Heat at work from 2027. What should a company calculate this winter?
From 11 January 2027, Polish labour law will for the first time set a temperature at which work must be stopped. For some companies, this means spending several thousand zlotys; for others, millions and years of investment. It is worth making decisions before spring.
Until now, heat at work in Poland was largely a matter of goodwill and a bottle of water. Piotr Ostrowski, chairman of the All-Poland Alliance of Trade Unions (OPZZ), said that apart from the obligation to provide drinks, that was “practically everything when it comes to such hard legal solutions”. The new regulation of the Ministry of Family, Labour and Social Policy changes that. Konfederacja Lewiatan, an employers’ organisation, warns that some plants will pay from several to more than a dozen million zlotys for adaptation.
We checked how much it costs to prepare different types of companies and which expenses are worth planning now rather than in July.
Two thresholds: first protective measures, then a work stoppage
The regulation introduces two levels of obligations. The first is thresholds after which the employer must protect people from heat: 28°C for indoor work and 25°C for heavy indoor work. The employer can choose technical and organisational measures: cooling, additional breaks, a shorter working day, or a different schedule that avoids the hottest hours.
The second level is the limits after which work must be stopped:
- 35°C indoors, for every type of work,
- 32°C outdoors, but only for heavy work,
- in both cases, what counts is the actual measurement, not the weather forecast.
Heavy work has a definition based on energy expenditure: above 1500 kcal per shift for men and above 1000 kcal for women. The rule on stopping work is not absolute, because it contains the reservation “unless technological reasons do not allow it”. Employers point out, however, that no one has defined those reasons.
Millions for a production hall, a few thousand for an office
The cost of adaptation depends above all on where and how work is performed. In a small office or service premises, a split air conditioner is usually enough. According to market prices reported by the industry portal GlobEnergia, one unit with installation by a certified company costs about PLN 3.5–5 thousand. A microbusiness faces no technical barrier here, only a question of budget and timing.
In a production hall, the scale is completely different. According to estimates from the industry service CoBouw, mechanical ventilation costs from PLN 40 to 150 per square metre, and full air conditioning from PLN 500 to 1500. We made an indicative calculation for a hall with an area of 2,000 m²: ventilation alone is PLN 80–300 thousand, air conditioning from PLN 1 to 3 million. With several halls, you quickly reach the amounts Lewiatan talks about.
On top of that comes the electricity bill. Lewiatan argues that the regulatory impact assessment clearly omitted the increased energy consumption for cooling. According to the organisation, in some plants it is simply impossible to add installations at all, because the building structure will not support additional equipment. Modernising the infrastructure may take from three to five years, which is longer than the time left until the first summer under the new rules.
The estimate of “from several to more than a dozen million zlotys” comes from Lewiatan’s preliminary analyses. The available materials do not include the methodology of these calculations or an example of a specific company that gave its own cost.
Organising work costs less than installing equipment
You cannot install air conditioning on a construction site. There, the tool is the calendar: earlier starts to shifts, breaks at midday, moving the heaviest work to cooler days. Such a plan mainly costs the manager’s time and possibly extra pay for work at different hours. Doing nothing, by contrast, means the risk of downtime in the middle of the season, when contract deadlines are at their tightest.
Plants with continuous production have it hardest. The line cannot be stopped because of heat, and downtime means delayed orders and reduced output. In warehouses, there is the added uncertainty of whether the limits cover loading zones and how drivers should be treated. Lewiatan also points out that it is unclear what happens to a process that began at a lower temperature when it gets hotter during the process.
Employers want changes, trade unions defend the rules
Konfederacja Lewiatan has asked Minister Agnieszka Dziemianowicz-Bąk to suspend the entry into force of the regulation. It is calling for renewed consultations, a reliable regulatory impact assessment, and solutions tailored to sectors instead of rigid limits.
We call for the entry into force of the regulation to be suspended, for consultations with entrepreneurs, experts and the social partners to be repeated, and for a reliable regulatory impact assessment to be prepared.
OPZZ assesses the same rules in the opposite way. Trade unionists have for years demanded a hard temperature limit, and the stricter version of the draft was described by Paweł Śmigielski from OPZZ as “a nod towards employees”. At the same time, he noted that “the devil is in the details”. In the materials available publicly, we found no response from the ministry to employers’ demands. Planning investments on the assumption that the rules will be postponed is therefore currently a gamble, not a strategy.
What to do before spring
In our view, the “cost and return” calculation looks best for companies that start now. In winter, installers have free slots, and estimates can be compared calmly. Lack of preparation also has a price today: an inspector from the National Labour Inspectorate (PIP) may order work dangerous to health to be stopped, and for violating occupational health and safety rules there is a fine from PLN 1,000 to 30,000. A difficult financial situation does not excuse poor working conditions. We suggest the following order:
- Map the workstations: indoors or outdoors, light work or heavy work.
- Measure what it was like in summer, if you have the data, or plan measurements from spring.
- Get cooling cost estimates where it is technically possible, and spread the investment over stages.
- Prepare summer schedules, breaks and remote work rules where possible.
- Record which processes you consider impossible to interrupt, and justify this technologically.
A small service company will solve the issue with a single purchase, but the air conditioning should be installed by a contractor with an F-gas certificate (authorisation to work with fluorinated gases). For installation without a certificate, the environmental protection inspectorate imposes administrative fines on contractors ranging from PLN 600 to 15,000. A large plant will not complete a full modernisation by summer 2027. By then, however, it can have schedules, measurements and an investment plan that shows the inspector the company is acting rather than waiting.