The Act of 5 November 2025 on Collective Bargaining Agreements and Collective Agreements introduced changes to collective labor law. The new regulations not only address the procedure for concluding collective bargaining agreements but also influence the shape of remuneration regulations.
One of the significant changes is the possibility of specifying in the remuneration regulations the conditions of remuneration of persons managing the workplace on behalf of the employer.
Current legal status
In the previous legal status, the provisions of the Labour Code provided for the appropriate application of certain regulations concerning collective labour agreements to the remuneration regulations, including Article 241[26] § 2 of the Labour Code.
In practice, this meant that remuneration regulations could not specify the terms and conditions of remuneration for employees managing the workplace on behalf of the employer. This category includes:
- employees managing a workplace individually and their deputies,
- employees who are members of the collective body managing the workplace,
- chief accountants,
- persons managing the workplace on a basis other than an employment relationship.
Changes introduced by the Act of November 5, 2025.
The new regulations repealed Article 241[26] § 2 of the Labor Code. At the same time, a reference was introduced, according to which selected provisions of the Act on Collective Labor Agreements and Collective Agreements apply to the remuneration regulations.
Although this Act contains a provision analogous to the previously applicable ban in the Labour Code on specifying the terms of remuneration of persons managing the workplace on behalf of the employer in a collective labour agreement, it should be emphasised that the Labour Code does not refer to this provision in relation to remuneration regulations.
Summary
As a result, there is currently no provision prohibiting remuneration regulations from specifying the terms and conditions of remuneration for individuals managing the workplace on behalf of the employer. The amendment to the regulations introduced by the Act of November 5, 2025, has in practice opened the possibility of regulating the principles of remuneration for these individuals in remuneration regulations. This is a significant change compared to the previous legal framework, which excluded such a possibility.
This article is for informational purposes only and does not constitute legal advice.
Legal status as of March 6, 2026
Author / Editor of the series:
