A foreign employer operating in Poland without reviewing its employment contracts, wypowiedzenie (dismissal notice) protocols, and social security registration procedures before mid-2025 faces meaningful legal exposure. Polish labour legislation has been amended, and the changes touch on multiple obligations that international companies routinely underestimate. Failure to comply within the applicable windows can trigger administrative penalties, back-payment obligations, and contested termination procedures before Polish labour courts.
Poland's updated employment regulations introduce stricter requirements for employment contract documentation, revised dismissal notice periods, and expanded social security obligations for employees hired through foreign entities. The changes took effect progressively from early 2025, with full compliance expected across all covered employer categories by mid-2025. International companies with even a single employee based in Poland fall within scope.
This alert explains what changed, which employers are affected, and the steps that require immediate attention. Businesses that have already engaged a specialist in employment law in Poland should review open engagements against the new requirements without delay.
What changed – the regulatory developments and their scope
Poland's employment legislation has been amended in three areas relevant to foreign employers.
Employment contract documentation. Under Polish employment legislation, every employment contract must now specify a broader set of conditions at the time of signing. These include detailed working-time arrangements, the applicable collective agreement where one exists, and the specific location or locations where work is to be performed. Contracts that omit these elements are not automatically void. However, employees may use incomplete documentation to challenge terms or claim additional entitlements. International employers who use standardised contracts drafted outside Poland are at particular risk of non-compliance here.
Dismissal notice periods. Revised rules under Polish labour law extend the wypowiedzenie (dismissal notice) period in certain circumstances. The length of the notice period has long depended on seniority. The amendments clarify how seniority is calculated when an employee has worked for affiliated entities, including foreign parent companies. An employee who previously worked for a group entity abroad may now count that service toward their Polish seniority threshold. This can shift an expected one-month notice obligation into a three-month one. Employers who proceed with termination procedure on the basis of outdated calculations risk claims for wrongful dismissal.
Social security and posting obligations. Amendments to social security rules affect foreign employers who post workers to Poland or hire Polish residents directly. The registration timelines have been tightened. Employers must now register employees with Polish social security authorities within a shorter window of commencing work. Delays in registration expose both the employer and the worker to gaps in coverage and to administrative penalties assessed by the Zakład Ubezpieczeń Społecznych (Social Insurance Institution of Poland, ZUS).
Companies with operations that span both Polish and EU regulatory requirements should also note that Poland has continued to transpose EU directives on transparent and predictable working conditions. The domestic implementing legislation extends protections that go beyond the minimum standard of the original directive in several respects.
Who is affected and the compliance deadline
The updated rules apply to a wide range of employer types. The following categories are squarely within scope.
- Foreign companies employing Polish residents under direct employment contracts, including remote workers engaged since 2020.
- Foreign entities posting workers to Poland for assignments exceeding a short-term threshold, regardless of whether a Polish subsidiary exists.
- Non-EU employers operating in Poland through a branch, representative office, or contractual arrangement with a local service provider.
- Foreign group companies whose Polish affiliates act as co-employers or whose employees transfer between group entities.
- Employers covered by a collective agreement that has been updated to reflect the new legislative minimums.
The compliance deadline for full alignment with the updated employment contract and social security rules is tied to the date each employee's current contract was last amended or renewed. Practically, most foreign employers operating under contracts drafted before 2024 must complete a review and issue updated documentation no later than the end of the first quarter following the effective date of the relevant amendment. For postings and social security registrations, the window is shorter – registration must occur before the employee begins work, not within days afterward.
Employers in sectors subject to sector-specific collective agreements face an additional layer. Where a collective agreement has been renegotiated to incorporate the new legislative standards, the contractual provisions override the statutory minimum. Employers bound by such agreements must track both the statutory position and the agreement text.
For a preliminary review of your workforce arrangements in Poland, email us at info@ferrazwhitmore.com.
Immediate actions for international companies
The following steps address the highest-risk areas first.
- Audit existing employment contracts. Identify every employee based in Poland. Check whether each contract contains the now-mandatory disclosure elements – working-time arrangements, applicable collective agreement reference, and place of work. Flag contracts drafted under a foreign governing law that may not meet Polish mandatory standards.
- Recalculate seniority for employees with cross-border group history. Where an employee previously worked for a related entity outside Poland, recalculate the applicable dismissal notice period under the revised seniority rules. Update internal HR records and inform affected employees in writing.
- Verify social security registration timelines. Confirm that every current employee in Poland is registered with ZUS from the correct date. Where gaps exist, consult counsel on voluntary correction procedures, which carry lower penalties than those triggered by a ZUS audit.
- Check collective agreement applicability. Determine whether any applicable collective agreement has been renegotiated since 2024. If so, obtain the updated text and compare its terms against current contracts. Where the agreement sets a higher standard than the statute, the agreement governs.
- Review posting documentation. For employees posted to Poland, verify that the posting notice and social security coordination documentation reflect the current rules. Postings that pre-date the amendments may need a supplemental notification to Polish labour authorities.
Companies managing corporate structuring in parallel with employment compliance should also consider the interaction with corporate law obligations in Poland, particularly where directors or senior executives hold dual roles across group entities. The classification of such individuals as employees or officers affects both the applicable employment law protections and the social security contribution base.
The compliance timeline is short and the administrative penalties for non-compliance are assessed per employee, not per employer. A company with a modest Polish workforce can accumulate a material aggregate liability quickly. Engaging a law firm in Poland with cross-border employment experience is the most effective way to contain that risk before any regulatory contact occurs. To discuss how these changes apply to your specific workforce in Poland, contact us at info@ferrazwhitmore.com.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our employment law practice supports foreign employers operating in Poland and across the EU with employment contract review, dismissal notice compliance, social security registration, and collective agreement analysis. The firm combines Portuguese civil law expertise with English common law tradition to deliver clear, actionable guidance for international businesses managing cross-border workforces. Our attorneys have advised on employment matters across both civil law and common law systems, and the firm maintains close working relationships with local counsel in Warsaw and other Polish cities. Engaging a lawyer in Poland with cross-border expertise from this firm means your compliance review covers both the local statutory position and the EU dimension simultaneously. To receive a tailored assessment of your employment obligations in Poland, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.