Publication date: January 28, 2026
In Poland there is planned the e-contract system – central IT system operated by the Ministry of Family, Labor and Social Policy. It will enable the electronic conclusion and management of employment contracts, contracts of mandate, contracts for specific work, and other HR documents, integrating with public registers (ZUS, CEIDG, KAS). Accessible through praca.gov.pl, the system will simplify HR processes, automate ZUS filing, provide access to documentation for the National Labor Inspectorate (PIP), and store and manage full employee records online, becoming a tool for the comprehensive digitization of the labor market.
The digital transformation of Polish public administration, observed over the last decade, is an evolutionary process, moving from simple mapping of paper processes in digital form (digitalization) to a fundamental reconstruction of public service delivery models (digitization).
Previous milestones, such as the introduction of the Standard Audit File (JPK), the mandatory electronicization of sick leave (e-ZLA), and the implementation of the National e-Invoice System (KSeF), focused primarily on the fiscal and insurance relationships between businesses and the government. The goal of these systems was to tighten the tax system and automate audits.
The draft act of November 16, 2022, on the IT system for handling certain contracts was developed by the Ministry of Family and Social Policy. The Sejm (lower house of parliament) debated the act in just three days, which significantly impacted the quality of the legislation. The act was submitted to the Senate on November 17, 2022. In a resolution of December 15, 2022, the Senate proposed an amendment to Article 19 of the act. The Senate Legislative Office noted that the Sejm act attempted to amend Article 58, paragraph 1, item 4 of the Act on Electronic Delivery. The problem was that this provision had already entered into force on October 1, 2022, while the Act on the Contract System was intended to amend it retroactively. The senators argued that this was legislative nonsense and a violation of the principles of proper legislation – one cannot amend a legal vacuum or give retroactive effect to procedural provisions in this manner. The Senate’s amendment was purely procedural and did not change the substantive meaning of the bill. Nevertheless, after the bill returned to the Sejm, the lower house rejected the Senate’s amendment. The vote to reject the amendment (232 in favor, 217 against) fell along the political divide between the government and the opposition. This is a striking example of the primacy of politics over the quality of law – the parliamentary majority preferred to pass a bill with a technical error rather than accept an amendment from the opposition-controlled chamber.
The system introduced by the bill expands the scope of computerization to include relationships between businesses and employees, as well as relationships between consumers. It offers a state-funded IT infrastructure for building civil law and employment relationships at their very foundations. Business organizations enthusiastically welcomed the bill, seeing it as an opportunity to reduce legal costs, although concerns were raised regarding ensuring the system’s interoperability with HR and payroll software used by larger businesses. The labor side, specifically the Solidarity trade union, supported the changes, pointing to the benefits for employees in the form of job security. A contract registered in the government system is more difficult to challenge than a verbal agreement. The system guarantees that pension contributions are actually paid. However, trade unionists highlighted the risk of digital exclusion for some employees and the need to ensure that the system allows for reporting abuses to the National Labor Inspectorate.
Data protection authorities and organizations were less enthusiastic. The President of the Personal Data Protection Office (UODO) raised serious concerns about the principle of data minimization (Article 5, Section 1, Letter c of the GDPR). By aggregating data on all civil law and employment contracts for millions of people, the system is becoming a powerful database of information about citizens’ lives. Particular criticism was leveled at the ZUS (Social Insurance Institution) mechanism for transferring sick leave data (sensitive data under Article 9 of the GDPR) to the system, which could be accessed by a wider range of officials than just ZUS employees.
The system was originally scheduled to launch within three years of its entry into force, and the first version will be released in January 2026. Further functionalities will be added in 2027.
The system supports four contract categories: Employment Contract – a fundamental type of contract regulated by the Labor Code (Article 22 § 1). The system allows for contracts for a trial period, a fixed-term contract, or an indefinite period. Data specified in Article 29 § 1 of the Labor Code must be entered into the system: the type of work, the location of work, remuneration with an indication of the components, working hours, and the start date. Importantly, the system enforces compliance with minimum wage regulations, blocking the possibility of concluding a contract with a rate lower than the one in force in a given calendar year. Mandate Contract – a civil law contract regulated by the Civil Code (Article 734). The system supports standard contracts in which the contractor undertakes to perform specific legal or factual actions for the contractor. The system enables monitoring of the minimum hourly rate applicable to contractors. Service Contract – to which the provisions on mandate contracts apply (Article 750 of the Civil Code), but which are not strictly mandates. This applies to a wide range of services not regulated by other regulations. Activation Agreement – This is a specific type of agreement, introduced by the Act of 4 February 2011 on the care of children under 3 years of age. Due to the complex system of subsidies from the state budget for ZUS contributions (as the budget finances contributions based on a base of 50% of the minimum wage), this agreement was difficult for parents to independently calculate. The IT system takes over the entire burden of these calculations, which is one of the most significant social benefits of the act.
The entities currently eligible to use the system can be divided into four groups: First, micro-entrepreneurs within the meaning of the Entrepreneurs’ Law, i.e., legal entities or individuals undertaking organized gainful activity, performed on their own behalf and continuously, who in at least one of the last two financial years employed fewer than 10 employees on average and achieved an annual net turnover not exceeding €2 million. Second, other entities that are not micro-entrepreneurs but employ no more than nine people. These may include, for example, associations and public benefit organizations. These two groups are collectively referred to as “employers”. The third group consists of farmers within the meaning of the Farmers’ Social Insurance Act, i.e., individuals who personally conduct agricultural activity on their farm, including as part of an agricultural producer group, as well as individuals who have designated land on their farm for afforestation. This will be a significant relief for all three groups, as they cannot afford to maintain large HR departments. The system will significantly simplify the work of a single employee responsible for personnel administration, or if one is not available, for the entrepreneur themselves. The final group comprises individuals who do not belong to any of the previous groups. This most likely refers to parents, for the purposes of concluding an activation agreement.
The contract management system allows the employer, client and parents to: conclude a contract, amend the contract, terminate the contract, manage the contract expiry, calculate the amount of leave and vacation leave to which the employee is entitled, maintain and store employee documentation, issue an employment certificate, access employee and contract documentation, calculate tax liabilities of the employee and contractor and submit to the tax office information on collected income tax advances referred to in the Personal Income Tax Act of 26 July 1991.
The system also provides information on the employer’s disclosure obligations under paragraphs 3-33 of Article 29 of the Labor Code. It also enables the transfer of documents concerning the parties’ declarations of intent regarding personal data, data management, and the submission of requests for care or leave, for example, or other documents related to the contract and work performed. The documents can also be obtained by the employee’s family members if necessary for insurance or inheritance purposes.
Concluding and managing a contract through the system is not mandatory. It requires the express consent of both parties. Such consent, once granted, remains binding for the duration of the legal relationship. To ensure contract processing, it is necessary to enter the data necessary to conclude the contract into the System and complete the contract form provided in the System. The parties are responsible for the accuracy of the data. A contract managed through the System is concluded upon affixing a qualified electronic signature, personal signature, or trusted signature by the parties. This form is equivalent to a written form. Amendments to, or termination of, a contract managed through the System, or the issuance of an employment certificate are made using the form provided in the System. The parties to the contract can download employee documentation from the System or contract documentation required to be maintained in the System. Upon request, the documentation should also be provided to the new employer who replaced the previous employer, as well as the successor administrator following the employer’s death.
The contract is managed and the documentation is kept for a period of 10 years from the termination or expiration of the contract, or for a maximum period of two years from the loss of the status entitling the client, entrepreneur or farmer to use the system
The initial draft did not resolve all the issues, so the successor to the original initiator of the legislative process, the Ministry of Family, Labor, and Social Policy, began work on amending the act even before the system’s launch. This work is currently at the General Committee of the Council of Ministers stage. As stated on the government website, thanks to the amendment to the Act of November 16, 2022, on the IT system for handling certain contracts, entities employing employees will complete formalities faster and more easily. Unlike the initial system, which was designed to handle simple contracts concluded by small entities, the amended system will allow any interested entity to conclude contracts, regardless of status or size. Furthermore, changes are planned to enable the conclusion of contracts other than the four listed above, such as a volunteering agreement and contracts accompanying employment, such as a non-competition agreement, a training agreement, or a joint financial liability agreement. In addition, it is planned to increase the functionality of the System by, for example, enabling the confirmation of an employee’s presence in the System or reporting the commencement of remote work, as well as expanding the catalogue of public administration bodies and information transferred to the system in order to reduce the bureaucratic burden.