PIP fines in 2026, how much really and for what

PIP fines in 2026, how much really and for what

How many levels of liability actually exist

The confusion around PIP fines in 2026 comes from people treating “the fine” as a single number. In reality, a PIP inspection can trigger four different, legally separate consequences, each with its own amount, its own authority, and its own procedure.

Level 1: a PIP decision finding an employment relationship. This isn’t a fine. Since 8 July 2026, a district labor inspector can issue an administrative decision recognizing a B2B contract as employment⁸. The decision itself doesn’t cost money, but it triggers a ZUS and tax assessment for the period specified in the decision, we cover those amounts in detail in the series article on the cost of reclassification.

Level 2: an inspector’s ticket, without court. A PIP inspector can issue a ticket on the spot during an inspection if the employer agrees to accept the penalty without going to court. Standard amount: up to PLN 5,000. For a repeat offense within 2 years: up to PLN 10,000².

Level 3: a fine imposed by a court. If the employer refuses to accept the ticket, or the offense is too serious for ticket proceedings, a district court hears the case in ordinary petty-offense proceedings. Here, the broad range from Articles 281-283 KP applies: PLN 2,000-60,000, up to PLN 90,000 in the narrow case of an alimony debtor¹.

Level 4: a criminal case. If the offense is malicious or systematic (for example, an employer knowingly and repeatedly fails to register a worker with ZUS, or retaliates against them after a PIP decision), the inspector can file a report of suspected crime under Article 218 § 1a or Article 219 of the Criminal Code (Kodeks karny, KK): a fine, restriction of liberty, or imprisonment of up to 2 years⁹.

A PIP fine isn’t one number. It’s four different procedures with four different amounts, and confusing them is the easiest way to underestimate or overestimate your own risk.

How much a conviction under Article 281-283 KP costs before and after 8 July 2026

This is the main table for B2B situations, circumventing an employment contract, unpaid wages, and workplace safety violations.

The practical takeaway for a typical B2B contractor: PLN 2,000-60,000. If you’re not an alimony debtor (and the vast majority of readers in this series aren’t), the PLN 90,000 scenario doesn’t apply to you directly. That’s exactly the detail most “PIP 2026 fines” overviews miss, because they copy the “before/after” table without checking under what conditions the upper limit even applies.

Ticket or court, what it looks like in practice

When a PIP inspector documents an offense, they don’t issue a fine automatically at first. In practice, it looks like this:

1. A written order (polecenie). The inspector specifies what to fix and by when. This isn’t a penalty yet.
2. A ticket, if the employer agrees. For failing to comply with an order, or for formal violations (documentation, deadlines), the inspector may offer a ticket: up to PLN 5,000 for a first offense, up to PLN 10,000 for a repeat within 2 years². The employer signs the ticket and the case closes without court.
3. Refusing the ticket means court. If the employer doesn’t agree to the ticket, or the offense is serious (systematic disguising of an employment relationship, a large number of affected workers), the inspector refers the case to a district court’s petty-offense division.

It’s worth clearing up a common misconception here. In older materials, especially translated from Soviet-era terminology, cases involving minor offenses are sometimes called a “board for petty offense cases” (an equivalent of an “administrative commission”). In Poland, such boards (kolegia do spraw wykroczeń) were abolished back in 2001 with the adoption of the current Code of Petty Offense Procedure (KPW)⁵. Today, a conviction under Articles 281-283 KP is issued by a district court, the same body that hears civil and criminal cases, just under a different procedure.

Example. An IT company received an order from an inspector: transition three B2B contractors to employment contracts by a deadline set by the inspector. The company complied on time. Will it get a ticket or a fine simply for the fact that the contracts were originally civil-law?

No. Complying with the order on time stops the procedure at this stage. A ticket or a court case only arises when the employer fails to comply with the order, repeats the violation, or refuses to cooperate with the inspector.

Repeat offenses within 2 years, where the line actually falls

A ticket for a repeat offense (§ 1b-1bc of Article 96 KPW) is counted not from the date of the very first inspection, but from the date of the last penalty, and only if a new offense of the same type occurred within 2 years of it².

Example 1 (within the limit). A company was penalized with a PLN 3,000 ticket for late wage payment in March 2025. In November 2026, 20 months later, the inspector documents the same offense. Does the higher ticket of up to PLN 10,000 apply?

Yes. 20 months is less than 2 years from the date of the previous penalty, so this counts as a repeat offense under § 1b, and the inspector can issue a ticket of up to PLN 10,000 instead of the standard PLN 5,000.

Example 2 (outside the limit). The same company got its first ticket in March 2023. The inspector documents a new offense of the same type in May 2026, more than 3 years later. Does the higher ticket apply?

No. More than 2 years have passed since the date of the previous penalty, so this counts as a first offense for the purposes of ticket proceedings, not a repeat offense. The standard limit: up to PLN 5,000.

Important: this 2-year counter applies specifically to ticket proceedings (§ 1b-1bc KPW). For a fine imposed by a court under Articles 281-283 KP, there’s no separate statutory “doubled” limit for repeat offenses: the court takes the history of offenses into account when choosing a specific amount within the same PLN 2,000-60,000 range, and the PLN 3,000-90,000 range applies not to repeat offenses but to the separate case of an alimony debtor we covered in the table above.

Illegally employing a foreigner is a different law and a different amount

This is the point most often confused by contractors from Ukraine themselves: fines for B2B reclassification and fines for illegally employing a foreigner come from two different laws, and PIP 2026 doesn’t change the fine amounts in the second one.

If a foreigner works without a work permit, without an appropriate basis for stay, or in violation of the conditions of a permit, the Act of 20 March 2025 on the conditions for the admissibility of entrusting work to foreigners in the territory of the Republic of Poland applies (in force since 1 June 2025, this area was previously governed by Article 120 of the Employment Promotion Act). This isn’t PIP 2026, and it doesn’t concern whether a contract is B2B or employment:

A ticket for these offenses (if a PIP inspector or the Border Guard chooses out-of-court proceedings) can reach PLN 10,000¹⁰. This 2025 law already raised the amounts from the previous PLN 1,000-30,000 (general offense) and PLN 3,000-30,000 (deception and blackmail) to their current levels⁴. The PIP 2026 reform amends this same law, but elsewhere: it adds new grounds for refusing a work permit when an employment relationship is uncovered by a PIP decision¹¹, and doesn’t touch the fine amounts under Article 84.

Example. A Ukrainian developer works on a JDG for a single Polish company, holds a valid residence card based on running a business, and all documents are in order. A PIP inspector finds the contract to actually be employment. Does the company risk a fine for illegally employing a foreigner under Article 84?

No. If the foreigner had a legal basis for stay and worked legally, reclassifying the contract as employment is a matter for Article 281 KP (circumventing an employment contract), not Article 84 of the foreigners’ law. These two risks are separate: the first concerns the form of the contract, the second concerns the foreigner’s very right to stay and work in Poland. We cover in detail what happens to a residence card based on a JDG after such a PIP decision in the series article on the residence card.

When a case becomes criminal rather than administrative

The first three levels (a decision, a ticket, a court fine for a petty offense) are liability for a petty offense (wykroczenie), financial at most. But when the offense is malicious or systematic, an inspector can refer the case to a prosecutor as a suspected crime (przestępstwo) under the Criminal Code:

• Article 218 § 1a KK: malicious or persistent violation of a worker’s rights arising from an employment or insurance relationship, a fine, restriction of liberty, or imprisonment of up to 2 years⁹.
• Article 219 KK: failing to register a worker for social insurance, or submitting false data affecting the right to benefits, the same penalty, up to 2 years⁹.

This isn’t a new PIP 2026 tool, both articles have existed in the Criminal Code for years. What’s new in 2026 is that the reform explicitly directs the inspector to go to the prosecutor in such cases, rather than sticking to administrative tools. In practice, this concerns not a one-off mistake in a contract, but systematic, deliberate concealment of an employment relationship over years, especially when several people are affected at once.

What this actually costs a company besides the fine itself

A fine under Articles 281-283 KP, even at PLN 60,000, is often the smaller part of the financial risk. Back-assessed ZUS contributions for the period specified in the PIP decision, and personal income tax, usually exceed the fine itself several times over, especially when several contractors are involved at once. We break down these amounts in detail, including how already-paid JDG contributions are credited, in the series article on the cost of B2B reclassification: how much ZUS and tax really cost.

Who’s most at risk and what to do about it now

Fine risk doesn’t depend on the industry, but on how much the contract actually looks like employment: one client, a fixed schedule, subordination to a manager. We break down risk profiles with detailed examples in the series article “Who risks losing B2B status after the PIP 2026 reform.” If you recognized your situation in the high-risk profile, the sequence for fixing it without a fine under Article 281 KP is described in the series article “How to fix a B2B contract under PIP 2026: a 12-point checklist,” including how the one-year voluntary correction window until 8 July 2027 works.

The window until 8 July 2027 protects against a fine under Article 281 KP, but not against ZUS back-assessments for years already past.

Frequently asked questions

Can you get both a ticket and a PIP decision on an employment relationship at the same time?

Yes. These are two separate procedures. A decision finding an employment relationship concerns the status of the contract and triggers ZUS consequences. A ticket or court fine concerns a specific offense (for example, circumventing an employment contract). They can arise simultaneously from the same inspection.

Does the PLN 90,000 upper limit apply to a regular B2B contractor?

No, except in a very narrow case: the affected worker is registered as an alimony debtor in the National Debtors’ Register. For the vast majority of readers in this series, the ceiling is PLN 60,000.

Who pays the fine: the company or a specific individual?

A fine under Articles 281-283 KP is paid by the employer (a legal entity, the company) or a person acting on its behalf (for example, a director or HR manager) if that person actually made the decision about the contract’s form. Criminal liability under Articles 218 and 219 KK is always personal.

Can a ticket be appealed?

Yes. An employer isn’t obligated to accept a ticket. Refusal automatically moves the case to a district court, where you can present your position and evidence.

Do these fines include ZUS debt?

No. A fine under Articles 281-283 KP and a ZUS assessment are two separate financial streams with different authorities: a court or an inspector for the fine, ZUS for contributions. The voluntary correction window until 8 July 2027 only protects against the former.

Does the increase in fines apply to companies that have already moved everyone to employment contracts?

Not directly. The new amounts under Articles 281-283 KP apply to violations, not to the mere fact of using civil-law contracts. A company where all contracts match the actual conditions of cooperation carries just as little risk as it did before 8 July 2026.

How to reduce this risk

The first step to reducing this risk is reviewing your own B2B contracts for three things: the number of contractors, the history of past PIP inspections, and whether any affected workers have a special status, for example alimony debtors.

If you work on a JDG yourself. The basic format is an online B2B audit: fill out a questionnaire about your situation, and within 48 hours you get a report with a fine-risk assessment and three priority steps.

If you’re the owner or HR of a company with several B2B contractors. To assess the combined risk across all contracts at once, you need a B2B operating model audit: checking contracts, inspection history, and documentation for the whole team of contractors at once, not one contract in isolation.

Sources

1. Act of 11 March 2026 amending the Act on the National Labour Inspectorate and certain other acts, Dz.U. 2026 poz. 473, Art. 3 (amending Art. 281 § 1, Art. 282 § 1, and Art. 283 § 1 of the Labor Code: PLN 2,000-60,000)
2. Dz.U. 2026 poz. 473, Art. 6 (amending Art. 96 § 1a and § 1b-1bc of the Code of Petty Offense Procedure: a PLN 5,000 and 10,000 ticket for repeat offenses within 2 years)
3. Act of 24 June 2021 amending certain acts related to family benefits, Art. 1 (Art. 281 § 2 and Art. 282 § 3 of the Labor Code, referring to Art. 2(1)(4) of the Act on the National Debtors’ Register); Dz.U. 2026 poz. 473, Art. 3 (raising it to PLN 3,000-90,000)
4. Act of 20 March 2025 on the conditions for the admissibility of entrusting work to foreigners in the territory of the Republic of Poland, Dz.U. 2025 poz. 621, Art. 84; National Labour Inspectorate announcement, “Foreigners: easier employment, higher sanctions for breaking the law”
5. Act of 24 August 2001, Code of Petty Offense Procedure, Dz.U. 2001 nr 106 poz. 1148, Art. 9 § 1 (district court as the first-instance authority since 2001, abolition of boards for petty offense cases)
6. Dz.U. 2026 poz. 473, Art. 1(2) (new Art. 11(1)(7a) of the PIP Act); Social Insurance System Act, Dz.U. 2026 poz. 199, Art. 18(1b) and Art. 38b (added by Dz.U. 2026 poz. 473, Art. 5)
7. Dz.U. 2026 poz. 473, Art. 16 (voluntary adjustment period until 8 July 2027) and Art. 14 (transitional provision)
8. Dz.U. 2026 poz. 473, Art. 1(2) (new Art. 11(1)(7a) of the PIP Act, a decision finding an employment relationship)
9. Act of 6 June 1997, Criminal Code, Art. 218 § 1a and Art. 219
10. Code of Petty Offense Procedure, Art. 96 § 1af (a ticket of up to PLN 10,000 for offenses under Art. 84 of the Act of 20 March 2025 on the admissibility of entrusting work to foreigners)
11. Dz.U. 2026 poz. 473, Art. 8 (amending Art. 33(2) and Art. 69 of the Act of 20 March 2025 on the admissibility of entrusting work to foreigners, new grounds for refusing a work permit)

This article does not constitute legal advice. Every situation is individual and depends on the specific contract and circumstances. Author: Walery Kusznirski, in-house legal practitioner at MojaFirma.