1. Outstanding annual leave

The employer must grant the employee the annual leave due for 2025 by 30 September 2026 at the latest. The deadline is met if the leave begins on or before that date, even if it ends later. Failure to grant leave by this deadline may result in a fine of up to PLN 30,000 for the employer. However, missing the deadline does not mean the leave is forfeited, as the right to the annual leave expires after 3 years.

2. Minimum wage set to rise

From 1 January 2027, new levels for the minimum wage and the minimum hourly rate will come into force. In accordance with the Regulation of the Council of Ministers of 14 September 2026, the minimum wage will be PLN 4,950 gross per month, while the minimum hourly rate will be PLN 32.30 gross.

3. Will the Central Register of Beneficial Owners (CRBO) be confidential?

The register is currently publicly accessible, but access will be restricted following the changes. Authorised bodies and institutions will be able to access it directly, while other interested parties will have to demonstrate a legitimate interest and submit an appropriate application. The changes stem from draft Bill UC75 on combating money laundering and terrorism financing. At present, entrepreneurs can verify a counterparty in the CRBO without much red tape. Following the changes, access to the data will require an additional application and a demonstration of legitimate interest, which may complicate and prolong the verification process. The new rules are due to come into force on 1 October 2027.

4. Amended Labour Code

From 24 September 2026, the new consolidated text of the Labour Code will come into force, incorporating the amendments introduced after 6 March 2025. It now includes, among other things, provisions concerning pay transparency, inclusion of additional periods in length of service, electronic submission of employee applications, extension of powers of the State Labour Inspection, and changes relating to workplace mobbing and discrimination.

5. Co-financing of work placements for minors

From 2027, new rules are set to make it easier for young people to undertake paid work placements, while also encouraging employers to organise them. Employers taking on interns under the age of 18 will be eligible for a grant from the Labour Fund of PLN 750 per month. This amount will comprise PLN 500 in benefits for the intern and PLN 250 for the employer to cover expenses related to organising the internship.

6. New draft amendment to the Act on Foreigners

The latest draft amendment to the Act on Foreigners, prepared by the Ministry of the Interior and Administration, aims to reduce the waiting time for the processing of applications for temporary residence in Poland. It provides for the introduction of a mechanism for the tacit conclusion of proceedings: if the authorities fail to issue a decision within 60 days, the application will be deemed to have been granted. However, this solution is not intended to apply to all foreigners, but only to nationals of selected countries meeting specific economic and financial criteria. The countries currently identified are Australia, Japan, the Republic of Korea, the USA, and the United Kingdom of Great Britain and Northern Ireland. The aim of the changes is to streamline proceedings and reduce waiting times for decisions.

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