HR Radar | A summary of 2025

Changes in how foreigners are employed

On 1 June 2025, the Act on the Conditions of Permissibility of Entrusting Work to Foreigners on the Territory of the Republic of Poland came into force, introducing practical changes to immigration law. The key changes mainly included:

1. the abolition of the so-called labor market test which required obtaining information on the local labor market before obtaining a work permit,
2. the full digitization of work permit procedures: currently, work permit applications are only completed online,
3. the obligation for employers to provide a copy of the employment contract to the work permit issuing authority, and
4. currently, if an employer has been conducting a business activity for less than one year, a work permit may be issued for a maximum period of one year.

Under the Act, an employer who illegally employs a foreigner is currently subject to a fine of between PLN 3,000 and PLN 50,000. The Act also provides a list of circumstances under which employment is legal.

In 2026, we can expect further changes in the employment of foreigners, including the implementation of the act on digitization.

A new strategy for the labor market

On 1 June 2025, the Labor Market and Employment Services Act also came into force, replacing the previous Act on Employment Promotion and Labor Market Institutions.

Among other things, the Act introduced the possibility for employers to receive subsidies when hiring unemployed persons who are over 50 but under 60 (in the case of women) or 65 (in the case of men). The subsidy amounts to a maximum of 50% of the minimum monthly wage. In addition, the Act provides, among other things, that:

1. registration as an unemployed person is not dependent on the place of residence,
2. farmers have the option of registering with labor offices, and
3. unemployed persons from large families or single parents are to be given priority assistance.

Georgian citizens are no longer covered by simplified employment rules in Poland

On 1 December 2025, a regulation came into force that significantly affects the employment of Georgian citizens in Poland. Currently, citizens of Armenia, Belarus, Moldova, and Ukraine can still benefit from simplified employment rules in Poland. However, these rules no longer apply to Georgian citizens.

Electronic confirmation of the completion of health and safety training

On 12 December 2025, a regulation came into force which provisions enable both employees and managers of an organisational unit to confirm that they have completed general and workplace training via an electronic form.

New legislation on pay transparency for candidates and on gender-neutral wording of job title

On 24 December 2025, an amendment to the Labor Code came into force, obliging employers to provide job applicants with, among others, information on the initial amount or range of remuneration, based on objective, neutral criteria, in particular, regarding gender. According to the regulations, this information must be provided: (i) in the job advertisement, (ii) before the job interview, or (iii) before the employment relationship is established.

In practice, therefore, employers are not obliged to include information about remuneration in job advertisements.

The Act also stipulates that employers are obliged to use gender-neutral job titles in job advertisements. The recruitment process must be non-discriminatory.

The period of civil law contracts is included in the period of employment

On 1 January 2026, an amendment to the Labor Code came into force, according to which, periods of employment that are not based on an employment relationship (including those prior to the entry into force of the Act) are included in one’s length of service. Therefore, contracts of mandate and contracts of service, among others, are included in the length of service. As a rule, periods during which a natural person was subject to pension and disability insurance are included in the length of service. Exceptionally, non-contributory periods may also be included in the length of service if the exemption from these contributions results from separate regulations.

The period of employment can be confirmed by a certificate issued by ZUS (the Social Insurance Institution) or, for persons who were not subject to social insurance, by presenting proof of employment (e.g. a contract of mandate).

Employees will only be able to have a higher period of employment determined from 1 May 2026 (except for employees of public finance sector entities who can already have a higher period of employment determined).

Further changes in the process of equalizing pay for women and men

The draft of a bill on strengthening the application of the right to equal pay for men and women for equal work or work of equal value is a continuation of the reform concerning equality and transparency of remuneration, initiated by the law that came into force on 24 December 2025.

The draft imposes key obligations on employers:

1. Every employer will be obliged to carry out an assessment of the value of work.
2. Furthermore, employers will be required to specify criteria for determining employee remuneration, remuneration levels, and increases in remuneration.
3. Each year, employers will also be required to inform employees of their right to request information about their individual pay levels and average pay levels broken down by gender for categories of employees performing the same work or work of equal value.
4. Employers with at least 100 employees will be required to prepare reports on the pay gap and submit them to the monitoring body in accordance with the deadlines specified in the Act.
5. Each year, employers preparing a pay gap report will also be required to provide information on the pay gap to employees and trade unions. If an unjustified pay gap of at least 5% based on gender is found, employers will be required to take corrective action within 6 months. If the pay gap is not objectively justified or eliminated within this period, employers will have to carry out a joint assessment of remuneration in consultation with trade unions or employee representatives.

The draft has been under review since November 2025.

Unfinished work on a new workplace definition of harassment and new statutory powers for the State Labor Inspectorate (PIP)

In 2025, work was underway on two bills that were important for employers and employees.

The first concerned simplifying the existing definition of workplace harassment and introducing rules developed by case law into the Labor Code. At the end of November, the Standing Committee of the Council of Ministers adopted the draft bill. Work on the draft bill is currently ongoing.

The second bill concerned granting the National Labor Inspectorate the power to quickly convert civil law contracts into employment contracts by means of an administrative decision. The bill was ultimately supposed to come into force on 1 January 2026 but, at the beginning of this year, it was announced that work on the bill would not be continued. The implementation of PIP reform is one of the conditions for Poland to receive full funding from the National Recovery Plan; therefore, further changes in this area cannot be ruled out.

Download: HR-Alert-Podsumowanie-roku-2025.pdf