Remote Labour Inspectorate control — employer obligations step by step

From 8 July 2026, a labour inspector may carry out an entire inspection or particular activities remotely — by means of electronic communication or a postal operator. The employer's consent is not a condition for this form of inspection. The remote form changes the way activities are performed, but does not reduce the scope of obligations: documents still have to be made available, information provided, conversations with employees enabled and post-inspection measures implemented. Below we describe what the employer must do at each stage of a remote inspection — with the legal basis, cases from practice and a checklist. Separately we discuss the most common flashpoint in companies employing foreign nationals: documentation of the legality of employment of foreign nationals.

1. What a remote inspection involves after 8 July 2026

The change is based on the Act of 11 March 2026 amending the Act on the Labour Inspectorate and certain other acts (Dz.U. 2026 poz. 473), promulgated on 7 April 2026 and, as a rule, in force from 8 July 2026. The amendment allows an inspection or its particular activities to be conducted through a postal operator or by means of electronic communication, if this is not contrary to the purpose of the inspection, if the nature of the inspected entity's activity permits it, or if it makes the inspection more efficient. In justified cases the inspector may demand an online transmission enabling the inspection of documents, the hearing of a party and an interview — with a two-way transmission of image, or image and sound, in real time. The inspection protocol may be drawn up in electronic form.

2. Verify the inspector before you send anything

An inspection is carried out upon presentation of an official identity card confirming the inspector's identity and powers, and an inspection of an entrepreneur — upon presentation of the identity card and an authorisation to carry it out (art. 24 ust. 2 i 3 ustawy o PIP). The authorisation contains, among other things, the legal basis, the subject-matter scope of the inspection, identification of the entity, the dates of commencement and expected completion, and instructions on the rights and obligations of the inspected party (art. 24 ust. 4). In the case of an urgent inspection, the authorisation may be delivered later, no later than within 7 days of the day the inspection was undertaken (art. 24 ust. 5).

In remote activities, identity verification is of particular importance, because personnel documentation goes into an electronic channel. Do not send personnel files to an address you cannot attribute to a district labour inspectorate, and do not use an unverified videoconference link. If in doubt, confirm the contact with the district labour inspectorate competent for the company's registered office.

3. Appoint a contact person

The inspection coordinator on the employer's side should receive the inspector's summonses and demands, hand over documents and keep a register of them, organise contact with HR, accounting and the occupational health and safety service, enable conversations with employees and contractors, and explain where particular information can be found.

This does not have to be a member of the management board. It should be a person who knows the company's organisation and has real access to the documentation. It is worth indicating a deputy for periods of absence straight away — the Act requires information to be provided on time (art. 27 ustawy o PIP), and the coordinator's holiday is no excuse for delay.

4. Make the documentation available in electronic form

The inspector has the right to demand the submission of personnel files and any documents connected with the performance of work by employees or by persons performing work on a basis other than an employment relationship (art. 23 ust. 1 pkt 5 ustawy o PIP), as well as information and documents concerning the posting of workers and drivers (art. 23 ust. 1 pkt 5a–5c). Depending on the scope of the inspection, these will be in particular:

• employment contracts, mandate contracts and contracts for the provision of services,
• working time records, schedules and rosters,
• payrolls and confirmations of payment of remuneration, including the minimum hourly rate,
• leave documentation,
• medical certificates and confirmations of health and safety training,
• occupational risk assessment and accident documentation,
• documents concerning the legality of employment of foreign nationals — the residence title, work permit, single permit or declaration on entrusting work,
• documents concerning the posting of workers and drivers.

The material must be complete, legible and described in such a way that it is clear what it concerns and which period it covers.

5. Provide the conditions for online transmission

If the inspector demands an online transmission, the employer must provide:

• a device with a working camera and microphone, if image or image and sound is required,
• a stable connection,
• the ability to share the screen or documents,
• the availability of a person representing the employer,
• the possibility for an HR officer, accountant or health and safety specialist to join,
• conditions allowing an unconstrained conversation without the participation of unauthorised persons.

Not every activity, however, can be carried out remotely. Inspection of a machine, a workstation, an escape route or the actual manner in which work is performed may require the inspector's presence at the establishment.

6. Provide explanations and do not obstruct conversations with employees

The inspector may demand written and oral information on matters covered by the inspection and may summon and interview not only current employees, but also persons who were employed or performed work for the inspected entity on a basis other than an employment relationship — including persons conducting self-employed business activity and using the services of employment agencies (art. 23 ust. 1 pkt 3 ustawy o PIP).

The employer should answer questions within the scope of the inspection, indicate the persons competent to explain the facts and enable contact with employees. It is not permitted to influence the content of statements or to arrange conversations in such a way that they can be overheard.

7. Take care of data security

Remote activities are to take place while maintaining an appropriate level of security of ICT systems — confidentiality, availability and integrity of data transmission. For the employer, this means:

• an agreed, secure communication channel,
• limiting access to documents to authorised persons,
• a ban on sending personnel files to private and random addresses,
• protecting files against unauthorised modification,
• a register of what was handed over and when,
• handing over specific files instead of entire folders,
• control over who is watching the transmission on the company's side.

Personal data protection is not a basis for refusing to hand over documents covered by the inspection — processing at the inspector's demand fulfils the controller's legal obligation (art. 6 ust. 1 lit. c RODO), and the choice of transmission safeguards follows from art. 32 RODO. The proper response is to agree on a secure way of making the documents available, not to refuse.

8. Provide the conditions and means for the inspection to run efficiently

The inspected entity is obliged to provide the inspector with the conditions and means necessary for the inspection to run efficiently, in particular to present the requested documents and materials without delay, to ensure that information is provided on time, to make technical equipment available and — as far as possible — a separate room with appropriate equipment (art. 27 ustawy o PIP). In a remote inspection, this obligation covers the equipment, a videoconferencing tool, the ability to make legible copies and access to data to the extent necessary for the inspection.

9. Keep a register of materials handed over and mark trade secrets

The inspector may make copies or extracts from documents necessary for the purposes of the inspection, as well as statements and calculations drawn up on their basis, and if necessary demand them from the inspected entity (art. 23 ust. 1 pkt 8 ustawy o PIP). So keep a version of every document handed over, the date of handover and the person handing it over, the scope of the data, the explanations to the files and confirmation of receipt. This matters in the case of staged transmissions and successive versions of statements — including as evidence, in the event of later reservations to the inspection protocol.

At the request of the inspected entity, the protocol includes a note about information covered by trade secrets (art. 31 ust. 2 pkt 14 ustawy o PIP). Indicate specifically which information is protected and why — marking an entire file as „confidential" is sometimes insufficient. Trade secrets do not justify a refusal to hand over a document connected with the inspection.

10. Inspection protocol, reservations and post-inspection measures

The inspector documents the findings of the inspection in a protocol (art. 31 ust. 1 ustawy o PIP); from 8 July 2026 it may take electronic form. The protocol contains, among other things, a description of the infringements of law found, the content of oral decisions and orders, a list of attachments and a note on whether reservations were raised (art. 31 ust. 2). Before signing the protocol:

• compare the description of the facts with the documentation handed over,
• verify the data, dates and identification of the days on which the inspection was carried out,
• point out errors and omissions,
• raise reasoned reservations to the findings — in writing, within 7 days of the day the protocol was presented (art. 31 ust. 4 i 5 ustawy o PIP).

After the inspection, the employer may receive a decision, an order or a post-inspection request. Post-inspection measures are implemented within the time limits arising from them, and the competent authority of the Labour Inspectorate is notified of the manner of implementation — also in electronic form.

11. What an employer should not do

• ignore the inspector's messages and summonses,
• deliberately delay handing over documents,
• send illegible or incomplete files,
• delete or modify data in the documentation,
• induce employees to give particular answers or obstruct conversations,
• invoke personal data protection in order to block the inspection,
• hand over documents through a channel of unverified security,
• make available a wider scope of data than is needed,
• assume that a remote inspection excludes a later visit to the establishment.

Thwarting or obstructing inspection activities gives rise to liability — for a petty offence under the Labour Code and criminal liability, where a person authorised to carry out inspections within the scope of labour inspection is thwarted or obstructed in an official activity (art. 225 § 2 Kodeksu karnego). At the same time, the employer has the right to expect that the inspector's demands will remain connected with the subject matter of the inspection.

12. Checklist before a remote inspection

1. Verify the inspector's identity card and authorisation.
2. Agree on a secure communication channel.
3. Appoint a coordinator and their deputy.
4. Secure the documentation against modification and deletion.
5. Prepare the documents in readable formats.
6. Check the completeness of the data for the requested period.
7. Prepare a legend for abbreviations and system reports.
8. Ensure the availability of the right people — HR, accounting, health and safety.
9. Check the consistency of the residence documents and the bases for work of foreign nationals with the actual conditions of employment.
10. Separate the data covered by the inspection from the company's other data.
11. Keep the confirmations of file handover.
12. After the inspection, analyse the protocol and the deadlines for post-inspection measures.