Poland: HR Revolution 2026: The End of Paper-Based Records. How to Implement Electronic Documentation?

The year 2026 will mark a turning point in Polish labour law, symbolizing the definitive shift from traditional paper-based processes to a fully digital reality. The amendment to the Labour Code, introduced under the Act of 4 December 2025 amending the Labour Code and the Act on the Company Social Benefits Fund, which came into force on 27 January 2026, introduces a fundamental change: full equivalence between paper and electronic formats in key HR processes.

For HR and Payroll teams, this means more than just fewer binders. It requires a redefinition of daily workflows, internal procedures, and compliance approaches.

Table of contents:

• The key change: “Format” instead of “Form”
• Practical applications of electronic documentation in HR
• New ICT system for micro-enterprises
• How to prepare HR departments for the changes

The Key Change: “Format” Instead of “Form”

The core of the 2026 reform lies in replacing the phrase “in writing” across multiple provisions of the Labour Code with “in paper or electronic format.”

In practice, this means that for a number of HR-related activities, a qualified electronic signature is no longer required, a barrier that previously limited adoption among employees. Instead, what is now sufficient is the so-called electronic format, which may include:

• an email sent from a corporate mailbox
• a request submitted via an HR/payroll system (ESS)
• a message sent through internal communication tools such as Slack or Microsoft Teams

This change significantly lowers the threshold for digital HR processes while maintaining compliance.

Broad Practical Applications of Electronic Documentation 

As of January 2026, most aspects of the employee lifecycle can be managed electronically. Below are selected examples where both paper and electronic formats are now equally valid:

Working Time Management

Requests for unpaid leave, overtime time-off, or personal leave no longer require paper forms. Employees can submit requests via internal communication tools, and managers can approve them digitally, often with automatic integration into payroll systems.

Work Organization

Applications for flexible working hours, weekend systems, or individualized schedules can now be handled entirely digitally. The same applies to occasional remote work, eliminating the need to submit printed requests within the annual limit.

Employer Information Obligations

Employers may now communicate key information, such as the introduction of monitoring systems (CCTV, email, GPS) or the transfer of an undertaking, via mass email or internal intranet notifications.

Onboarding

Personal data questionnaires, electronic referrals for medical examinations, and confirmations of health and safety (H&S) training can all be processed digitally, streamlining onboarding workflows.

Employee Benefits (Company Social Benefits Fund)

Declarations of income for benefit eligibility or applications for loans from the social fund can be submitted through employee self-service portals, without the need for paper documentation.

New ICT System for Micro-Enterprises

The beginning of 2026 also marks the launch of a government-provided ICT system (available via praca.gov.pl). It is primarily designed for micro-enterprises and individuals employing domestic workers, such as nannies or household staff.

The platform enables:

• the conclusion of employment and civil law contracts using standardized templates
• automatic employee registration with social security (ZUS)
• maintenance of electronic employee records (e-files)

All of this can be done without the need to invest in dedicated HR software, significantly lowering the entry barrier for compliant HR administration.

How Should HR Departments Prepare for the Changes?

To fully leverage the opportunities introduced in 2026, HR and Payroll teams should focus on four key areas:

• Process Audit: Review internal policies and procedures to eliminate requirements for written form wherever the law now allows electronic communication (e.g. standard email).
• System Readiness: Ensure that HR systems include employee self-service (ESS) functionalities aligned with new types of requests and approvals in electronic format.
• Data Security and Compliance: Implement clear policies for storing and archiving emails, system logs, and digital records as valid HR documentation, in line with GDPR requirements.
• Internal Communication: Employees and managers must understand that digital communication (e.g. via email or internal tools) now carries legal weight and constitutes binding HR requests.

The shift to electronic documentation in 2026 is not only about convenience. It is primarily about legal certainty, operational efficiency, and speed, all of which have become essential in today’s hybrid and distributed work environments.