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Employment agencies – what's new?

by Małgorzata Kolasa-Dorosz

24 June 2025

The new Labour Market and Employment Services Act, which came into force on 1 June 2025, has introduced numerous changes to the operation of employment agencies, including temporary work agencies.

Employment agencies – what's new?

The Labour Market and Employment Services Act has replaced the Employment Promotion and Labour Market Institutions Act of 20 April 2004. It aims to regulate tasks related to professional activity, employment promotion and the labour market in Poland. The Act also contains important regulations affecting the operation of employment agencies, including temporary work agencies in Poland.

The most important changes are listed below:

1. Provision of employment agency and temporary work agency services to foreigners will be possible no sooner than 2 years after the agency’s registration as an employment agency.

When it comes to foreigners who are required to have a work permit or a foreigner employment declaration, employment agencies will be allowed to provide professional employment agency and temporary work services to them no sooner than after 2 years after being registered as an employment agency and providing such services.

Entities registered as employment agencies which provided professional employment agency and temporary work services to foreigners before 1 June 2025 are not subject to the obligation to run the business for 2 years. However, if they want to continue the business, they must apply for amended entry within 3 months (i.e. by 1 September 2025).

2. Foreign businesses must register as employment agencies.

Foreign entities that are not registered as employment agencies are obliged to do so within 3 months of the effective date of the Act.

3. Employment agencies must operate in brick-and-mortar premises.

The Act explicitly introduces the obligation for employment agencies to have premises where agency representatives may be contacted directly and where employment documentation and documents related to the provision of employment by the agency are kept.

4. Changes to the registration procedure and fees.

A provincial marshal now enters the entity in the register of employment agencies within 14 days (instead of the former 7 days). The fee for entry and amended entries to the register has also increased – it is now 1,000 Polish zloty (instead of the former 200 Polish zloty). Also, new documents will be required as part of the registration procedure, including certificates of no arrears in insurance contributions and taxes.

Counteracting employee outsourcing

At the same time, the Act on Admissibility Criteria for Hiring Foreigners in the Republic of Poland has been introduced, which contains important regulations aimed at counteracting labour outsourcing intended to circumvent legislation on temporary work.

New grounds for refusal of a work permit include the case where a foreigner performs work for a third party without having the status of a temporary worker hired by a Polish temporary work agency.

New sanctions have been introduced to combat labour outsourcing. One of them is a fine of not less than 6,000 Polish zloty for hiring a foreigner provided by an entity that is not an employment agency. Enterprises using the services of outsourcing companies should pay particular attention to this and scrutinise their employee hire agreements.

If you have any questions or need to discuss the impact of the new regulations on your business, you are welcome to contact our experts – we will be happy to help you find the best solutions.