Poland has tightened control over employment contracts: the Ryanair story and new risks for Ukrainians

In Poland, control over how companies formalize workers has noticeably increased. The State Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) has received new powers and can now seek to recognize as employment those relations that are formally registered as B2B, umowa zlecenia or umowa o dzieło.

For those working in Poland this is an important change: the name of the contract is no longer the main argument. Inspectors look primarily at how a person actually works — whether they perform the work personally, obey a manager, are obliged to follow a set schedule and work at a specified place.

What has changed since July

Since 8 July 2026, the Polish labour inspectorate has been given the right to initiate the conversion of civil-law relations into employment without a mandatory prior court process.

However, an inspector cannot simply “rewrite” a contract during an inspection. First, the employer is given an order: to formalize an employment contract or change the actual working conditions.

If the employer does not do this, the case may be transferred to a district labour inspector. He has the right to issue an administrative decision on the existence of employment relations or refer the dispute to court.

The decision may specify the parties to the contract, the date work began, the position, place of work, working hours and salary.

The employer and employee have the right to appeal the decision in a labour disputes court within a month.

Who may be affected

The key question is not what is written in the contract, but how the person actually works.

The risk of reclassification is higher if the worker:

• is obliged to perform the work personally;
• works according to a schedule set by the company;
• obeys the instructions of a manager;
• works at a place determined by the client;
• receives regular payment for performing ongoing duties.

This applies not only to B2B. The same rules apply to umowa zlecenia and umowa o dzieło, if the actual relations resemble ordinary employment.

The inspectorate is already checking large companies

One of the first high-profile tests of the new system were inspections in the aviation industry.

Since July, the Warsaw labour inspectorate has been checking LOT and the companies of the LOT Crew and LOT Cabin Crew group. The focus is on B2B contracts with people who actually work within the group.

Separately, the trade union Związkowa Alternatywa asked PIP to check Ryanair Sun — the Polish company of the Ryanair group operating under the Buzz brand.

The union claims that some pilots and cabin crew are engaged through B2B, although their working conditions show signs of ordinary employment relations.

Employee’s desire to stay on B2B will not always help

Previously, one of the arguments in favour of keeping B2B could be the employee’s own wish.

Now this is not a decisive factor. The Ministry of Labour explains: the will of the parties is taken into account only if it is not used to circumvent the law.

That means an employee and a company cannot legalize actual employment relations just because both find it more advantageous to call them B2B.

What an employee receives after moving to staff

An employment contract gives more protection: paid leave, sick pay, working time rules and stronger protection against dismissal.

But there is a flip side. For some employees, after moving from B2B to staff the net amount they receive may decrease.

The reason is taxes and social contributions. The self-employed often use preferential ZUS schemes or ryczałt tax, whereas salary under an employment contract is taxed under different rules.

Meanwhile, the inspectorate’s administrative decision applies to the future. To demand payment of overtime, holiday pay or other payments for previous years, an employee will have to go to court.

Fines for employers have increased

For businesses the risks have also risen.

The fine for using a civil-law contract where employment relations should exist is now from 2,000 to 60,000 zlotys.

The maximum fine an inspector can issue directly during an inspection has increased from 2,000 to 5,000 zlotys.

However, for old contracts there is a transitional period: an employer may voluntarily register people as staff by 8 July 2027 and avoid some sanctions.

Complaints have noticeably increased

The new powers have already led to a rise in appeals to the inspectorate.

According to PIP data, from 8 July to 13 August alone 690 complaints and applications were filed about substitution of employment contracts with civil-law ones. Since the beginning of the year there were 1,794 such appeals against 619 a year earlier.

Inspectors have started more than 100 inspections and issued 121 written orders. At that time not a single administrative decision on reclassification had yet been issued: some employers changed contracts on their own before the procedure was completed.

Complaints come not only from aviation or IT, but also from trade, services, manufacturing, security, catering, healthcare and platform work.

Why this is especially important for Ukrainians

Ukrainians make up a noticeable part of the Polish self-employment market.

According to the Polish Economic Institute, in 2022–2025 Ukrainian citizens registered 109.1 thousand individual entrepreneurs JDG in Poland. In 2025 alone Ukrainians opened 31.4 thousand such businesses — about 12% of all new JDG in the country.

This does not mean that every Ukrainian JDG is a hidden employment contract.

But a scheme where a person permanently works only for one client, follows their schedule and instructions and effectively performs the functions of an ordinary employee is exactly what the inspectorate focuses on.

For Ukrainians, migration status is also important. People with UKR status may move from B2B to staff without a separate work permit: the employer only needs to submit the required notification through praca.gov.pl.

For Ukrainians with other grounds of residence the situation may be more complicated — especially if the residence permit was issued precisely for running a business.

What an employee should check

The main question now is simple: do you really work as an independent contractor — or are you only formally considered one.

If a company determines your schedule, place of work, duties and manner of performing them, and you personally and permanently work for one client, such a contract may attract the inspectorate’s interest regardless of whether it is labelled B2B, zlecenie or dzieło.

The Polish reform in essence shifts attention from the name of the contract to the actual working conditions. Therefore, the changes may affect a much wider circle of workers than just B2B entrepreneurs.