Newsletter HR | May 2021

As part of the national vaccination program, it is possible to organize vaccinations at the workplace. Guidelines for the organization and implementation of such vaccinations have been published on government websites. The employer will be responsible, inter alia, for collecting a list of employees who express their willingness to be vaccinated, ensuring appropriate safety conditions and also for covering any additional costs which may arise during the organization of vaccinations, relating, for example, to the rental of premises intended for vaccination points. The condition for the organization of vaccination at the workplace is the registration of at least 300 persons. The registration form for workplaces is available at

As a result of legislative changes, it is possible to vaccinate outside of the national registration schedule. This is possible  when a risk of waste of a vaccine dose occurs. The above may result in unexpected absences in the workplace or an increase in the number of employees’ applications for release from work for the time of vaccination. Currently, the employee is not entitled to a day off for the duration of the vaccination, however it is worth remembering that in the event of side effects, the employee may receive sick leave under the general rules.

As of 16 May 2021, an additional information obligation will be imposed on entrepreneurs with regard to the Social Security Institution (pol. ZUS). When registering an employee / contractor for insurance, employers will be required to indicate the occupation code which the insured will perform. For this purpose, the respective application forms (ZUS ZUA and ZUS ZZA) will be updated. The new forms will contain a 6-digit occupation number, indication of which will be mandatory when reporting new employees and contractors. As indicated in the rationale for the bill, collecting information on the occupation of insured persons by ZUS will be used for statistical purposes. This information will be used, among others, to analyze the reasons for sickness absences, the assessed degree of inability to work, the level of benefits. The new information obligation applies only to new registrations, so the registrations made before that change will not have to be corrected.

Employers who have not fulfilled the obligation to implement Employee Capital Plans (pol. PPK) within the statutory deadline can expect to receive a reminder from the Polish Development Fund (pol. PFR) to conclude a PPK management agreement. After receiving the reminder, employers are obliged to conclude a PPK management agreement within 30 days and with a financial institution designated by PFR, i.e. PFR Towarzystwo Funduszy Inwestycyjnych SA.  However, employers may choose another financial institution, which should be immediately notified to PFR.

The reminders from PFR have already been received by employers who had to implement the PPK by 27 October 2020, but failed to comply with this obligation. This refers to employing entities that, as at 30 June 2019, paid contributions for at least 50 individuals, as well as entities with at least 20 individuals hired as at 31 December 2019.

Identical reminders from PFR can be expected by entrepreneurs who were required to conclude a management agreement until 23 April 2021 and failed to do so. We would like to remind you that failure to comply with the obligation to conclude a PPK management agreement may result in imposition of a fine of up to 1.5% of the wage fund in the employing entity in the financial year preceding failure to comply with this obligation.

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