PIP sends companies letters about converting civil law contracts into employment contracts
The inspectorate cites data from ZUS and the tax administration, even though the algorithm for selecting companies for inspections is not due to launch until January 1, 2027. ZUS confirms that it is already providing PIP with data in response to its inquiries.
The National Labour Inspectorate (PIP) is sending entrepreneurs letters titled “Recommendation on optimizing forms of employment and voluntarily transforming civil law contracts into employment contracts”. The content of one of them was published on LinkedIn by legal counsel Dr. Katarzyna Kaleta, and the case was described by pulsHR.pl. According to the letter, the company was selected based on data from the databases of the Social Insurance Institution (ZUS) and the National Revenue Administration (KAS) as an entity that assigns work under civil law contracts.
The letter is neither a decision nor an order. Its purpose is to encourage the company to carry out a self-audit and voluntarily convert contracts where the work has the characteristics of an employment relationship. What matters is how the work is performed, not the name of the contract: subordination, as well as the place and time of work determined by the contracting party.
The pulsHR.pl website points out a discrepancy between the content of the letters and the inspectorate’s position. The inspectorate told the website that it checks civil law contracts on the basis of complaints. Chief Labour Inspector Janusz Krasoń had announced that until the end of the year PIP would respond only to reports from employees, and that it would start using risk assessment based on ZUS and KAS data from January 1, 2027.
ZUS confirms that, pursuant to Article 50(13a) of the Act on the Social Insurance System, it makes data on insured persons, contribution payers and specific-task contracts available to PIP. It does so in response to specific inquiries; so far there have been several dozen. Data exchange was expanded by regulations in force since July 8, 2026. In its own inspections, ZUS divides payers into risk categories: low, medium and high. Priority is given to companies registering more than 20 people for insurance.
According to Mateusz Rzemek, spokesperson for the Chief Labour Inspector (GIP), from July 8 to October 9, 2026, 1,457 complaints about the improper use of civil law contracts were submitted to the 16 regional labour inspectorates. Inspectors issued 661 orders to convert a contract into an employment contract, of which 597 had been complied with by October 9, while 10 had not. For the remaining cases, the compliance deadline had not yet passed.
For companies working with people under mandate contracts, specific-task contracts or B2B arrangements, a letter from PIP is a signal to review contracts before the algorithm is launched. If there are doubts about specific contracts, it is worth consulting a lawyer before making a decision.