Unregistered business activity and the Social Insurance Institution (ZUS) in Poland – what companies should know

Unregistered business activity does not automatically remove the hiring company’s obligations towards the Polish Social Insurance Institution (ZUS). If the relationship corresponds to a mandate or service contract, the company may have to register the contractor and settle contributions. Neither a bill nor the absence of a written agreement proves that no social security obligation exists.

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When can unregistered business activity trigger ZUS contributions?

In decision DI/200000/43/1309/2025 of 16 January 2026, ZUS assessed a one-off carpet-cleaning service performed by a person carrying out unregistered business activity. No contract was signed, and the contractor issued a bill.

ZUS found that ordering, performing and paying for the service could constitute an implied service contract. The company could therefore become the contribution payer.

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What rules apply to unregistered activity in 2026?

From 2026, the revenue threshold is calculated quarterly. It amounts to PLN 10,813.50 per quarter, equal to 225% of the minimum wage. The individual must also have had no registered business during the previous 60 months.

No CEIDG registration means that the contractor is not insured as an entrepreneur. A different insurance title may still arise from a mandate or service contract.

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Does the absence of a written contract protect the company?

No. A service contract may be concluded orally or implicitly. For ZUS, the actual course of cooperation matters more than the name of the transaction or the absence of a signed document.

If a company orders a service, an individual performs it personally and receives remuneration, the company’s obligations may include:

• registering the contractor for the relevant insurance schemes,
• calculating and paying contributions by the statutory deadline,
• correctly reporting the remuneration in settlement documents.

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Does every transaction require ZUS registration?

The ZUS decision concerned an individual case, so each arrangement requires a separate assessment. The sale of a finished product may have different consequences from a service personally performed for a business.

Risk increases when the cooperation is recurring, the company determines the place, time and manner of work, or the contractor uses its tools and follows its instructions. The National Labour Inspectorate may then examine whether the arrangement has the characteristics of employment.

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What should a company verify before making payment?

The assessment should establish:

• whether the transaction concerns a product or a service,
• whether the work is performed personally and independently,
• whether the cooperation is one-off or recurring,
• who controls the conditions and manner of performance,
• whether the relationship resembles a mandate contract or employment,
• whether the documentation reflects the actual cooperation.

A declaration of unregistered activity and a bill are not sufficient. Review before payment reduces the risk of overdue contributions, corrections and challenges during an inspection.

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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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