The Social Insurance Institution (ZUS) is developing an advanced analytical algorithm aimed at identifying companies that may engage in so-called bogus self-employment. The new tool is intended to support the National Labor Inspectorate in detecting cases in which B2B ( business-to-business ) contracts effectively replace an employment relationship.
The algorithm will analyze a wide range of data collected by the Social Insurance Institution (ZUS), including information on contribution payers and patterns of cooperation with sole proprietors. Although the technical details remain unknown, experts point to key "red flags," such as issuing a single invoice per month to a single contractor, providing services to a former employer immediately after transitioning to B2B, and the permanence and subordination inherent in an employment contract.
The new system is intended to fundamentally change the way inspections are conducted. Instead of random or reactive visits (often initiated by complaints), the National Labor Inspectorate (PIP) will receive lists of entities with the highest probability of violations from the Social Insurance Institution (ZUS). This will allow inspectors to access companies with prior risk analysis and specific data, significantly increasing the effectiveness of inspections.
For entrepreneurs, this means a significant increase in the risk of B2B relationships being challenged. Business models based on mass self-employment will come under particular scrutiny, and
"aggressive" labor cost optimization will become significantly more risky. Entrepreneurs should now analyze both the content of contracts and the actual way they work with contractors to mitigate potential financial and legal consequences.
This article is for informational purposes only and does not constitute legal advice.
The law is current as of December 16, 2025.
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