Newsletter | Employment law in Poland | July 2025

Shortened working hours pilot programme - details announced

The Ministry of Family, Labour and Social Policy has announced the rules for the shortened working hours pilot programme. Employers' applications to participate in the project will be accepted electronically from August 14 to September 15, 2025. Employers will be notified of the selection process results by 15 October 2025, and the pilot program will commence on 1 January 2026 and run until the end of 2026.

To participate in the pilot programme, several conditions must be met, including operating for at least 12 months prior to the date of application, employing at least 75% of people based on an employment contract, covering at least 50% of the workforce with the pilot programme, and maintaining employment at a level of at least 90% of the initial level, without deteriorating working and pay conditions. The maximum value of support per pilot project is PLN 1 million. Importantly, the cost of the project per employee covered by the pilot programme cannot exceed PLN 20,000. The pilot project may finance, among other things, information and promotion activities, costs related to project management, participant recruitment, monitoring, research, analysis and training for employees.

Soon, a team for reduced working hours will be appointed among the representatives of the ministry. Its task will be to monitor the pilot project on an ongoing basis, support its implementation and develop legislative recommendations.

Planned changes to the rules for calculating length of service refferred for further work

On 24 June 2025, the Council of Ministers adopted and submitted to the Sejm a draft amendment to the Labour Code prepared by the Ministry of Family, Labour and Social Policy, providing for changes in the rules for calculating length of service.

The amendment provides that seniority will include, among other things, periods of running a sole proprietorship and performing work under a contract of mandate, as well as periods of performing an agency contract, remaining a person cooperating with persons performing these contracts, remaining a member of an agricultural production cooperative and a farmers' cooperative, or periods of suspension of business activity by a person conducting non-agricultural business activity to provide personal care for a child, for which pension and disability insurance contributions have been paid. The above-mentioned periods are to be confirmed by certificates issued by the Social Insurance Institution (ZUS).

According to the draft, the new regulations are to come into force on 1 January 2026.

Further work on the implementation of the EU Directive on pay transparency

Work on the comprehensive implementation of the EU directive on pay transparency is underway. Although the exact date of publication of the draft regulations is not yet known, the Ministry of Family, Labour and Social Policy has shared the first details of the planned solutions, which are intended to make it easier for employers to comply with the new regulations.

The Central Statistical Office (GUS) will be responsible for creating a system for reporting data on the pay gap. In addition, in cooperation with the Central Institute for Labour Protection (CIOP-PIB), the ministry is preparing a free tool to help employers evaluate jobs by the requirements of the EU directive. As part of this work, a free handbook will also be produced, which will show step by step how to reliably compare the value of work in different positions.

Planned changes to the process of confirming health and safety training and submitting applications for caregiver benefits

As part of its deregulation efforts, the Ministry of Family, Labour and Social Policy, has drafted an amendment to the regulation on health and safety training from 20 June 2025, which will enable employees to confirm completion of initial health and safety training not only with a traditional signature on paper or a qualified electronic signature, but also by e-mail or instant messaging. The employer will be required to attach such confirmation to the training card and make an appropriate note. The new solution is to come into force in the fourth quarter of 2025.

The Ministry also plans to simplify the procedures for applying for childcare allowance. Currently, the Z-15 application must be submitted in paper form or electronically using a qualified signature or a trusted profile. The draft provides for the possibility of applying for an electronic form, including a scan or e-mail.

Proposed deregulation solutions in the labour code and the act on the company social benefits fund

The Ministry of Family, Labour and Social Policy has prepared a draft amendment to the Labour Code and the Act on the Company Social Benefits Fund, the main purpose of which is to simplify employers' obligations and digitise certain procedures.

According to the amendment, the cash equivalent for unused holiday leave is to be paid on the date of payment of remuneration (and not, as previously, on the date of termination of the employment contract). The draft also provides for a change in the rules of employee representation in matters relating to the Company Social Benefits Fund. The provisions of the remuneration regulations concerning the amount of the contribution to the Fund or the non-creation of the Fund will require agreement with at least two employees selected by the staff to represent their interests.

The draft also extends the list of documents that can be submitted in electronic form. This applies, among other things, to information on monitoring, the conditions for the transfer of the workplace to another employer, consultations with the trade union organisation on the intention to terminate an employment contract, the employer's instructions and guidelines on familiarising employees with health and safety regulations and rules, as well as requests concerning the organisation of working time and the granting of time off.

The draft has been submitted for public consultation and is currently being reviewed. The new regulations will come into force 14 days after their publication in the Journal of Laws.

New regulations concerning monitored redundancies

In connection with the entry into force of the Act of 20 March 2025 on the labour market and employment services, some of the provisions relating to so-called monitored redundancies have been amended.

The new Act clarifies the definition of a monitored dismissal, specifying that it is a situation where an employer intends to dismiss at least 50 employees within 3 months for reasons related to the workplace. In such a case, the employer is obliged to take measures to ensure that employees have access to labour market services in the form of various programmes aimed at enabling the dismissed employees to continue their employment after their dismissal. The provisions in force from 1 June 2025 clarify the procedure to be followed by employers in the event of monitored redundancies.

In the case of monitored redundancies, after prior consultation with the district labour office, the employer shall provide employees who are to be made redundant, who are in the process of being dismissed, or who have been dismissed, with assistance in the form of, among other things, job placement, career guidance, training, confirmation of acquired knowledge and skills, and obtaining documents confirming the acquisition of knowledge and skills, which shall be provided in the form of special, dedicated programmes. The programmes may be financed by bodies or by the employer and relevant public administration bodies, or based on an agreement between organisations and legal persons with the participation of the employer.