Poland’s First 8 Individual PIP Rulings on B2B and Service Contracts. What Should Companies Know?

In August 2026, Poland’s Chief Labour Inspector (GIP) published the first individual interpretations issued under the new regulations on determining the existence of an employment relationship. For the first time, the labour inspectorate has shown in concrete terms how it will assess cooperation models based on B2B contracts and civil law agreements.

The first eight cases covered a wide range of industries and models: temporary work arranged through an online platform, sales services, IT contracts, child transport and care, students working in a bakery, and delivery drivers. GIP approved three models. Five were challenged as displaying characteristics of an employment relationship.

The numbers themselves matter less than what these rulings mean for the day-to-day management of contractor relationships in your organisation.

What Cooperation Models Did GIP Evaluate?

The eight cases spanned very different sectors: from digital platforms and IT, through commercial services, to transport and care. Below is a summary of all cases, including the ruling and the key argument behind each decision.

No.	Cooperation model	GIP ruling	Key argument
1	Short-term tasks performed at a temporary work agency’s clients	❌ Challenged	Client supervision, ongoing instructions, fixed place and working hours
2	Tasks chosen by individuals through an online platform	❌ Challenged	Freedom to choose a task does not eliminate subordination once the task is accepted
3	Acquiring business contacts and clients	✅ Approved	Autonomy, results-based billing, genuine right of substitution
4	Specialist IT services and Project Manager in B2B model	✅ Approved	No subordination, separate work orders, contractor bears business risk
5	Transporting children on a fixed route throughout the school year	❌ Challenged	Fixed schedule, continuous and personal nature of work
6	Caring for children during transport to educational facilities	❌ Challenged	Integration into an organised process, no real right of substitution
7	Students working as sales assistants and production staff	❌ Challenged	Tasks assigned by the employer on an ongoing basis according to operational needs
8	Drivers making occasional bread deliveries	✅ Approved	Self-determined availability, right to refuse a delivery, right of substitution

Freedom to Choose a Task Is Not Enough

The first two interpretations concerned a temporary work agency that allowed individuals to select tasks through an online platform. This sounds flexible. And indeed, contractors could decide independently which assignment to accept. The problem appeared after that acceptance.

Once a task was taken on, workers were required to show up at a specific place and time, worked under the supervision of the agency’s client, and followed ongoing instructions. For the Labour Inspectorate, what mattered was not when or whether the contractor accepted the task, but how the work looked once it began.

GIP also challenged the formal option to transfer a task to another person. In practice, this led to terminating one contract and signing a new one with a different contractor — which the authority treated as a simulated, rather than genuine, right of substitution.

For companies using marketplace platforms, crowdworking models, or flexible operational resources, this is a significant signal. Freedom to choose an assignment does not protect against an employment classification if the actual working conditions, once the task begins, resemble a standard employment model.

When Does a Civil Law Contract Pass the Test?

The third interpretation concerned individuals responsible for acquiring clients and arranging sales meetings. GIP approved the model.

The deciding factor was autonomy. Contractors chose their own place of work, organised their own time, used their own tools, and determined how to carry out their activities. The client set objectives but did not control how those objectives were achieved. The genuine right of substitution and a focus on results rather than presence also played an important role.

The ruling confirms that a civil law contract can work well in a long-term cooperation arrangement, provided the contractor retains real independence and billing is tied to outcomes, not hours logged.

The Most Important Ruling for the B2B Market: IT Sector

From the perspective of companies working with contractors, the fourth interpretation — covering an IT cooperation model — carries the most weight.

The company engaged sole traders under framework B2B contracts. Individual services were delivered based on separate work orders specifying the scope, conditions, and billing terms. Contractors could decline an order. The company guaranteed neither continuity nor a minimum volume of work.

Contractors were not subject to the company’s management authority. Project coordinators could define the goal, quality standard, and deadline, but did not dictate how the work should be carried out. Time tracking served billing purposes, not attendance monitoring under employment law.

GIP approved the model. The ruling highlighted:

• the right to decline a work order,
• no guaranteed continuity of cooperation,
• contractual liability for results,
• the ability to provide services to other clients,
• no payment for mere availability,
• the contractor bearing business risk.

The interpretation also covered Project Managers working in a B2B model. GIP accepted this arrangement on the condition that the contractor does not act as an employer. This means not making decisions on hiring, dismissal, or remuneration, with activities limited to delivering a specific project.

This is an important signal for the specialist services market: coordinating a project or leading a project team does not automatically constitute an employment relationship.

Transport and Care: Why Did PIP Challenge These Models?

The fifth and sixth interpretations concerned transporting children with disabilities and providing care during school transport. In both cases, GIP identified characteristics of an employment relationship.

The reasoning was similar across both cases: work was continuous and repetitive throughout the entire school year, carried out on a fixed route according to a set schedule, with the organisational and economic risk resting entirely with the transport organiser. Contractors were effectively part of an organised process rather than independently operating entities.

GIP also addressed an important point of principle: worker subordination does not require instructions to be issued on a daily basis. It is sufficient that the organisation of work, the schedule, and the rules governing how duties are performed remain under the control of the engaging party. Companies that justify the civil law nature of their contracts by pointing to a lack of day-to-day interference should take note.

Flexible Scheduling for Students: Why It Was Not Enough

The seventh interpretation concerned students working as sales assistants and production staff at a bakery. On the surface, the model looked flexible: students set their own availability, could pause cooperation during exam periods or internships, and were not required to work a minimum number of hours.

GIP challenged the model nonetheless. One element proved decisive: once work began, the employer assigned tasks on an ongoing basis according to the current needs of the shop or production line. Students decided when they were available, but not what they would actually do once they arrived.

For companies, the takeaway is straightforward. A flexible schedule and the absence of a minimum hours requirement do not determine whether a contract is genuinely civil in nature. What matters is who actually organises the work once it starts.

Bakery Delivery Drivers: An Approved Model

The final interpretation concerned drivers making supplementary bread deliveries and GIP approved it. Two elements were decisive: the drivers set their own availability and were not obligated to accept deliveries outside the hours they had declared in advance. The contract also provided for a genuine right of substitution.

Comparing this case with the children’s transport interpretation is instructive. In both cases, drivers used vehicles owned by the organiser. In the delivery model, however, autonomy prevailed — both in terms of availability and the acceptance of individual assignments. In the children’s transport model, a fixed schedule and organisational subordination were present throughout.

The same occupation, the same vehicles, different conclusions. The difference lay in how everyday cooperation was organised.

PIP Is Not Fighting B2B. It Is Reviewing How Cooperation Actually Works

Looking across the first eight individual interpretations, it is difficult to conclude that the purpose of the new regulations is to eliminate B2B contracts or civil law agreements. GIP approved cooperation models with IT contractors, with individuals acquiring clients, and with drivers making occasional deliveries.

For the first time, companies also have practical examples showing how the inspectorate evaluates real-world cooperation arrangements. For years, organisations based their assumptions primarily on court rulings. Today, we have the first formal positions from an authority equipped with new enforcement powers.

The problem is not B2B or a civil law contract. The problem is cooperation that looks like employment. Even a well-drafted contract may not provide adequate protection if the day-to-day working arrangement resembles an employment model. An audit should cover not only documentation but also onboarding practices, manager behaviours, operational communication, task assignment processes, and the terms on which services are billed and availability is managed.

Practical Conclusions for HR and Operations Teams

The first GIP interpretations do not close the debate on B2B and civil law contracts. They open an entirely new chapter: instead of assumptions and court precedents, companies now have concrete positions from the enforcement authority itself.

It is worth reviewing not only documentation but also how cooperation actually functions day to day:

• who assigns tasks to contractors and how,
• whether contractors have a genuine right to decline an assignment,
• how the right of substitution works in practice,
• whether billing relates to results or to time worked,
• how closely the day-to-day cooperation model aligns with the contract in place.

These first interpretations mark the beginning of PIP’s enforcement practice, not its conclusion. What they already show clearly is that the strongest protection will not come from the name of the contract, but from consistency between the documentation and the reality of how work is actually carried out.