On July 8, 2026, an amendment to the Act on the National Labour Inspectorate entered into force, introducing a new instrument: an individual interpretation issued by the Chief Labour Inspector.
The interpretation determines whether a legal relationship described in the application – existing or merely planned – constitutes an employment relationship within the meaning of Article 22 § 1 of the Polish Labour Code. A party that acts in accordance with the interpretation obtained cannot be subject to administrative or financial sanctions or penalties within the scope covered by it – in this respect, the interpretation is binding on the labour inspection authorities.
Given the new competence of the labour inspection authorities – introduced under the same amendment – to establish the existence of an employment relationship by way of an administrative decision, the individual interpretation may become an important risk management tool for businesses using B2B and civil-law contracts.
If you have any questions on the above, please contact @Mikołaj Machnio (mmachnio@cmwlegal.pl).