimately, employees will be entitled to information on the average remuneration of employees performing the same work or work of equal value. Furthermore, job evaluation will be mandatory, meaning the establishment of a hierarchy of positions within the company and objective criteria, such as qualifications, effort, responsibility, and working conditions (not personal characteristics) for a given position. This is intended to establish a foundation for proving that people in different positions are performing “work of equal value.” It’s also worth mentioning that the new regulations will result in new sanctions for non-compliance, including full compensation (back pay, bonuses) for employees who have been victims of pay discrimination. Importantly, the burden of proof has shifted to the employer.
Possible Changes in Counteracting Mobbing and Discrimination
The planned entry into force is 21 days after publication in the Journal of Laws. The draft amendment to the Labor Code concerning mobbing has been adopted by the Standing Committee of the Council of Ministers and is continuing its legislative work. The amendment will include a change in the definition of mobbing, specifying that it is persistent harassment of an employee that is repetitive, recurrent, or permanent. Incidental inappropriate behavior is excluded from mobbing, which is intended to reduce the number of false accusations. The new regulations clearly state that mobbing can take verbal, nonverbal, and physical forms, which are not covered by the current Labor Code. The intention of the perpetrator’s behavior and the occurrence of a harmful effect are excluded from the assessment of whether mobbing has occurred. Furthermore, possible perpetrators of mobbing are listed as supervisors, co-workers, and subordinates (the perpetrator can be a single person or a group). Ordering or inciting this type of violence is equated to mobbing in terms of punishment. Every employer is obligated to implement procedures to prevent mobbing and to quickly and effectively respond to reports of this type. Due to growing employee awareness of their rights, the importance of redress is also growing. Every employee experiencing abuse is entitled to compensation of at least six times the minimum wage. If both mobbing and a violation of the principle of equal treatment occur, the victim is entitled to compensation of at least three times the minimum wage. As far as civil liability for mobbing in the workplace is concerned , the employer is generally liable, but he or she may be exempted from liability if he or she implements appropriate anti-mobbing regulations and the victim’s co-worker commits mobbing (according to the draft act of 30 May 2025 amending the Labor Code and the Civil Procedure Code, art. 9433). Furthermore, the draft assumes the unification of defined forms of harassment (simple) and its qualified form (sexual harassment), following the example of the currently applicable provisions regarding sexual harassment, as actions occurring physically, verbally and non-verbally, the introduction of the principle of the distribution of the burden of proof in cases concerning the violation of the principle of equal treatment by placing the burden of proof on the employee by placing the burden of proof on the employer to prove that the violation of the principle of equal treatment did not occur, specifying that the obligation to counteract violations of the principle of equal treatment and mobbing is fulfilled by applying preventive measures, detecting and reacting quickly and appropriately, as well as by taking appropriate measures. corrective measures and support for people affected by unequal treatment, supplementing the code catalogue of employer obligations to counteract violations of dignity and other personal rights of employees.
| Area of change | Adjustment range | Effective date | The most important effects |
| Social dialogue and collective bargaining agreements | New act on collective bargaining agreements, establishment of the National Register of Collective Bargaining Agreements (KEUZP), simplification of procedures, mediation | December 13, 2025 | Easier conclusion of agreements, electronic registration, wider scope of collective regulations |
| Recruitment and salary transparency | Gender neutrality of job advertisements, obligation to disclose remuneration, prohibition of asking about salary history, right to information on average salaries | December 24, 2025 | Greater transparency in recruitment, reducing the pay gap |
| Seniority and benefits | Including civil law contracts and work abroad in the internship, new rules for confirmation by the Social Insurance Institution (ZUS), increase in the minimum wage | January 1, 2026 (partially from May 1, 2026) | Longer leave, higher severance pay and bonuses, higher benefits linked to the minimum wage |
| Sick leave | Extended ZUS inspections, possibility of minor activities during L4, payment of benefits from the first day by ZUS, faster certification | January 1, 2026 | Limiting abuses, relieving employers of sick pay |
| Digitization of employee documentation | Abolition of the written form requirement for many documents, allowing electronic form, changes in the payment of holiday allowance | January 27, 2026 | Simplification of procedures, reduced administrative burden |
| Equal pay (EU law) | Implementation of Directive 2023/970, pay gap reporting, salary structures, job evaluation, new sanctions | Partially from 2025, full implementation by June 7, 2026. | Strengthening the principle of equal pay for women and men |
| Mobbing and discrimination (project) | New definition of mobbing, list of perpetrators, obligation of anti-mobbing procedures, compensation, unification of the concepts of harassment | Planned (after announcement) Act) | Strengthening employee protection and employer liability |
Major Changes to Polish Labour Law in 2026 – What Employers Need to Prepare For
2026 brings one of the most significant waves of labour law reforms in recent years in Poland. The upcoming amendments will reshape recruitment processes, pay transparency obligations, seniority calculations, sick leave procedures, workplace digitisation, collective bargaining, and anti-mobbing responsibilities.
Key legal developments include:
Pay Transparency & Recruitment
Employers will be required to:
✔ disclose salary ranges already at recruitment stage,
✔ use gender-neutral job advertisements,
✔ avoid asking candidates about salary history,
✔ provide access to information on average remuneration levels.
These changes are part of the implementation of the EU Pay Transparency Directive and are intended to reduce the gender pay gap and strengthen equal treatment standards.
New Rules on Seniority
From 2026, periods worked under civil law contracts, agency agreements, and even certain forms of work performed abroad may count toward employment seniority. This will directly affect:
Changes to Sick Leave
The Social Insurance Institution (ZUS) will take over payment of sickness benefits from day one of absence, while inspections related to sick leave abuse will intensify. Employees may also perform limited professional activities during sick leave under specific conditions.
Digitalisation of Employment Documentation
Many employment-related documents will no longer require written form and may be processed electronically, significantly reducing administrative burdens for employers.
Collective Bargaining Reform
The new National Register of Collective Bargaining Agreements (KEUZP) introduces electronic registration and broader possibilities for regulating workplace matters, including AI usage, work-life balance, and anti-mobbing measures.
Anti-Mobbing & Anti-Discrimination
Planned amendments will broaden the definition of mobbing, strengthen employer obligations regarding preventive procedures, and shift the burden of proof in discrimination cases increasingly toward employers.