Business Review Poland – January 2026

The start of 2026 brings Polish businesses a mix of tighter compliance expectations, administrative changes, and cost pressure. In practice, many organisations need to tidy up processes across HR & payroll, tax settlements, and documentation controls—especially where they rely on payroll outsourcing or external support for accounting and tax in Poland.

In this article, we present the most important events of the past month that shape the conditions for doing business in Poland.

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Pay transparency from December 2025 – new obligations for employers in Poland

From 24 December 2025, employers in Poland must provide job candidates with remuneration information (a fixed amount or a salary range) early in the recruitment process and ensure job ads use gender-neutral, non-discriminatory language. A further key change is the prohibition on asking candidates about previous pay, which requires updates to recruitment documentation, interview scripts and internal HR procedures. For businesses, this is not merely a legal update—it affects payroll data consistency and the readiness of payroll processing and HR workflows, particularly in larger organisations preparing for broader pay-transparency requirements expected in 2026.

Read the article for more details: Pay transparency Dec 2025 – employer obligations.

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EUDR Regulation postponed – what does the deferral mean for businesses?

The postponement of the EU Deforestation Regulation shifts due diligence obligations to 30 December 2026 for large and medium-sized companies, and to 30 June 2027 for micro and small enterprises. While this provides more time, it does not remove risk—companies will still need to evidence product origin and supply-chain transparency. For businesses operating in Poland, the additional year should be used to implement practical compliance processes (data, documentation, accountability) and to assess impacts on contracts and costs—rather than leaving preparations until the last moment.

Read the article for more details: EUDR Regulation postponed – what does it mean for businesses?.

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JPK_VAT in Poland’s National E-Invoicing System (KSeF) from 1 February 2026 – KSeF number, OFF/BFK/DI markings and correction rules

For VAT periods starting 1 February 2026, JPK_VAT records will reflect invoices issued via KSeF by requiring the KSeF invoice number, and by introducing OFF/BFK/DI markings for documents issued outside KSeF. This matters because it directly impacts VAT in Poland compliance and the accuracy of VAT registers—especially during the transition period when KSeF invoices and “outside-KSeF” documents will coexist. Importantly, the approach to corrections is pragmatic: as a rule, JPK_VAT does not need to be corrected solely to add the KSeF number, except in a narrow scenario involving offline24 after JPK submission. Implementation-wise, this is a reminder that KSeF is not only an invoicing topic—it also affects accounting workflows, document circulation and data quality controls.

Read the article for more details: New regulations for Poland’s E-Invoicing System (KSeF) for 2026.

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Important changes to obtaining a PESEL number in Poland for foreigners as of 1 January 2026

From 1 January 2026, certain foreigners—particularly from outside the EU/EEA/Switzerland—must appear in person to apply for a PESEL number, limiting the previous proxy-based approach. For companies with foreign board members, this can become a practical bottleneck: PESEL often enables smoother use of digital administration tools and timely signing and filing of key documents. As a result, businesses should plan these formalities in advance, especially when appointing board members and coordinating corporate updates connected with company registration in Poland and ongoing statutory filings.

Read the article for more details: Changes to obtaining a PESEL number in Poland for foreigners.

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Will Polish National Labour Inspectorate (PIP) convert civil law contracts into permanent employment contracts? Draft law – key information before 2026

The PIP reform proposal — although work on it was reportedly suspended in its current form as of 6 January 2026 — signals a clear compliance direction: the classification risk depends increasingly on how work is performed in practice, not merely on the label of the agreement. For employers, this is a prompt to review B2B and civil-law cooperation models, documentation and internal communication, particularly where misclassification could translate into payroll, social security and tax exposure. In many organisations, such reviews sit at the intersection of labour law compliance and payroll services in Poland, because operational reality must match contractual assumptions.

Read the article for more details: Will PIP reclassify civil contracts? Key changes in Poland by 2026.

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Social Insurance Institution (ZUS) contributions in Poland in 2026 – current bases, limits, and contribution amounts for entrepreneurs

In 2026, social security burdens increase mainly due to higher contribution bases (driven by projected average wage and minimum wage figures), and due to the higher minimum health insurance contribution from 1 February 2026. The annual pension/disability contribution cap (“30-times limit”) is PLN 282,600, which is relevant for high earners and cost planning. For entrepreneurs, this means factoring higher ZUS contributions in Poland into 2026 budgets and ensuring settlements are properly organised to avoid errors in calculations and reporting.

Read the article for more details: Social Insurance Institution (ZUS) contributions in Poland in 2026.

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Remote work from abroad and the new OECD update – key implications for employees and employers in Poland

The OECD’s updated Commentary (November 2025) places stronger emphasis on the “economic reality” of cross-border remote work and the potential consequences: permanent establishment (PE) risk for the employer and possible taxation of employment income where work is physically performed. For businesses in Poland, this means reviewing mobility policies and assessing the outcome under the relevant double taxation agreement (DTA) — with potential implications across CIT in Poland and PIT in Poland (and in some cases also VAT). A practical approach is essential: tracking the actual work location, role and business rationale for presence abroad, because these factors most often determine exposure.

Read the article for more details: Remote work from abroad: OECD 2025 guidance for Poland.

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January 2026 confirms that businesses in Poland must respond simultaneously to HR changes (pay transparency), the digitalisation of tax reporting (KSeF and JPK_VAT), and higher operating costs (ZUS). In practice, this increases the need for well-structured processes in HR & payroll, VAT compliance, and ongoing tax advisory in Poland. At the same time, workforce mobility raises the importance of managing tax risk (OECD guidance and DTAs). The most resilient organisations implement changes in a process-driven way: assigning clear responsibilities, maintaining strong data/document discipline, and updating policies before corrections, audits or disputes arise.

At getsix®, we support companies by providing a full range of services in accounting, taxes, HR and payroll, as well as company registrations, administrative support, reporting and international consulting both in Poland and abroad.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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