1. Draft bill on pay transparency

At the end of April, a second draft bill was published on strengthening the application of the right to equal pay for men and women for work of the same nature or work of equal value, implementing EU Directive 2023/970 on pay transparency and the enforcement of the principle of equal pay. The draft provides, among other things, for the establishment of a Commission for Combating Discrimination in Employment with broad supervisory powers and for tougher penalties for a lack of pay transparency (up to PLN 60,000). It also provides for the introduction of uniform reporting rules, extension of the analysis of the situation of employees returning from parental leave, as well as strengthening of the role of trade unions and the supervision of the State Labour Inspection. It has been agreed that the act will enter into force within 6 months from the date of its publication.

2. Digitisation of PIT forms

On 4 May, a draft bill amending the Personal Income Tax Act and the Corporate Income Tax Act was published. The draft bill provides for the abolition of the obligation for tax remitters to provide taxpayers with PIT-11, PIT-R, PIT-8C, IFT-1R and IFT-2R forms – these documents are to be made available via the Twój e-PIT service. However, it will be possible to provide them at the taxpayer’s request. The forms will have to be submitted electronically to the tax office by 31 January each year. It has been indicated that these provisions will come into force on 1 January 2027.

3. New rules on length of service now apply to everyone

Please note that from 1 January 2026 in the public sector, and from 1 May 2026 in the private sector, periods other than employment under an employment contract are also included in length of service, including periods of performing civil law contracts, running a business (B2B) and periods of childcare during the suspension of business activity. These changes extend length of service, which translates, among other things, into earlier entitlement to 26-day holiday leave upon reaching 10-year service (instead of 20 days), and also affects length-of-service allowances, long-service awards and notice periods. The new periods require appropriate documentation, e.g. a certificate from the Social Insurance Institution (ZUS) available on PUE.

4. Less paperwork for Employee Capital Plans

The Council of Ministers has adopted a deregulation bill simplifying the administration of Employee Capital Plans. Notifications to employers regarding Employee Capital Plans will be sent electronically via their Social Insurance Institution (ZUS) account, rather than by post. Documents are to be signed electronically, which should speed up and improve communication. A notice will be deemed to have been served on the date it is viewed in the ZUS account or 14 days after it is made available in that account. Employers will still have 30 days to conclude a PPK management agreement. The new regulations are due to come into force 14 days after their publication in the Journal of Laws.

5. Internship Act

The draft of the new act provides that internships will mainly be carried out on the basis of an employment contract, although interns will not be subject to all the provisions of the Labour Code. Remuneration during an internship is to amount to at least 65% of the minimum wage. Temporary employment agencies will be banned from placing interns at a company, with financial penalties for breaches. Compared to the previous version, the draft bill is less detailed – specific regulations concerning working hours, days off and health and safety obligations, among other things, have been removed. The maximum duration of an internship, set at 6 months, remains unchanged, as does the exclusion from the act of student internships, internships organised by labour offices and professional traineeships. The new regulations are due to come into force on 1 January 2027.

6. Case Handling Module for foreigners

From 27 April 2026, the MOS (Case Handling Module) IT system has been in operation, through which foreigners may submit applications for temporary residence permits, permanent residence permits and EU long-term resident status, exclusively in electronic form. Paper applications sent before this date but delivered to the office after 27 April 2026 will not be processed. Other applications, including those concerning intra-corporate transfers, worker mobility, family reunification and family members of Polish, EU and UK citizens residing abroad, must still be submitted in paper form, in accordance with the hitherto rules.

Drawn up by: Dorota Dąbrowska-Kobus, attorney-at-law, Karolina Śledź, trainee attorney-at-law