B2B contracts are a very popular form of cooperation in Poland. Recently, they have gained importance, especially in the IT, consulting, and marketing industries.
There's increasing talk of the so-called gig economy, a model of economic activity based on the performance of specific tasks or projects—often via digital platforms—instead of traditional full-time employment. This model of collaboration is primarily used by freelancers, also known as giggers, for whom choosing a flexible form of work is often a conscious alternative to an employment contract.
The amendment to the PIP regulations means that the assessment of the legality of B2B contracts is based on much stricter enforcement criteria. Is this the end of B2B contracts?
PIP reform. What changes?
As we have repeatedly emphasized, the most important procedural change is granting the National Labor Inspectorate the right to establish employment relationships through an administrative decision. Previously, the inspectorate, seeking to challenge a B2B contract, had to file a lawsuit in the labor court. The National Labor Inspectorate has gained access to automatic data exchange with the Social Insurance Institution (ZUS), National Revenue Administration (KAS), and Central Registration and Information on Business (CEIDG). This solution will significantly facilitate inspections and data exchange between institutions.
First interpretations
In August 2026, the National Labor Inspectorate published individual interpretations based on the new regulations in force from 8 July 2026. The interpretations show how the Chief Labor Inspector will assess civil law contracts and B2B contracts in the light of the Inspectorate's new competences.
What are the practical conclusions from the issued interpretations?
The published interpretations of the GIP show that:
- It is the practice that counts, not just the contract – the content of the contract does not exclude the risk of the cooperation being considered an employment relationship.
- The replacement must be real – the apparent possibility of replacement does not exclude the personal nature of the performance.
- Flexible working hours do not mean independence – autonomy is also important when performing tasks.
- Simple operational work can increase risk – this is especially true for physical, warehousing and production work.
Given the above, it should be noted that interpreting the PIP can mitigate risk. It allows for verification of the cooperation model before its implementation.
What does the PIP reform mean for entrepreneurs and the self-employed?
For the self-employed, reclassification may mean changes to tax and contribution settlement rules, even if the parties preferred B2B cooperation. For entrepreneurs, there is a risk of paying overdue social security contributions, personal income tax (PIT), and holiday pay.
Therefore, a reasonable solution is to apply to the National Labor Inspectorate (PIP) for a binding interpretation that will answer the questions that entrepreneurs are asking.
This article is for informational purposes only and does not constitute legal advice.
The law is current as of August 28, 2026.
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