Three months of the PIP reform. What do the first figures on B2B and civil-law contract inspections show?

Find out what the first data on B2B and contract-for-services inspections show, three months after the PIP reform entered into force.

On 8 July 2026 provisions entered into force allowing the authorities of the National Labour Inspectorate to establish the existence of an employment relationship by way of an administrative decision. Three months have passed and the first official figures, provided by the Chief Labour Inspector, have appeared. The picture that emerges from them differs from what had been expected until recently.

How many complaints and orders are there?

According to data from the Chief Labour Inspector, between 8 July and 18 September 2026 the sixteen regional labour inspectorates received 1,164 complaints concerning improperly applied civil-law contracts. During that time inspectors issued 355 orders to convert a civil-law contract into an employment contract, of which 287 were complied with. In the remaining cases the deadline for complying with the order has not yet expired.

By way of comparison: the figures from mid-August showed 690 complaints, more than a hundred inspections commenced and 121 written orders. At that point inspectors also recorded 201 cases in which the employer changed a civil-law contract into an employment contract of their own accord, before any legal measures were applied. The rate of increase in complaints is also visible on an annual basis: since the beginning of 2026 there have been 1,794, compared with 619 in the same period a year earlier.

How many administrative decisions have been issued?

The information provided indicates that there was no need to issue a single administrative decision. All orders whose compliance deadline has already expired were complied with, and no decision proceedings were initiated. The instrument that was described for six months as a breakthrough in employment supervision was not used in its first quarter in force.

The explanation lies in the sequence of steps. The inspector first issues an order to confirm employment on the basis of an employment contract. Only if the employer fails to comply may the inspector apply to the regional labour inspector for a decision to be issued. With 287 orders complied with out of 355 issued, the decision route was simply not needed.

The practical conclusion is that the moment that actually decides matters is the order, not the decision. That is when the entrepreneur chooses whether to confirm the employment relationship or prepare for further proceedings. So far, almost everyone has chosen the first route.

What about applications for an interpretation from the Chief Labour Inspector?

A second mechanism introduced by the same amendment operates in parallel: an application for an individual interpretation as to the nature of a specific cooperation arrangement.

When submitting an application, two things are worth remembering:

• Applications most often concern planned cooperation rather than ongoing cooperation. Entrepreneurs ask about a model they intend to implement, before they sign the contracts.
• An interpretation will not be issued where PIP or ZUS proceedings are already under way in the matter. An application filed after an inspection has begun will not stop it and will not replace a defence in the proceedings. It is a preventive instrument, not a rescue measure. The fee is PLN 40, and the deadline for issuing an interpretation is 30 days from a complete application.

What will change from 2027?

The Chief Labour Inspector announced that from 1 January 2027 inspections will be more targeted: based on risk analysis and data exchange with the National Revenue Administration and ZUS. It was also announced that where irregularities are demonstrated "there will be no leniency". The past three months were therefore a stage of responding to complaints, not of planned inspections.

The second date in the calendar is 8 July 2027. Until that day, a twelve-month period runs during which voluntarily concluding an employment contract with a person who has until now been working under a civil-law contract excludes liability for the petty offence under Article 281 § 1 point 1 of the Labour Code, punishable by a fine of up to PLN 60,000. The exclusion covers the petty offence itself, not arrears in contributions and taxes, nor employee claims.

If you use B2B cooperation or contracts for services on a wider scale, the coming months are a good moment for a review. Not so much of the contracts themselves, as of how that cooperation looks in day-to-day work organisation, because that is precisely what inspectors look at. A clause stating the absence of subordination will not help if the work is performed at fixed hours, at the counterparty's premises, on their equipment and under the ongoing instructions and supervision of a superior.