A Swedish technology company opens a Polish subsidiary in Warsaw, hires five local engineers, and assigns two Stockholm-based managers to oversee the operation. Within six months, the Polish Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) audits the entity and identifies three separate compliance failures – none of which existed under Swedish law. The cost: back pay obligations, administrative fines, and a reputational alert on the National Court Register (Krajowy Rejestr Sądowy, KRS).

Swedish companies operating in Poland must comply with Polish labour law from the first day of employment – regardless of the parent company's home-country standards. Key obligations include mandatory employment contracts in Polish, statutory notice periods, a whistleblower protection framework effective since September 2024, and posted-worker notification requirements enforced by the PIP. Non-compliance triggers fines of up to PLN 30,000 per violation and, in serious cases, personal liability of the managing director.

This alert covers three areas of immediate concern: the regulatory changes that took effect in late 2024 and early 2025, the thresholds that determine which obligations apply to your Polish entity, and the concrete action items your team must complete within defined deadlines.

What has changed in Polish employment law since 2024?

Polish employment regulation shifted materially in 2024 and 2025. Three instruments now directly affect Swedish employers with Polish operations. Each carries its own threshold, deadline, and enforcement mechanism.

First, the ustawa o ochronie sygnalistów (Whistleblower Protection Act) became fully effective in September 2024. Employers with 50 or more employees must maintain an internal reporting channel, appoint a channel administrator, and adopt a written reporting procedure. Failure to establish the channel is a criminal offence for the responsible manager – not merely an administrative fine. The 50-employee threshold is calculated on a headcount basis across the Polish legal entity, not the global group.

Second, remote work provisions under the amended Kodeks pracy (Labour Code) have been in force since April 2023, but PIP enforcement intensified through 2024. Swedish parent companies frequently instruct Polish employees to work from home without a compliant remote-work agreement. Under Polish labour law, remote arrangements require a written agreement specifying the work location, equipment, and cost-reimbursement terms. For a practical breakdown of those requirements, see our guide on the remote work framework under Polish labour law.

Third, the posted-worker notification system was tightened. Any Swedish employee assigned to Poland – even for a short project – must be notified to the PIP before work begins. The notification is made electronically. The A1 certificate from the Swedish Social Insurance Agency (Försäkringskassan) does not substitute for the PIP notification; both are required in parallel.

  • Whistleblower channel: mandatory for entities with 50+ employees (September 2024)
  • Remote-work agreement: required from day one of any home-office arrangement
  • Posted-worker PIP notification: filed before the assignment starts
  • Minimum wage: PLN 4,666 gross per month from January 2025
  • Civil-law contracts (B2B): subject to reclassification risk if employment criteria are met

The minimum wage increase to PLN 4,666 from January 2025 is a concrete trigger for payroll review. Swedish companies that set Polish salaries in SEK equivalents and convert monthly may inadvertently fall below the statutory floor during currency fluctuations. That breach carries back-pay liability plus interest.

Who is affected and what are the thresholds?

Not every obligation applies to every entity. Polish labour law uses three threshold levels: the individual employment relationship, the 20-employee threshold, and the 50-employee threshold. Understanding which tier your Polish entity sits in determines your compliance workload.

At the individual level, every employer – regardless of size – must issue a written employment contract before the employee starts work, inform the employee of working-time norms within seven days, and comply with the statutory notice periods set by the Labour Code. Notice periods range from two weeks (employment under six months) to three months (employment of three years or more). These obligations apply from the first hire.

At the 20-employee level, the employer must establish a company-wide remuneration policy (regulamin wynagradzania). Many Swedish subsidiaries in Poland reach this threshold faster than anticipated, particularly in the IT and shared-services sectors. Without the policy, individual salary arrangements may be challenged by employees or the PIP.

At the 50-employee level, the Whistleblower Protection Act kicks in. Additionally, entities at this size must establish a company social benefits fund (Zakładowy Fundusz Świadczeń Socjalnych, ZFŚS), contributing a statutory amount per employee annually. For 2025, the base contribution is PLN 2,417.14 per full-time employee. Swedish HR teams often overlook this fund entirely, treating it as optional. It is not.

Swedish companies assigning staff to Poland under secondment arrangements face a separate layer. Posted workers are entitled to Polish minimum conditions – including the PLN 4,666 monthly minimum wage – from day one. The assignment duration does not create an exemption. For cross-border assignment structuring, our analysis of posted workers and A1 certificates provides a directly applicable framework.

One common misconception: Swedish employers sometimes assume that registering a branch (oddział) rather than a subsidiary (spółka z o.o.) reduces employment obligations. It does not. The Labour Code applies equally to both structures. The branch's employees are employees of the foreign parent, which itself becomes subject to PIP jurisdiction for those relationships.

What immediate action items apply to your Polish entity?

Compliance gaps in Polish employment law do not self-correct. The PIP can inspect without prior notice. Fines are assessed per violation, not per audit. A single inspection identifying five separate breaches generates five separate penalty proceedings, each carrying up to PLN 30,000. Personal liability of the manager responsible for labour matters is a real enforcement outcome – not a theoretical risk.

We secured a reversal of a PIP fine exceeding PLN 85,000 for a Swedish manufacturing client in the Mazowieckie region (autumn 2025), where the original assessment had incorrectly aggregated violations. The reversal required a formal administrative appeal and took four months. Prevention costs a fraction of that effort.

Your immediate action list, prioritised by deadline exposure:

  • Audit all employment contracts for Polish-language compliance and statutory content requirements
  • Verify payroll against the PLN 4,666 January 2025 minimum wage – retroactive corrections must be made
  • Establish or audit the whistleblower reporting channel if headcount is at or near 50
  • File PIP notifications for any posted Swedish employees currently working in Poland
  • Review B2B contractor arrangements for reclassification risk under Labour Code criteria

For entities involved in commercial disputes arising from employment relationships, the procedural options available to Swedish companies are addressed in our guide on dispute resolution for Sweden companies doing business in Poland. Employment claims in Poland are heard by dedicated labour courts (sądy pracy), with first-instance proceedings typically running six to eighteen months.

We obtained interim injunctive relief protecting a Swedish employer's trade secrets in a departing-employee dispute in Lower Silesia (spring 2025). Acting within 48 hours of the employee's resignation was decisive. Delay in that case would have been irreversible.

The work permit (zezwolenie na pracę) and EU Blue Card (Niebieska Karta UE) landscape matters for Swedish companies hiring non-EU nationals through their Polish entity. An employment lawyer in Warsaw can map the correct permit type against the role, salary, and entity structure before the hire is made – not after the PIP identifies the gap.

Specific situations require individual assessment. If your Polish entity is approaching any of the thresholds described above – or has already crossed them without implementing the required instruments – the window for voluntary correction is narrower than most HR teams assume.

To receive an expert assessment of your Polish employment compliance position, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does a Swedish company need to register with Polish authorities before hiring its first employee in Poland?

A: Yes. Before the first employment contract is signed, the Polish entity must be registered with the Social Insurance Institution (Zakład Ubezpieczeń Społecznych, ZUS) as a contribution payer. Registration must occur within seven days of commencing activity as an employer. Late registration triggers back-contribution assessments and interest. The entity must also register with the tax authority (Urząd Skarbowy) as a withholding agent for personal income tax.

Q: How long does it take to set up a compliant whistleblower channel for a 50-employee Polish subsidiary?

A: Implementation takes between three and six weeks when done properly. The process involves drafting the internal reporting procedure, consulting the employee representative body or trade union (if present) for a minimum 14-day consultation period, appointing a channel administrator, and deploying the technical reporting tool. Companies that skip the consultation step face a procedural defect that invalidates the entire channel – meaning the criminal exposure for the manager remains.

Q: Can a Swedish parent company apply its own employment policies to Polish employees?

A: Swedish policies can supplement Polish law but cannot replace it. Polish Labour Code standards – notice periods, leave entitlements, working-time limits, and health-and-safety obligations – are mandatory and cannot be contracted out of, even by mutual agreement. Where a Swedish policy provides a more favourable condition than Polish law (for example, longer parental leave), the more favourable standard applies. Where the Swedish policy provides less, Polish law governs. A compliance audit should map each policy provision against the Labour Code minimum before the policy is applied in Poland.

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, workforce structuring, and cross-border mobility. 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.