HR and payroll legislative updates: Q3/2024

Below we present the most important, in our opinion, changes and planned legislative changes in the area of HR and payroll.

1.     Increase in minimum wage

As of 1 July 2024, another increase in the minimum wage was made to the amount of PLN 4,300. However, the minimum hourly rate for certain civil law contracts and contracts for the provision of services, to which the provisions of the Civil Code apply, should be established in the contract in such a way that the remuneration for each hour of performance of the order or provision of services is not less than the amount of the minimum hourly rate, i.e. PLN 28.10.

2.     Obligation to provide statements to the Polish Development Fund (PFR) on the number of employees and participants in the Employee Pension Program (PPE)

By 31 July 2024, employers were required to provide the Polish Development Fund (PFR) with a statement on the number of employees and PPE participants employed by the employer as of 
1 January and 1 July in a given calendar year. According to Article 23a of the Act on Employee Pension Programs of 20 April 2004 (Journal of Laws of 2024, item 556), this statement should be submitted in either electronic or paper form by 31 January and 31 July in a given calendar year.

3.     PUE ZUS to be transformed into eZUS

On 29 July 2024, the Social Insurance Institution (ZUS) announced on its website (www.zus.pl) that works to modify the Platform for Electronic Services (PUE ZUS), which will eventually be replaced by eZUS, are in progress.

Other important changes to be introduced at this stage include a new cookie policy for PUE/eZUS and the translation of eZUS components into Ukrainian and English.

4.     Act on the Protection of Whistleblowers

As of 25 September 2024, the Act of 14 June 2024 on the Protection of Whistleblowers (Journal of Laws, item 928) came into force (with exceptions), imposing a number of new requirements on employers. The law applies to legal entities (private entity or public entity) for which, as of 1 January or 1 July of a given year, at least 50 people perform paid work, covering full-time employees or persons performing work for remuneration on a basis other than employment, if no other persons are employed for such work, regardless of the basis of employment. The threshold of 50 persons does not apply to a legal entity performing activities in the fields of financial services, products and markets, as well as anti-money laundering and counter-terrorist financing, transportation security and environmental protection covered by the EU legal acts listed in Part I.B and II of the Annex to Directive 2019/1937.

The introduced law imposed a number of new requirements on employers. Under the new regulations, employers will be obliged to, among other things:

  • introduce secure methods for reporting;
  • establish the content of the internal reporting procedure;
  • carry out verification of reports and follow-up;
  • ensure the confidentiality of data and information contained in reports;
  • maintain records of internal reports.

5.     Minimum wage and minimum hourly rate in 2025 - draft regulation

The draft Regulation of the Council of Ministers on the amount of the minimum wage and the amount of the minimum hourly rate in 2025 (draft number RD111) specifies the following minimum wage amounts effective as of 1 January 2025:

  • minimum wage - PLN 4,626,
  • minimum hourly rate - PLN 30.20.

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