A year to sort out B2B. What the window to July 2027 gives you, and what it doesn't

The amendment to the act on the National Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) gave inspectors a new power and gave companies one gift. The gift lasts 12 months and ends in July 2027.

Everyone who writes about it calls it an “amnesty” (abolicja). It is a good word, but a bit of an overstatement. Amnesty suggests that the past disappears. Here only a small part of it does. It is worth knowing exactly which part before you plan a year of work around it.

This piece closes the series. In the first one we described how the process runs from order to decision. In the second, which five features of employment the inspector looks for. Here we deal with what to do with that knowledge, and by when.

What exactly the provision says

The whole provision is one sentence. It is worth reading in full, because every word of it is a condition:

Let's break it down.

Who it covers. Relationships that existed before 8 July 2026, that is before the act entered into force 1Art. 20. A new B2B contract (umowa B2B) signed today is not covered.

Which relationships. Those that have all the features of an employment relationship. In other words, those that are employment in every sense except the name.

Until when. 12 months from 8 July 2026, that is until 8 July 2027. Today about nine months are left.

How. Voluntarily, and in only one way: by signing an employment contract (umowa o pracę, often called etat). The act does not speak of improving the B2B contract or of changing the way you work together. It speaks of employment.

What it gives. Release from liability under Art. 281 § 1(1) of the Labour Code. That is the petty offence (wykroczenie) of concluding a civil-law contract where there should be an employment contract. Since 8 July it carries a fine at a higher level, and for a repeat offence one higher by half again 1Art. 3(1).

What the window does not give

Here is the part that is easy to miss. The provision releases you from one petty offence. It closes nothing else 22Infor.pl, “PIP może już zmieniać decyzją umowy cywilnoprawne w umowy o pracę. Co trzeba zrobić do lipca 2027 r.” (PIP can now convert civil-law contracts into employment contracts by decision. What to do by July 2027) (opens in a new tab). Conditions of the amnesty, referral of the act to the Constitutional Tribunal.33CGO Legal, “Nowe uprawnienia PIP. Zmiana B2B na umowę o pracę” (New powers of PIP. Changing B2B into an employment contract) (opens in a new tab). The amnesty does not cover employee claims or ZUS dues; follow-up review by the Constitutional Tribunal; selection for inspection.:

• ZUS contributions. ZUS, the Polish Social Insurance Institution, runs its own proceedings and can claim contributions for up to five years back 344KBIW, “PIP a umowy zlecenia, o dzieło i B2B: jak działać po 8 lipca 2026 r.” (PIP and contracts of mandate, for specific work and B2B: how to act after 8 July 2026) (opens in a new tab). Limitation of claims, ZUS, effects on personal income tax (PIT) and VAT, data exchange between PIP, ZUS and KAS.. Signing an employment contract does not settle the period in which there was none.
• The employee's claims. Holiday, overtime, other benefits for the B2B period. As a rule they become time-barred after three years 4.
• Taxes and VAT. Reclassification may require corrections on both sides, and the obligation to pay the VAT shown on an issued invoice remains 4.
• A finding of an employment relationship for the past. The district labour inspector can still bring a court action to establish an employment relationship for the earlier period 1Art. 33a(6).

So the window is worth as much as the fine for the petty offence. For many companies that is a lot. But it is not an amnesty for the past, and it is not worth presenting it that way to the board.

There is also a question the act does not settle directly: what “voluntarily” means. The safest reading is that the conversion must happen on the company's own initiative, not in carrying out an order the inspector issued during an inspection. That is our cautious interpretation, not settled practice. The practical conclusion is simple: the window works for those who move before an inspection.

Three paths for every contract

The provision means the window fits only one situation: a relationship that is employment and that you want to keep as employment. The other situations need a different decision. In practice there are three paths for every contract.

Path 1: employment. The relationship has all or almost all the features from the second piece, and the company wants to keep the person on the same terms. Here the window works directly. You sign an employment contract before July 2027 and you are not liable for the petty offence.

Path 2: genuine B2B. The relationship has some of the features, but it can be rebuilt so that it is truly a collaboration with a business. That means changing the contract and the practice: orders instead of instructions, payment for results, the option of a substitute, own tools. This path does not use Art. 16, because it does not end in employment. It does remove the risk for the future. That is why “tidying up the contract” on its own lowers the risk, but does not give the formal protection of Art. 16.

Path 3: ending the collaboration. Sometimes the best decision is to end the relationship. If so, do it before an inspection. Ending the contract after an inspection has started means the employment contract is treated as concluded on the date the inspection started, and the person is protected against dismissal 1Art. 34(2g) and (2h).

For completeness: there is also a path 0. Wait and hope that the inspection never comes or that the act falls. The President signed it while referring it to the Constitutional Tribunal (Trybunał Konstytucyjny) for follow-up review (kontrola następcza), but the provisions are in force 23. Companies are selected for inspection based on risk analysis, and PIP, ZUS and the National Revenue Administration (KAS) exchange data 34. Path 0 is possible, it is just hard to call it a plan.

Why nine months is less than it seems

On paper, nine months is a lot of time. In practice, moving someone from B2B to employment is not a change to one document.

Employment needs the consent of both sides. A contractor who earns on B2B today will take home less on an employment contract at the same cost to the company. Some people will say “no”. So the company has to decide whether it raises the budget, changes the model of collaboration or parts ways. Each of these decisions is a conversation, and conversations with dozens of people take weeks.

Then there is the order of things. You cannot decide well on a path for a contract you have not reviewed. You cannot review it without knowing what the practice looks like. And the practice is scattered across calendars, Slack and teams.

A sensible plan looks roughly like this:

1. Inventory. Every contract under which someone works for the company: B2B, contracts of mandate (umowa zlecenie), contracts for specific work (umowa o dzieło). Also those ended in the last year, because an inspection can cover them 1Art. 13.
2. Assessment. For each contract, the five features from the second piece, assessed on the basis of practice, not just the text of the contract.
3. Decision. Employment, genuine B2B or ending the collaboration. Long, exclusive, closely supervised relationships first.
4. Execution. Conversations, new contracts, a change in how work is done, training for managers.
5. Drift check. Once a quarter, a check that practice has not slipped back to the old ways. Because it usually does.

If you start in October, you will fit in with time to spare. If you start in May, you will be doing all of this under deadline pressure, and that is the worst moment for conversations about money.

How we do it at Kepta

This is exactly the kind of work we built Kepta for: lots of documents, repeatable assessment, and at the end a decision that needs a lawyer.

You start by uploading your contracts to the Register. The platform organises them and pulls out the clauses that matter for the assessment: working time and place, subordination, personal performance, exclusivity, how pay works. Our lawyers assess the risk of each contract and propose one of the three paths. We confirm the scope and the price before the work starts, not after the fact.

What we won't do: assess the practice from the contract alone. For that we need a conversation with you and your managers. The contract is half the picture, Monday is the other half.

See how it works in Kepta →

This piece describes the law in general terms and is not legal advice on a specific matter. The interpretation of “voluntarily” in Art. 16 is not yet settled. The law is stated as at 12 October 2026.