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:

1. The physician has no access to the IT system (for example, a technical outage).
2. The employee explicitly requests it - an employee can ask for a printed version of the electronic certificate, signed by hand by the physician.
3. 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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On-demand leave in Poland is a feature of the Labour Code that has no direct equivalent in many other jurisdictions, which is exactly why it trips up international employers operating in Poland. Employees are entitled to take up to four days of on-demand leave per calendar year, requested on the same day they want to use it — but that right is not unconditional, and it is not an extra allowance on top of normal annual leave. This article explains how many days of on-demand leave apply, how employees must request it, when an employer can legally refuse, and the mistakes HR teams most often make when handling it.

1. What is on-demand leave in Poland, and how many days apply

On-demand leave is not a separate benefit — it is a portion of the employee's regular annual leave entitlement, distinguished only by how it is requested. Under Article 167² of the Labour Code, the employer is obliged to grant, at the employee's request and on the date the employee specifies, no more than 4 days of leave in each calendar year.

In practice, this means an employee entitled to 20 or 26 days of annual leave (depending on length of service) does not receive 4 additional days — those days are simply a portion of the same pool that can be used at short notice, without advance planning. The 4-day limit applies per calendar year regardless of how many employers the person has worked for during that year.

2. How employees must request on-demand leave

Unlike ordinary annual leave, which should follow a leave schedule or be agreed with the employer in advance, on-demand leave can be requested on the very day the employee wants to take it. Article 167² states that the employee must submit the request at the latest on the day the leave is due to start.

Poland's Supreme Court clarified this deadline in a ruling of 15 November 2006 (case I PK 128/06): the request should be submitted before the employee's scheduled start time for that day, unless the workplace regulations or established company practice allow a later notification. Employers operating in Poland should set out the accepted notification channel in the workplace regulations (e.g. through an HR system, by phone, or by email) — this reduces disputes and makes the requests easier to track.

3. Can an employer refuse on-demand leave

The employer's duty to grant on-demand leave is not absolute. In a ruling of 28 October 2009 (case II PK 123/09), the Supreme Court held that an employer may refuse on-demand leave where a specific, protection-worthy interest of the employer requires the employee's presence at work on the date requested. A refusal cannot be routine or arbitrary — it must be based on concrete, exceptional organisational circumstances.

It is equally important that the employee cannot start on-demand leave unilaterally before the employer approves it. Under a Supreme Court ruling of 16 September 2008 (case II PK 26/08), starting the absence before approval can be treated as unauthorised absence from work and, in serious cases, as a grave breach of basic employee duties — potentially justifying summary dismissal under Article 52 §1(1) of the Labour Code.

4. Common employer mistakes with on-demand leave

A handful of mistakes recur in how companies operating in Poland handle on-demand leave:

• Assuming unused on-demand days are simply lost at year end. In reality, they are not forfeited — they remain part of the general annual leave pool, which is why the outcome depends on whether the whole year's leave was used, not on the on-demand portion in isolation. For the specific September 30 carry-over deadline that applies to any unused annual leave, see our article on carry-over leave.
• Treating on-demand leave as an extra allowance on top of the 20 or 26-day entitlement, rather than as part of it.
• Requiring more advance notice than the law allows (e.g. "one day ahead" instead of same-day), without that requirement being set out in the workplace regulations.
• Issuing blanket, routine refusals without pointing to a specific, exceptional business need — such refusals have no basis in Supreme Court case law.
• Failing to document the reason for a refusal, which weakens the employer's position in a labour court dispute or a Labour Inspectorate (PIP) audit.

5. How Time Harmony supports on-demand leave management

Time Harmony lets HR teams handle on-demand leave in line with the Labour Code, without manually tracking limits or missing the same-day notification requirement.

The Electronic Leave Requests module handles annual leave, on-demand leave, care leave and unpaid leave as distinct request types, each following its own rules. The system prevents the on-demand leave limit from being exceeded, and managers approving a request see immediately how many days of each type the employee has left.

Through the My Time Harmony mobile app, an employee can submit an on-demand leave request the same day, from anywhere, and a manager can approve it with a single tap — matching the same-day notification requirement. Every request is automatically forwarded to HR, which simplifies record-keeping in the event of an audit.

For a broader look at what happens to any unused annual leave, including the September 30 deadline, see our article on carry-over leave, or on unused leave in general.

Summary

On-demand leave in Poland gives employees the right to take up to 4 days of annual leave per calendar year at short notice — requested at the latest on the day it starts. It is not an absolute right: an employer can refuse it in exceptional, justified circumstances, and the employee cannot begin it without approval. Setting out clear rules in the workplace regulations, and applying them consistently, helps HR teams avoid the most common mistakes with on-demand leave.

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Paid leave under a contract of mandate in Poland – the short answer

Paid leave under a contract of mandate in Poland is not a statutory right. If your organization engages contractors in Poland under a umowa zlecenie (contract of mandate), this civil law arrangement is governed by the Polish Civil Code, not the Polish Labour Code — and annual leave is strictly a Labour Code entitlement reserved for employees on an employment contract. For international HR teams used to statutory leave applying broadly across contract types, this distinction is one of the most common compliance traps when managing a Polish workforce.

What a contract of mandate actually is

A contract of mandate is a civil law service agreement, regulated under Articles 734–751 of the Polish Civil Code rather than the Labour Code. Under this framework, the contractor undertakes to perform a defined task diligently and in line with the agreement, and is entitled to remuneration and reimbursement of justified expenses — but the relationship does not create an employment relationship. This is exactly why the Civil Code does not attach the standard package of employee entitlements, including paid leave, to this type of contract.

Why contractors don't get automatic paid leave

Because a contract of mandate does not establish an employment relationship, none of the Labour Code's default employee protections apply automatically — no statutory annual leave, no on-demand leave, no paid overtime. If a contractor stops performing services (for example, to take time off) and the contract says nothing about it, they simply don't get paid for that period. Remuneration under a contract of mandate is, by default, tied to work actually performed, not to the passage of time.

There's also a compliance risk worth flagging to any HR or legal team drafting these contracts: using Labour Code terminology — words like "annual leave," "leave on demand," or "leave equivalent" — inside a contract of mandate can be read by the National Labour Inspectorate (PIP) as evidence that the parties actually intended an employment relationship. That exposes the company to reclassification risk under Article 22 §1 of the Labour Code. The safer wording is "a paid break in the performance of services," which keeps the civil law character of the agreement intact.

How companies can legally offer a paid break

Since paid leave under a contract of mandate in Poland isn't automatic, companies that still want to offer contractors time off with pay need to build it into the contract itself. A workable clause typically defines:

• the number of calendar days per year during which the contractor may pause services without losing pay,
• how remuneration for that period is calculated (for example, based on an average of recent months),
• how the contractor should notify the company before taking the break.

Without this kind of clause, every day the contractor doesn't work is simply unpaid — particularly under hourly-rate contracts, where hours not worked are recorded as zero.

Does the 2026 employment tenure reform change anything?

Starting 1 January 2026 for the public sector, and 1 May 2026 for private employers, Poland's amended Labour Code (enacted 26 September 2025, signed 15 October 2025) allows periods worked under a contract of mandate to count toward an employee's overall employment tenure — provided those periods were subject to social security contributions and are confirmed with a ZUS certificate.

This is a meaningful change for anyone who spent years working on mandate contracts before eventually moving to an employment contract, since it can push them past the 10-year tenure threshold that unlocks 26 days of annual leave instead of 20. It's important, though, to keep two things separate: the reform affects leave entitlement after someone becomes an employee under an employment contract. It does not create a right to paid leave while someone is still working exclusively under a contract of mandate. We cover the documentation side of this reform in more detail in Changes to employment tenure in Poland from 2026 – what employers must know.

The minimum hourly rate isn't a substitute for leave

Since 1 January 2026, the statutory minimum hourly rate for contracts of mandate in Poland is PLN 31.40 gross, set by the Council of Ministers' regulation of 11 September 2025 (Journal of Laws 2025, item 1242). This guarantee protects pay for hours actually worked — it has nothing to do with leave. If a contractor isn't performing services and the contract doesn't include a paid-break clause, there's simply no minimum rate to apply for that time, because there are no hours to pay for. This makes accurate time recording essential for contracts settled on an hourly basis, both to demonstrate compliance with the minimum rate and to correctly account for any agreed paid break.

How Time Harmony helps HR teams track contractor time

Time Harmony lets you record time worked under contracts of mandate alongside standard employment contracts, whether settlement is hourly or lump-sum. That gives HR and finance teams a single source of data to:

• demonstrate compliance with the statutory minimum hourly rate,
• generate cost reports for a specific contract or project,
• properly document any agreed paid break in the contract, without mislabeling it as statutory "leave" in the system.

The Activity Records module also gives the possibility of registering the time of activities performed by a given employee on a contract of mandate, which greatly facilitates the process of accepting the commissioned work. If your organization also needs a simple way to log hours per contract for cost settlement, our related article on work hours tracking for contractors walks through how that works in practice.

See the Activity and Productivity module →

Summary

Paid leave under a contract of mandate in Poland starts from a default of "no" — contractors don't get statutory annual leave, and the 2026 tenure reform doesn't change that while someone remains exclusively on a mandate contract. Companies that want to offer paid time off can do so through a precise contractual clause, kept clearly separate from Labour Code leave terminology. For HR teams managing a mixed workforce of employees and contractors in Poland, accurate, contract-level time tracking is what makes both compliance and cost control possible — which is exactly what Time Harmony is built for.

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Heat waves with temperatures reaching 40°C are becoming the new normal, and not just in southern Europe. They are increasingly common in central Europe too — a region that, until recently, was known for its temperate climate. As a result, governments across the region are being forced to introduce rules protecting workers from the effects of extreme heat, and employers have to stay on top of these changes and implement them as they land. Poland is no exception: heat regulations at work in Poland are becoming a genuine compliance topic for HR teams managing Polish operations, not just a seasonal inconvenience. The stricter temperature limits described below only take effect from January 2027, but it's worth understanding now what already applies, and what to prepare for.

What employers must do about heat today

Under Article 207 § 1 of the Polish Labor Code, employers have a general duty to ensure safe and hygienic working conditions — heat included. In practice, for now, this means:

• providing free, cold drinks once the indoor temperature exceeds 28°C, or 25°C for outdoor work (under the existing general health and safety at work regulation),
• responding to signs that employees are unwell and allowing them to rest,
• there is currently no statutory temperature threshold that automatically forces a stoppage of work.

In other words, during the summer of 2026, decisions about shortening the working day, adding breaks, or moving tasks to cooler hours largely rest with the employer — but documenting those decisions properly matters just as much as making them, especially in the event of a National Labour Inspectorate (PIP) inspection.

What the new regulation changes, and from when

On 9 July 2026, Poland's Minister of Family, Labour and Social Policy signed an amendment to the general health and safety at work regulation — the first in Polish labor law history to introduce maximum working temperatures. It was published on 10 July 2026 (Dz.U. 2026 item 927) and enters into force six months later, on 11 January 2027.

The new rules, once in force, set out two separate thresholds:

• 28°C indoors for standard/office-type work, 25°C indoors for physically demanding work, and 25°C outdoors for any type of work — above these levels, employers must apply technical solutions (e.g. air conditioning) or organizational ones (extra breaks, shortened hours, adjusted schedules), agreed after consultation with employees or their representatives,
• 35°C indoors (for any type of work) and 32°C outdoors (for physically demanding work only) — only above this higher threshold does work have to actually stop, with employees keeping their full pay for that time.

This distinction matters: 28°C/25°C is the threshold for an organizational response, while 35°C/32°C is the threshold at which work genuinely has to be interrupted. It's also worth knowing the new rules don't apply across the board without exception — §30a(8) exempts uniformed services, military personnel, and staff at childcare facilities for children under 3 (nurseries) from the maximum-temperature duty.

How to prepare your organization before the new rules apply

The six-month vacatio legis is a good window to get processes in order before they become a legal requirement rather than scrambling once they do. Worth doing now:

• set an internal procedure for who decides on an extra break or a shortened day during a heat wave, and how that decision is communicated to the team,
• make sure every such decision is recorded in the time and attendance system, not just agreed verbally — this protects the company during a PIP inspection, which tends to happen more often during heat waves,
• check whether your time-tracking system can flexibly record events like an extra break or an early finish without manual recalculation of hours.

Recording heat-related absences correctly

Whether it's an extra break during a heat wave or an employee sent home early for the day, the event should be recorded in the time and attendance system — otherwise it shows up at month-end as an unexplained time deficit.

In Time Harmony, this is handled through absences: users can define any custom absence type, for example "BHP-related work stoppage/leave," and use it to mark an employee being sent home early because of heat. This gives you:

• a complete, compliant record of when and why working hours were shortened or stopped,
• immediate visibility in the records that the event doesn't create a deficit to be made up,
• data that's ready for a PIP inspection without reconstructing the situation from a shift supervisor's memory.

The Polish Labor Code and organizing work during a heat wave

The Polish Labor Code doesn't yet directly regulate work in high temperatures, but a few of its provisions are directly relevant when organizing work during a heat wave:

• Article 207 § 1 — the general duty to provide safe and hygienic working conditions, which is also the basis for responding to heat,
• Article 134 — the right to a 15-minute break counted as working time once the working day reaches at least 6 hours — a natural point at which to schedule an additional "cooling" break,
• the general health and safety at work regulation, which covers appropriate conditions in workplace premises.

Any change to the standard break schedule should stay consistent with the company's work regulations or collective agreement — and any such change is best reflected in the time and attendance system right away.

Heat regulations at work in Poland - summary

Heat regulations at work in Poland currently come down to one key distinction: what already applies today, and what only takes effect from January 2027. Even so, it's worth building an internal procedure for responding to high temperatures now, and consistently recording every extra break or shortened working day in your time and attendance system — the best protection for employers and employees alike.

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A new draft bill in the Polish parliament would change pregnancy sick pay in Poland by shifting it from employers to the Social Insurance Institution (ZUS) from day one of sick leave. The proposal, filed by MPs from the Polska 2050 party, passed its first reading in the Sejm on 9 June 2026 and is now being reviewed by a parliamentary committee. It is not yet law, and — importantly for international HR teams — it would apply only under Polish law, affecting only employers and employees covered by the Polish Labour Code and Polish social insurance system.

How pregnancy sick pay in Poland works today

Under current Polish law, an employer pays sick pay for the first 33 days of an employee's incapacity for work in a calendar year (14 days for employees over 50). From day 34 onward, ZUS takes over and pays a sickness benefit from the Social Insurance Fund (FUS).

During pregnancy, the split between employer and ZUS is the same as for any other employee — only the amount differs. Under the Polish Labour Code, incapacity for work during pregnancy is already paid at 100% of the assessment basis, whether the payer is the employer or ZUS. The maximum period for receiving this benefit during pregnancy is 270 days.

So the issue the new bill addresses isn't the amount of the benefit — it's who pays for the first weeks of leave, and how much of a burden that is for smaller employers.

What the draft bill on pregnancy sick pay proposes

The bill (Sejm druk no. 2416) would amend the Labour Code and the Act on cash benefits from social insurance in case of sickness and maternity so that pregnancy sick pay in Poland is paid entirely by ZUS from the Social Insurance Fund, from the very first day of incapacity for work — removing the employer's share of the first 33 days entirely.

Key points of the proposal:

• Employers would no longer bear the cost of the first 33 days of sick leave for a pregnant employee.
• The benefit would remain 100% of the assessment basis — nothing changes financially for the employee.
• The maximum benefit period (270 days) would stay the same.
• Rules for issuing electronic sick notes (e-ZLA) would not change.

The bill was submitted by MPs from Polska 2050. Its first reading took place during a Sejm sitting on 9 June 2026, after which it was referred to the Special Committee on Amendments to Codifications for further work. Before it could take effect, it still needs to go through committee work, a second and third reading in the Sejm, a Senate vote, and the President's signature — so there is currently no confirmed date for entry into force.

Why lawmakers say the change would help women in Poland's labour market

The bill's authors argue that the current system may discourage some employers — particularly smaller companies — from hiring young women on employment contracts, since the employer has to both fund sick pay and arrange cover for the absence.

Shifting this cost to the Social Insurance Fund is intended, according to the bill's sponsors, to reduce the risk of discrimination against women in recruitment and to encourage employment contracts over civil-law contracts. The proposal also ties into a broader policy discussion in Poland about demographic policy and family support.

What the reform would cost, and open questions

The change would mean an additional cost for the Social Insurance Fund. Based on estimates cited in Polish media, the additional annual cost to the fund would be roughly PLN 1.5 billion — part of which simply shifts existing employer costs onto the social insurance system rather than creating new spending from scratch.

Experts have flagged a risk of abuse — for example, employers or employees arranging a short period of high-salary employment shortly before sick leave begins, to inflate the benefit's assessment basis. Additional safeguards against this kind of practice may be added as the bill moves through further committee work.

How to prepare your business for changes to pregnancy sick pay in Poland

Even if the bill changes further as it moves through the Sejm, the fact that it is now part of the public debate is a good reason to review how your company handles pregnancy-related and general sickness absence — regardless of who ends up paying for which stage of the leave, employers still need to record it accurately, settle it correctly, and plan cover.

This is where the Time Harmony electronic leave requests module helps: it lets you log sick leave alongside every other type of absence, track limits and history, and gives managers real-time visibility into how many people on their team are currently on sick leave. That makes planning cover and organizing work simpler, no matter how the rules on funding sickness benefits are ultimately shaped.

Changes to sick leave rules in Poland have come up regularly this year — for what already took effect in April 2026 (including new ZUS inspection rules and permitted activities during sick leave), see our article New sick leave rules in Poland from April 13, 2026: What has changed?.

Summary

The bill introducing pregnancy sick pay in Poland funded by ZUS from day one is, for now, a legislative proposal rather than law — it is still at an early stage in the Sejm. If passed, the cost of the first 33 days of a pregnant employee's sick leave would shift to ZUS, easing the burden on employers and, according to its sponsors, reducing hesitation around hiring young women. Until then, it's worth following the bill's progress and — regardless of the outcome — making sure pregnancy and sickness absences are recorded efficiently and in line with Polish labour law.