1. Changes to sick leaves (L4)
On 13 April, changes to the sick leave procedure came into force. From now on, not every activity undertaken by an employee is automatically considered a breach of the binding rules. The new regulations clarify the concepts of gainful employment and activities inconsistent with the purpose of sick leave, stating that if a person on sick leave takes up incidental activities arising from important circumstances, such as signing an urgent document, such activities are permissible provided they are not carried out at the employer’s instruction and do not constitute regular work. A person on sick leave remains permitted to conduct ordinary daily activities and deal with exceptional situations, such as childcare. Additionally, the legislator has introduced a possibility to work for one employer while on sick leave from another if one’s state of health permits it.
2. The State Labour Inspection with new powers
At the start of the month, the President signed a bill amending the regulations governing the State Labour Inspection (PIP). The new regulations will come into force on 8 July 2026. One of the most significant changes is vesting inspectors with powers to convert incorrectly concluded civil law contracts, such as contracts of mandate or B2B contracts, into employment contracts. The procedure is to be multi-stage. First, PIP will issue a notice to remedy the breaches. Only if there is no response, will it be possible to issue a decision establishing an employment relationship. The decision may be appealed to the labour court, which will suspend its enforcement. The Act also introduces, among other things, the possibility of remote inspections, improved data exchange between state administrative bodies, i.e. PIP, ZUS and KAS, and higher fines in summary fine proceedings.
3. New forms for notifications to ZUS
The Ministry of Family, Labour and Social Policy has introduced new forms for social security and health insurance notifications, as well as reports submitted to ZUS, covering 23 documents, which will come into effect on 30 April and 1 May. These include, among others, notifications and changes to insured persons’ details (ZUS ZUA, ZZA, ZIUA), family members for health insurance (ZUS ZCNA), deregistration from insurance and contribution payers (ZUS ZWUA, ZWPA), registration and changes to payer details (ZUS ZPA, ZFA, ZIPA), information on bank accounts and business addresses (ZUS ZBA, ZAA), as well as personal reports and settlement declarations (ZUS RCA, RSA, RPA, DRA), including versions for selected groups of insured persons, and documents such as ZUS ZSWA, RIA, OSW and RUD.
4. Digitalisation in occupational medicine
On 17 April, a regulation came into force introducing the possibility of issuing electronic certificates in occupational medicine. The documents are available in medical systems and on the Online Patient Account, which reduces the need for paper forms, although these are still permitted in justified cases or at the employee’s request. The new regulations also clarify, among other things, the scope of information provided to the employer, limiting it to an assessment of work capacity, and streamline the flow of documentation, while providing for a transitional period for the implementation of the changes.
5. New compensation rates
As of 1 April, an insured person who has suffered permanent or long-term damage to their health because of an accident at work or an occupational disease is entitled to a one-off compensation payment of PLN 1,636 for each percentage point of impairment, representing an increase of PLN 205. To receive the one-off compensation, the employee or their employer must submit an application to ZUS, along with the required documents, including an accident report or card and medical records, and in the case of an occupational disease, also the decision of the health inspector. The degree of impairment is determined by a medical examiner or a ZUS commission after treatment has been completed. ZUS issues a decision within 14 days and pays the benefit within 30 days.
6. Length of service
The amendment to the Labour Code extends the list of periods counted towards length of service to include employment other than under an employment contract. In the public sector, the changes have been in force since 1 January 2026, and in private companies they will come into force from May 2026. Length of service will include, among other things, civil law contracts (contracts for specific tasks, service contracts, agency contracts), running a business (B2B) or assisting with it, periods of personally caring for a child while business operations are suspended, and membership of agricultural production cooperatives. In practice, this may increase the length of service for many people, which will, for example, allow them to obtain 26-day annual leave from their employer more quickly after exceeding 10-year service, instead of the current 20 days, and will also affect the amount of seniority allowances, long-service awards, the length of the notice period and the amount of severance pay.
Drawn up by: Dorota Dąbrowska-Kobus, attorney-at-law, Karolina Śledź, trainee attorney-at-law
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