en

New regulations on transparency of remuneration in the recruitment process

From 24 December 2025, recruitment rules will change.

The amendment to the Labour Code introduces the obligation to disclose remuneration at the job advertisement stage. It also changes the way advertisements are formulated – they must be gender-neutral and free from any suggestions regarding the preferred gender of the candidate.

What does this mean for employers?

  • the need to review work and remuneration regulations,
  • update job titles,
  • adapt the recruitment process to the new requirements,
  • and prohibit asking candidates about their previous earnings.

This is the last moment to prepare your company for the upcoming changes.

An analysis with recommendations from expert Dr Joanna Łukaszczuk can be found at: https://tiny.pl/jmj-mwx5

 

Political agreement on abolishing the €150 threshold for e-commerce shipments – changes as early as 2026?

The political agreement of 13 November 2025 accelerates the end of the EUR 150 threshold for e-commerce shipments – EU institutions announce a temporary customs collection mechanism as early as 2026, ahead of the launch of the EU Customs Data Hub in 2028.

At the same time, it should be remembered that the EUR 150 threshold still applies today, and the agreement itself does not yet have the status of a legal act amending Regulation 1186/2009 – the adoption and publication of the relevant regulation in the Official Journal of the EU will be crucial.

Customs expert Rafał Wojciechowski shows what this change means for e-commerce platforms, importers and consumers, what competitive and compliance risks lie behind the reform, and why businesses should start preparing now for the new model of clearing low-value shipments.

Read more in the article on Lexplorers: https://lnkd.in/dddrTivX

Flavourings with alcohol. CJEU: it is the intended purpose that counts, not the actual use

Excise Duty Wednesdays

The Court of Justice of the European Union (Case T-614/24, AROCO, 22 October 2025) clarified the application of Article 27(1)(e) of Directive 92/83/EEC.

The Court ruled that the exemption from excise duty for flavouring substances containing alcohol cannot be made conditional on proof of their actual use in beverages with an alcohol content of ≤1.2%.

It is sufficient that the products are intended for the production of food or non-alcoholic beverages – the mere intention to use them for this purpose is sufficient.

This ruling reduces the burden of proof for manufacturers and distributors of flavourings and limits the risk of disputes with customs authorities.

A new definition of workplace bullying is on the horizon – what will change for employers?

The government is finalising work on a draft amendment to the Labour Code, which redefines the concepts of mobbing and discrimination.

The changes are intended to tighten regulations and provide greater protection for employees, but for companies they mean that they will have to adapt their rules and procedures within six months of the law coming into force.

The most important changes:

  • a new definition of mobbing, which also covers unintentional actions,
  • the introduction of the concept of discrimination by association and assumption,
  • minimum compensation – at least three times the minimum wage,
  • the obligation to update work regulations and anti-mobbing policies.

Any unclear situation in employee relations may now result in a higher risk of claims.

A full analysis and recommendations from experts can be found at: https://tiny.pl/pjxrtsyg

Lubricating oil ‘returns’ to another warehouse? – without excise duty suspension

#excise

The Director of the National Revenue Information Service (18 September 2025, 0111-KDIB3-3.4013.184.2025.2.MAZ) explained that excise goods can only be returned to the same tax warehouse from which they were originally released.

The transfer of lubricating oils from the user to another warehouse is not a ‘return’ within the meaning of the Act and cannot be covered by the excise duty suspension procedure, even if the oils are expired or unused.

Businesses should verify their warehouse network and logistics routes to avoid violations of e-DD documentation requirements.

Employment of foreign students and graduates in Poland: between simplifications and tighter controls

The employment of foreign students and graduates of Polish universities in 2025 is a topic fraught with new challenges and legislative changes.

Simplified procedures for students and graduates improve access to the labour market, but stricter Border Guard controls and new document verification requirements impose additional obligations on employers.

In a new article on Lexplorers, Dominika Cząstka, LL.M., explains the key aspects of legal employment, the consequences of the new regulations and the risks associated with incorrect documentation of student or graduate status.

This is a must-read for all employers who hire foreigners or plan to recruit students from abroad.

Link to the article: https://tiny.pl/pmg2dw3m

NSA RULING: Aircraft engine servicing – fuel exempt for MRO services

The Supreme Administrative Court (20 March 2025, I FSK 1742/21) confirmed that fuel consumed during testing, maintenance and repair of aircraft engines is exempt under Article 32(1)(1) in conjunction with Article 32(2) of the Excise Duty Act, provided that the activity is commercial in nature and is performed for a third party.

This is good news for the MRO (Maintenance, Repair & Overhaul) sector – fuel used during tests commissioned by the customer and invoiced falls within the scope of the exemption. It is worth analysing service contracts and the method of documenting fuel consumption in terms of meeting the conditions of commerciality.

This can be done with an excise duty expert, tax advisor Dominika Kamińska.

Withholding tax on intermediary services – change in the approach of the Supreme Administrative Court

The Supreme Administrative Court changes the rules of the game in withholding tax on intangible services.

The latest ruling of the Supreme Administrative Court may radically change the way tax authorities classify payments for intangible services provided by foreign entities.

The court clearly stated that it is not the name of the contract that matters, but the actual nature of the service provided. The line between intermediation and consulting or advertising is becoming increasingly blurred, and the tax risk for companies is growing. In our latest alert, we discuss the implications of the Supreme Administrative Court’s ruling, how it may affect entrepreneurs, and what steps should be taken to protect oneself.

Read the analysis below by Mariusz Tkaczyk, tax advisor, and Aneta Skowron, solicitor: https://tiny.pl/9x1dctxd

No more paper applications to the Social Insurance Institution (ZUS)

The change comes into force tomorrow – 4 November 2025.

From now on, entrepreneurs no longer need to print and store paper copies of their Social Insurance Institution (ZUS) notifications. This marks the end of unnecessary bureaucracy and another step towards the full digitisation of HR and payroll documentation.

What does this mean in practice?

  • Fewer administrative duties,
  • lower costs and fewer errors,
  • greater data security,
  • consistency with the document circulation digitisation process.

This is a good time to update your archiving procedures and policies and prepare your HR team for the new application handling model.

Full alert and commentary from GWW experts at: https://tiny.pl/6p000p3m

Energy recovery without new excise duty obligations

According to current case law and the interpretation of Article 11(2) of the Excise Duty Act, electricity recovered through recuperation does not constitute a new volume of energy subject to taxation.

Excise duty arises only when the electricity is released by the distribution system operator, i.e. when its quantity and value are actually settled. The energy fed into the grid (recovered) is in fact the same energy that was previously consumed, so there is no new generation within the meaning of the Act.
This approach confirms the favourable position for railway companies and traction system operators who recover energy from vehicle braking.
If your company settles electricity based on the recuperation process, it is worth verifying the method of calculating excise duty and the documentation from the DSO.

Need advice? Contact our experts Sebastian Gumiela and Dominika Kamińska.

Translated with DeepL.com (free version)