HR Radar 05/2026

As of 1 May, new seniority rules apply to private entities

On 1 January 2026, the law regarding the new rules for calculating length of service came into effect. For private entities, its provisions apply only as of 1 May 2026. This means that employers may only recalculate their employees’ length of service and include additional periods starting on that date. The new length of service may affect the duration of vacation time or notice periods.

Please note that employees can confirm their length of service with a certificate from ZUS. Those who were not subject to social insurance can provide proof of employment, e.g., a contract of mandate.

More information: Link to the law

New draft law on pay transparency

On 4 May 2026, a new version of the draft law on pay transparency was published which sets a new effective date for the law, i.e., 6 months from the publication of the law in the Official Journal of the Republic of Poland. Previously, the effective date was 7 June 2026. The draft also provides, among others, for the submission of information and applications in paper or electronic form, and extends the deadlines for providing information requested by, among others, the National Labor Inspectorate from 14 to 30 days. The rules for cooperation with trade unions have also been clarified.

Along with the draft law, a draft regulation was published aimed at facilitating the calculation of indicators for the pay gap report

More information: The proposed provisions

MOS 2.0 is now operational – digitization in immigration law

On 1 January 2026, an amendment to the Act on Foreigners entered into force, aimed at introducing new solutions regarding the legalization of foreigners’ residence. One of these is the implementation of the new MOS 2.0 system which allows applications for legal stay to be submitted exclusively online. The system has been operational since 27 April 2026.

Since 4 May 2026, it has also been possible to submit applications for a CUKR card (residence card for citizens with UKR status) which grants free access to the labor market, and allows Ukrainian citizens to conduct business activities.

More information: Link to the Act

The upcoming new powers of the National Labor Inspectorate are already leading to a surge in complaints

The law granting new powers to the National Labor Inspectorate will take effect on 8 July 2026. However, according to information provided by the State Labor Inspectorate, a significant number of complaints are already being received from employees hired under civil law contracts which currently cannot yet be processed under the new regulations – this will only be possible starting 8 July 2026. It can therefore be expected that once the regulations take effect, there will be another wave of complaints, and the State Labor Inspectorate will be responsible for reviewing them first, in accordance with the obligation to review complaints without undue delay, but no later than within one month.

More information: Link to the Act