A Budapest-based logistics group had been operating a Polish subsidiary for nearly two years before its HR director noticed a problem. Several employees hired locally had never been registered with the Social Insurance Institution (ZUS). One non-EU national was working without a valid work permit. And the company had no whistleblower reporting channel – a legal requirement since the Polish Whistleblower Protection Act came into force. The exposure was real and growing.

Hungarian companies operating in Poland must comply with Polish employment law in full, regardless of where the parent entity is incorporated. This means proper registration with the Social Insurance Institution (ZUS), valid work authorisation for non-EU nationals, and – since mid-2024 – a functioning internal whistleblower reporting channel. Failure to meet these obligations triggers personal liability for management, fines of up to PLN 30,000 per violation, and potential criminal exposure for individuals responsible for the breach.

This case study traces how we helped the Hungarian client identify its compliance gaps, remediate each one, and build a structure that will hold up to inspection by the National Labour Inspectorate (PIP). The lessons apply to any Hungarian company with a Polish presence – whether a subsidiary, branch, or posted-worker arrangement.

What was the background to this matter?

The client – a mid-size logistics operator headquartered in Budapest – had expanded into Poland by acquiring a local freight-forwarding company in early 2024. The acquisition moved quickly. Integration of HR processes did not. By the time the group's compliance officer flagged the issues, the Polish entity employed 34 people. Three were third-country nationals. None of the three held current work permits. ZUS registration for six employees had been filed late or was missing entirely.

The whistleblower channel gap was the most immediately pressing. Polish law required companies with 50 or more employees to establish an internal reporting procedure by 25 September 2024. The Polish subsidiary had 34 staff – below that threshold. However, the group's Polish headcount, when aggregated across related entities, exceeded 50. Under the Act, that aggregate figure is the relevant measure. The client had not appreciated this point at all. (This is, in our experience, the single most common misconception among foreign groups entering Poland.)

The National Labour Inspectorate (PIP) has authority to audit compliance with both work-permit rules and whistleblower obligations. A PIP inspection – triggered by an anonymous tip from a former employee – was already scheduled. We had roughly three weeks to remediate.

What compliance gaps required immediate action?

Three categories of breach required parallel remediation. Each carried a distinct legal consequence and a different remediation timeline. Speed mattered: the PIP inspection date was fixed, and incomplete remediation at the time of inspection would not be treated as good-faith effort.

First, the work-permit failures. Under Polish immigration and employment legislation, employing a non-EU national without a valid work permit exposes the employer to a fine of up to PLN 30,000 per worker. The three affected employees were Ukrainian nationals. Two were eligible for a simplified work notification procedure available to citizens of Ukraine, Belarus, Russia, Moldova, Georgia, and Armenia. The third required a full Type A work permit, which carries a processing time of up to 60 days at the relevant Voivodeship Office (Urząd Wojewódzki). We filed the notifications and the Type A application within 48 hours of instruction.

Second, ZUS registration arrears. The Social Insurance Institution (ZUS) imposes late-registration surcharges and can assess unpaid contributions going back three years. We prepared corrective ZUS declarations for all six affected employees and coordinated with the client's Polish accountant to calculate arrears. The total liability came to just over PLN 18,000 – manageable, but only because the gap was caught before a full ZUS audit.

Third, the whistleblower channel. We drafted an internal reporting procedure, appointed a compliance officer as the designated recipient, and arranged a 14-day employee consultation period – the minimum required under the Act before the procedure can take effect. The channel was operational before the PIP inspection date.

We also reviewed the employment contracts of all 34 staff against the requirements of the Polish Labour Code (Kodeks pracy). Four contracts lacked mandatory provisions on working-time norms. Amended annexes were signed within one week.

How did the PIP inspection proceed?

We secured a reversal of a potential PLN 90,000 penalty exposure for this logistics client in Mazowieckie (winter 2026). The PIP inspector arrived on the scheduled date and reviewed documentation for all 34 employees. Because remediation had been completed before inspection, the inspector found no ongoing violations. The work-permit notifications and the Type A application were on file. ZUS corrections had been acknowledged. The whistleblower procedure was posted on the company intranet and signed by management.

The inspector issued a post-inspection protocol noting the historical ZUS registration delays. No fine was imposed. The protocol required the company to submit a written remediation confirmation within 30 days – a standard procedural step that we prepared on the client's behalf. (Had the inspection found live violations, the fine exposure for the three permit-less workers alone would have reached PLN 90,000.)

One lesson stands out here. The PIP inspector specifically asked whether the whistleblower channel covered anonymous reports. Our procedure did. A channel that accepts only identified reports does not satisfy the Act's requirements. Foreign HR teams – accustomed to Hungarian law, which has different standards – often assume that a named-reporter-only system is sufficient. It is not under Polish rules.

For context on how cross-border employment structures interact with Polish insolvency risk, see our analysis of cross-border insolvency involving Poland and Hungary.

What lessons apply to other Hungarian companies in Poland?

This matter illustrates four transferable points for any Hungarian group with Polish operations. The compliance calendar in Poland is dense. Missing one deadline – even by a few days – can convert a technical breach into a fine or, in the case of work permits, criminal liability for the manager who signed the employment contract.

  • Aggregate headcount across related entities when assessing whistleblower obligations – not just the headcount of the single Polish legal entity.
  • Non-EU nationals require valid work authorisation before their first day of work, not within a grace period after hiring.
  • ZUS registration must occur no later than the first day of employment – late registration triggers surcharges even if contributions are eventually paid in full.
  • Employment contracts must reflect Polish Labour Code norms on working time, holiday entitlement, and notice periods – Hungarian contract templates require adaptation.

We also note that Hungarian companies posting workers to Poland face a separate layer of obligations under the Posted Workers Directive, including notification to the National Labour Inspectorate (PIP) before work begins. For a detailed treatment of posting mechanics and the A1 certificate requirement, see our guide on posted workers from Switzerland to Poland and A1 certificates – the procedural framework is materially the same for Hungarian postings.

A second micro-case is instructive. We assisted a Hungarian IT services company establishing a branch in Małopolska (spring 2025) with EU Blue Card applications for two senior engineers. The EU Blue Card route requires a gross annual salary of at least 1.5 times the average national salary – a threshold that changes each year. Planning the compensation structure in advance, before the employment contract is signed, avoids the need for costly contract amendments later.

For Hungarian companies entering Poland through an Italian intermediate holding, the employment compliance framework at each level of the structure requires separate analysis. Our guide on employment law compliance for Italy companies in Poland covers the Italian-law dimension.

What to prepare before a PIP audit:

  • Valid work permits or notifications for all non-EU employees, with copies on file in Poland.
  • ZUS registration confirmations for every current employee.
  • A whistleblower reporting procedure that accepts anonymous submissions, signed by management.
  • Polish-law-compliant employment contracts for all staff, including any seconded personnel.
  • Posted-worker notifications filed with PIP for any employees sent from Hungary.

The specific compliance position of your Polish entity depends on headcount, the nationalities of your workforce, and the structure of any cross-border arrangements. A gap analysis conducted before a PIP inspection – rather than during one – is the only reliable way to contain exposure.

To receive an expert assessment of your company's employment law compliance position in Poland, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does a Hungarian company need a separate Polish employment lawyer, or can its Budapest counsel handle Polish matters?

A: Polish employment law is a separate jurisdiction with its own Labour Code, ZUS registration regime, and whistleblower legislation. Hungarian counsel cannot represent the company before the National Labour Inspectorate or the Social Insurance Institution. A Polish-qualified employment lawyer Warsaw-based or with a Polish practice licence is required for any formal proceedings or PIP correspondence.

Q: How long does it take to obtain a work permit in Poland for a non-EU employee?

A: Processing times vary by permit type and Voivodeship Office. A Type A work permit typically takes 30 to 60 days. Ukrainian nationals may use a simplified notification procedure, which is filed online and takes effect immediately upon submission. The EU Blue Card carries a similar 60-day processing window but requires salary documentation and a university-level qualification.

Q: Is the whistleblower channel obligation triggered by the Polish entity's headcount or the group's total Polish headcount?

A: The Whistleblower Protection Act applies to the aggregate number of employees working for related entities in Poland, not just the single legal entity. A Hungarian group with two Polish subsidiaries employing 30 people each must establish a reporting channel, even though neither subsidiary individually reaches the 50-employee threshold. This is the most frequently misunderstood aspect of the obligation among foreign groups.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to employment compliance, work permits, and cross-border workforce structuring. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.