Electronic medical certificates are one of the most significant changes to occupational medicine in Poland in 2026. Although the reform technically applies to physicians, it reshapes the everyday work of HR departments too. Instead of a paper certificate handed over by the employee, the certificate now goes straight into a national IT system. This article explains exactly when the new form takes effect, how the document flow changes between the physician, the employee and the employer, and what HR needs to do to avoid missing a deadline during the transition period.
What electronic medical certificates are and why this is changing
Electronic medical certificates in Poland were introduced by a regulation of the Minister of Health dated 20 March 2026, amending the 1996 regulation on occupational medical examinations, preventive healthcare for employees, and medical certificates issued for purposes provided for in the Polish Labour Code. The change is part of a broader digitalisation of medical documentation carried out under Poland's National Recovery Plan, and it marks the first step toward full electronic occupational medicine in the country.
The scope of the preventive examinations themselves (preliminary, periodic and follow-up) and how the occupational physician makes their assessment stay the same. Only the form in which the certificate is drawn up, transmitted and stored is changing.
Rollout timeline: three dates to know
The move to electronic medical certificates is not a single switch-over. The regulation phases it in across three stages:
- 17 April 2026 - the provisions allowing certificates to be issued electronically come into force. This opens a transition period in which the occupational physician may, but does not have to, issue the certificate electronically. Paper certificates (on the new template) remain fully valid.
- 18 July 2026 - occupational physicians gain the ability to issue individual health recommendations electronically too. This is a new tool the certificate did not previously provide for.
- 18 October 2026 - the six-month transition period ends. From this date, the electronic form becomes mandatory, and paper remains an exception, allowed only in specific situations (see below).
For companies that are only now starting to review their HR processes for this change, the second half of 2026 is a natural point to audit how certificates flow into the business.
How the new document flow works
After the examination, the occupational physician issues the certificate electronically. It goes automatically into the national Medical Information System, and from there onto the employee's Online Patient Account. An electronic certificate does not carry a traditional medical stamp; its authenticity is confirmed by the IT system itself rather than a physical signature or seal.
The regulation also introduces new certificate templates and clarifies the appeal procedure an employee can use if they want to challenge the certificate's content.
Who actually delivers the certificate to the employer?
Under Article 12 of the Act on Occupational Medicine Services, that obligation sits with the occupational medicine provider that carried out the examination. The provider transmits the certificate to the employer, on terms set out in the service agreement between the two. The mechanism works in a similar way to Poland's electronic sick leave system (e-ZLA): the document lands in the system, and the employer gets access to it automatically, without the employee acting as a go-between. In practice, this means employees no longer have to deliver or forward anything themselves, which is a real change from the old paper-based process.
What changes for employers: less medical data, not more
This is an easy point to miss when focusing only on the technical side: after the reform, employers receive only a fit-for-work or not-fit-for-work outcome, with no medical data, diagnoses or health recommendations, which stay strictly between the physician and the employee.
In practice, this means the reform does not increase the volume of sensitive data flowing through a company's HR systems. If anything, it draws a sharper line than before between what reaches HR (a simple fit/not-fit result) and the medical information that stays outside the employer's reach. This fits well with the data minimisation principle under GDPR, which we cover in more detail in Personnel files and GDPR in Poland.
When a paper certificate is still allowed
Paper does not disappear entirely, even after 18 October 2026. The regulation allows for it in three situations:
- The physician has no access to the IT system (for example, a technical outage).
- The employee explicitly requests it - an employee can ask for a printed version of the electronic certificate, signed by hand by the physician.
- Certain uniformed services - separate rules apply to selected professional groups.
Outside these exceptions, once the transition period ends, the electronic certificate becomes the standard, not an option.
What this means in practice for HR teams
The reform changes how the document reaches the company, but it does not change the employer's obligations under Article 229 of the Polish Labour Code: the employer still has to refer employees for examinations on time and cannot allow anyone to work without a valid certificate. We cover those obligations, referrals, costs and penalties in detail in Occupational medical examinations in Poland.
What actually changes in day-to-day HR work:
- Less paper handling - during the transition period, some certificates will be electronic and some still paper, which for a while means handling two formats in parallel.
- A different scope of data on the employer's side - HR no longer receives (and formally never should have received) medical data, only the fit-for-work or not-fit-for-work result.
- The deadline-tracking obligation stays the same - regardless of the certificate's form, the employer is still responsible for making sure no employee works with an expired certificate.
How Time Harmony helps you track examination deadlines
Whether the certificate is electronic or paper, the hardest part of this obligation stays the same: keeping track of expiry dates in real time across a larger team, different positions and different examination schedules. The Electronic Employee File module in Time Harmony lets you record preliminary, periodic and follow-up examinations in one place alongside the rest of an employee's HR data, and automatically reminds you of upcoming deadlines, regardless of the form in which the certificate itself was issued.
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