HR changes from 1 January 2027: minimum wage of PLN 4,950, ZUS 30x cap, ZFŚS and the draft new PIT scale
From 1 January 2027, HR and payroll teams must apply the new minimum wage of PLN 4,950 gross and the minimum hourly rate of PLN 32.30 gross, as well as the official ZUS 30x contribution cap of PLN 300,990 announced in Monitor Polski. From the same day, the obligation to issue invoices in KSeF will cover all taxpayers, including the smallest businesses. The ZFŚS (Company Social Benefits Fund) write-off amount for 2027 has not yet been announced. The act introducing a new PIT tax scale has been passed by the Sejm and adopted by the Senate without amendments, but as of 9 November 2026 it has not been signed by the President or published in the Journal of Laws. It is therefore not in force and is not a basis for changes to HR and payroll systems.
The turn of the year is a time of intensive preparation in HR and payroll departments, a review of pay grids and planning the HR budget for 2027. Upcoming legislation poses considerable interpretation and calculation challenges for those responsible for people matters. Amid the flood of information, the key is to separate precisely the rules already published in the Journal of Laws and Monitor Polski from amounts that have yet to be announced and from acts still awaiting the end of the legislative process.
The key HR changes from 1 January 2027 include legally guaranteed increases in the lowest pay rates and a new cap on pension and disability contributions, as well as the annual challenges of the social fund, the full roll-out of KSeF and a potential reform of the tax thresholds. This article organises the most important areas of change, shows their formal status and suggests how to prepare your organisation for a safe start to the new calendar year.
Summary of legal changes: status, dates and sources
To help HR and payroll teams prioritise their work, the table below shows the formal status of each key regulatory area as of 9 November 2026.
Minimum wage of PLN 4,950 gross and hourly rate of PLN 32.30: formal requirements
The minimum wage is now fully settled. Under the Council of Ministers Regulation of 14 September 2026, published in the Journal of Laws (Journal of Laws 2026, item 1213), from 1 January 2027 the minimum wage is PLN 4,950 gross. In 2026 it was PLN 4,806 (Journal of Laws 2025, item 1242), which means an increase of PLN 144, or 3%, compared with the 2026 minimum wage.
The same regulation sets the minimum hourly rate for certain civil-law contracts, which from 1 January 2027 is PLN 32.30 gross (2026: PLN 31.40).
Impact on benefits linked to the minimum wage
The PLN 4,950 gross amount automatically affects a number of employee benefits and limits that the law links to the minimum wage:
- Night work allowance: it is calculated from the hourly rate derived from the minimum wage, so it rises with it.
- Minimum basis for benefits (zasiłki): for a full-time employee it is linked to the minimum wage.
- Severance pay on termination for reasons not attributable to employees: its maximum amount is set by reference to the minimum wage.
- Lower limit of compensation: compensation for breach of the principle of equal treatment in employment may not be lower than the minimum wage (Art. 18³ᵈ § 1 of the Labour Code), and compensation for mobbing may not be lower than six times the minimum wage (Art. 94³ § 11 of the Labour Code as in force from 5 November 2026, Journal of Laws 2026, item 1046).
Pay grid compression
A 3% increase in the pay floor requires HR departments to review internal pay relativities. Even a moderate rise in base pay narrows the financial gap between entry-level employees and more qualified or longer-serving staff. Failing to adjust rates at higher levels may reduce motivation and create a sense of unfairness, so HR teams should plan appropriate shifts in their budgets.
ZUS 30x contribution cap for 2027: officially PLN 300,990
The second important issue for payroll is the annual cap on the basis for pension and disability contributions.
The official cap for 2027
The 2027 cap is no longer a forecast. The Minister of Family, Labour and Social Policy announced it in a notice of 3 November 2026, published on 4 November 2026 in Monitor Polski (Monitor Polski 2026, item 1098). In 2027 the annual basis for pension and disability contributions may not exceed PLN 300,990.
This amount equals thirty times the forecast average wage, which the notice sets at PLN 10,033. For comparison, in 2026 the cap is PLN 282,600 (Monitor Polski 2025, item 1206), an increase of PLN 18,390. Payroll teams can already enter the new value into the annual parameters of their HR and payroll system for 2027.
How it works and the 1 January reset
Once the annual cap is exceeded during the year, the employer and employee stop paying pension and disability contributions, while other contributions continue to be calculated. A higher cap means that, at an unchanged salary, an employee will reach the threshold later than in 2026.
On 1 January the mechanism resets completely:
- The contribution payer resumes paying full contributions on the pay of key experts and managers.
- Employees earning above the threshold see lower net pay in the first months of the year compared with the end of the previous year.
- The employer records higher monthly contribution costs in the first quarter.
Company Social Benefits Fund: write-off and the social criterion
The start of the year is also a time to review how the Company Social Benefits Fund (ZFŚS) is used.
The write-off basis for 2027
The basic write-off per employee working in normal conditions for 2027 will be announced. As of 9 November 2026 the amount has not yet been published. For comparison, in 2026 the basic write-off is PLN 2,943.23, i.e. 37.5% of the average wage in the second half of 2025 (PLN 7,848.60 according to the notice of the President of Statistics Poland (GUS) of 19 February 2026). Preliminary financial plans for the new year can use this amount as a baseline until the new write-off is announced. It is also worth remembering the rules for adjusting the ZFŚS write-off.
Employers with at least 50 full-time equivalent employees (as at 1 January) are legally required to create the fund, unless they introduce provisions in their internal regulations, following the proper procedure, opting out of the ZFŚS or of paying the holiday benefit.
The mandatory social criterion
The most important legal rule for distributing ZFŚS funds remains Article 8 of the Act on the Company Social Benefits Fund. Under it, granting subsidies and the amount of benefits must depend on the life, family and financial situation of the eligible person.
Giving all employees the same amounts or identical vouchers without checking income breaches the law and may result in the ZUS contribution exemption being challenged during an inspection.
Modern fund management with the Nais platform
Collecting paper income declarations can be tedious and raises data protection concerns. The Nais cafeteria platform makes it possible to:
- collect employees' declarations on their financial situation digitally and securely,
- automatically assign each employee to the right income group in line with the company's rules,
- allocate funds precisely while respecting the principle of differentiation,
- let employees freely choose their benefit, from recreation and culture to support with health and education expenses.
This makes it easier for employers to comply with ZFŚS rules and relieves HR of manually recording paper documents.
The new PIT tax scale: status of the legislative work
The change to personal income tax thresholds is widely discussed in public. However, HR and payroll departments must remember that as of 9 November 2026 the act has not been signed by the President or published in the Journal of Laws, so it is not binding law and is not a basis for changes to payroll systems.
Legislative timeline
The first government bill amending PIT, CIT and the flat-rate tax was submitted to the Sejm on 29 September 2026 as Sejm print 3147. The Sejm passed the act on 22 October 2026, and on 27 October 2026 the Senate introduced amendments. As the Ministry of Finance explained in a statement of 4 November 2026, to avoid any doubt about the correctness of the procedure, the government decided to submit the bill again.
The new bill was submitted to the Sejm on 4 November 2026 (Sejm print 3293). In it, the government indicated that the act needed to be published in the Journal of Laws by 30 November 2026. On 5 November 2026 the Sejm held the first reading, the Public Finance Committee presented its report (print 3323), followed by the second and third readings. 236 MPs voted in favour and 207 against. On 6 November 2026 the Senate adopted the act without amendments: 63 senators voted in favour, 31 against and 1 abstained. On the same day the act was sent to the President for signature. The President may sign the act, veto it or refer it to the Constitutional Tribunal.
What the act provides, if it enters into force
According to the bill (print 3293), if the act enters into force, the tax scale applied to income earned from 1 January 2027 will have three brackets:
- 12% on income up to PLN 130,000,
- 24% on income above PLN 130,000 up to PLN 150,000,
- 32% on income above PLN 150,000.
Currently there are two rates, 12% and 32%, with a threshold of PLN 120,000. According to the explanatory memorandum, the tax-free amount does not change and stays at its current level.
If the act enters into force, payers would have to rebuild their systems for withholding tax advances and apply new rules for calculating net pay.
How should HR approach the act?
Until the act is signed by the President and published in the Journal of Laws, it cannot be a basis for updating production parameters in payroll software as of 1 January 2027. Implementing new calculation algorithms will only be justified after the act is published in the Journal of Laws and taking into account its entry-into-force date. Until then, income tax advances should be calculated under the current rules. HR and payroll teams should follow the President's decision and agree a quick update plan with their payroll software provider now, but hold off on modifying payroll systems.
KSeF: the National e-Invoicing System and the smallest businesses
Another formal area is the National e-Invoicing System (KSeF). Under the Ministry of Finance schedule, KSeF has been mandatory since 1 February 2026 for large businesses and for receiving invoices, and since 1 April 2026 for other businesses, except the smallest ones. From 1 January 2027 the obligation to issue invoices in KSeF will cover all taxpayers. Only until 31 December 2026 can invoices be issued outside KSeF if the total gross value of sales documented with such invoices in a given month does not exceed PLN 10,000. Details are available in the implementation schedule on ksef.podatki.gov.pl and the notice of the Tax Administration Chamber in Wrocław of 9 October 2026.
Although KSeF is mainly associated with accounting and VAT, this change matters directly for HR departments and employee settlements:
- Invoices for employee benefits: from 1 January 2027, training services, medical subscriptions, sports cards and purchases under non-wage benefit programmes, including from the smallest subcontractors, will be documented with structured invoices issued in KSeF.
- Settlements with HR service providers: the smallest entities providing advisory, recruitment or training services will issue invoices in KSeF, which requires adapting cost approval procedures and document flow in the HR department.
Managing the benefits budget effectively in times of change
With fixed labour costs rising, traditional rigid packages of employee perks become budget-inefficient. Employees have different needs, and offering everyone the same package wastes part of the money.
Implementing the flexible Nais benefits platform allows an organisation to:
- Optimise spending: ZFŚS funds or the company's own funds go directly to employees' virtual cafeteria accounts, giving them freedom to choose their benefit.
- Stay compliant: the system supports applying the social criterion when spending social funds.
- Reduce the administrative burden: automated reporting and distribution remove paper applications, letting HR focus on strategic tasks.
Practical HR and payroll checklist for December
To avoid mistakes in the first payroll of the new year, it is worth completing the following control steps:
- Review base salaries: check the list of employees on employment contracts and identify those earning below PLN 4,950 gross in order to prepare annexes or amending agreements from 1 January 2027.
- Audit civil-law (mandate) contracts: review contracts with contractors to guarantee a minimum hourly rate of at least PLN 32.30 gross.
- Update derived rates: enter the new minimum wage (PLN 4,950) in the HR and payroll system for calculating night work allowances and the minimum benefit basis.
- Update the ZUS 30x cap: enter the annual cap of PLN 300,990 for 2027 in the HR and payroll system (Monitor Polski 2026, item 1098) and reset the pension and disability contribution counters from 1 January.
- ZFŚS procedure for the new year: if you want to opt out of creating the fund or paying the holiday benefit, prepare the relevant information for employees or arrangements with staff representatives in line with the applicable rules.
- Check the social criterion: start collecting up-to-date declarations on the financial situation of those eligible for the social fund on the Nais platform.
- KSeF readiness audit: prepare for the fact that from 1 January 2027 all suppliers, including the smallest training and HR service providers, will issue invoices in KSeF, and review with the finance department the flow of cost documents and invoices for benefits and HR services.
- Monitor the new PIT scale act: follow the President's decision and any publication of the act in the Journal of Laws, without changing how tax advances are calculated before it is published and enters into force.
Frequently asked questions
1. Is the PLN 4,950 gross rate final?
Yes. The minimum wage (PLN 4,950) and the minimum hourly rate (PLN 32.30) have been published in the Journal of Laws (Journal of Laws 2026, item 1213) and apply from 1 January 2027. This is a 3% increase compared with 2026, when the minimum wage is PLN 4,806.
2. What is the ZUS 30x cap for 2027?
The cap is PLN 300,990 and is already official. It was announced by the Minister of Family, Labour and Social Policy in a notice of 3 November 2026 (Monitor Polski 2026, item 1098). The amount equals thirty times the forecast average wage, set at PLN 10,033. In 2026 the cap is PLN 282,600.
3. What ZFŚS write-off should be used in the 2027 budget plan?
The 2027 write-off amount will be announced. For comparison and preliminary calculations, it is worth remembering that in 2026 the basic write-off is PLN 2,943.23.
4. Should payroll software already include the new PIT scale (12/24/32%)?
No. The act introducing the new tax scale was passed by the Sejm on 5 November 2026 and adopted by the Senate without amendments on 6 November 2026, but as of 9 November 2026 it has not been signed by the President or published in the Journal of Laws. It is therefore not in force and is not a basis for changes to payroll systems. Until then, tax advances should be calculated under the current rules.
5. How does extending KSeF to the smallest businesses affect HR?
From 1 January 2027 all taxpayers, including the smallest businesses, must issue invoices in KSeF. Invoices for employee benefits, training or services from the smallest subcontractors and HR service providers will therefore reach the company through KSeF, through which receiving invoices has been mandatory since 1 February 2026. It is worth coordinating invoice approval processes with the accounting department before the end of the year.
Legal basis and sources
- Council of Ministers Regulation of 14 September 2026 on the minimum wage and the minimum hourly rate in 2027 (Journal of Laws 2026, item 1213).
- Council of Ministers Regulation of 11 September 2025 on the minimum wage and the minimum hourly rate in 2026 (Journal of Laws 2025, item 1242).
- Notice of the Minister of Family, Labour and Social Policy of 3 November 2026 on the cap on the annual basis for pension and disability contributions in 2027 (Monitor Polski 2026, item 1098).
- Notice of the Minister of Family, Labour and Social Policy of 19 November 2025 on the cap on the annual basis for pension and disability contributions in 2026 (Monitor Polski 2025, item 1206).
- Government bill amending the Personal Income Tax Act, the Corporate Income Tax Act and the Act on flat-rate income tax on certain income earned by natural persons, Sejm print 3293, together with the course of the legislative process on the Sejm website and the voting result on the Senate website.
- Ministry of Finance: "Etapy wdrożenia KSeF 2.0" (KSeF 2.0 implementation stages), ksef.podatki.gov.pl; Tax Administration Chamber in Wrocław: "Krajowy System e-Faktur (KSeF) – III etap wdrożenia od 1 stycznia 2027 r." (KSeF – stage III of implementation from 1 January 2027), 9 October 2026.
Legal disclaimer
This article is for information only and does not constitute legal or tax advice. It describes the legal position as of 9 November 2026, based on the official sources listed above. The rules, in particular those on the PIT tax scale, may change after that date. Before making HR, payroll or tax decisions, check the current wording of the law in the Journal of Laws (Dziennik Ustaw) and Monitor Polski, or consult a tax adviser or lawyer.
