Hundreds of contracts per month, high turnover, employees from several continents, and government agencies that will accept applications exclusively online starting June 1, 2025. Here’s how a temporary staffing agency can sign contracts with employees and foreign nationals entirely remotely—legally and without a printer.
A temporary staffing agency hires employees on its own behalf and assigns them to client companies. In practice, this means a monthly flood of documents: temporary employment contracts, service agreements, addenda, medical examination referrals, and information on terms of employment. Given the high turnover typical of this industry, paperwork becomes a real cost—couriers shuttling between branches, delayed work clearances, incomplete files, and a growing archive.
The second challenge is foreigners. As of June 1, 2025, the entire process of legalizing employment moved online, and at the same time, penalties for procedural errors—including the lack of a written contract—were increased. The paradox is that while the official process is now fully digital, many agencies continue to print contracts simply because „that’s how it’s always been done.” Below, we show how to complete the digitization process in accordance with the regulations—separately for each type of contract, since the requirements differ significantly.
Temporary employment contracts are governed by the Act of July 9, 2003, on the Employment of Temporary Workers (consolidated text: Journal of Laws 2025, item 236). Pursuant to Article 13 The contract specifies the parties, the date of execution, the user employer, the duration of the temporary work, and the terms of employment—the type of work, hours of work, place of work, and compensation.
As for the form, the law states explicitly: An employment contract must be in writing. If the contract was not concluded in writing, the agency must confirm the terms of the contract to the temporary employee in writing no later than the second day of temporary work (Art. 13, para. 4). This rule is more lenient than in „regular” employment—Art. 29, § 2 of the Labor Code requires confirmation even before the employee is allowed to begin work. Important: a contract concluded without being in writing remains valid, but failure to confirm the terms and conditions within the prescribed time limit constitutes a violation of the employee’s rights, punishable by a fine of between 1,000 and 30,000 PLN (Article 281, § 1, point 2 of the Labor Code, as applied to agencies in their capacity as employers).
Key message for digital transformation: "written form" does not mean "paper". Pursuant to Article 78¹ § 2 of the Civil Code, a declaration of intent made in electronic form—that is, signed with a qualified electronic signature—is equivalent to a declaration made in writing, and Article 29 § 2 of the Labor Code explicitly permits electronic employment contracts. Condition: Both parties must have a QES, or qualified electronic signature — a representative of the agency and a temporary employee. In that case, the contract can be signed remotely even before the first day of work, without the need for scans or couriers.
Yes—and this is a huge relief for employment agencies, where a large portion of the staff works under civil law contracts. The Civil Code does not specify any form for a contract of mandate (Art. 734 et seq. of the Civil Code). It may be concluded in writing, electronically, in a documented form (e.g., acceptance on a platform, email exchange, SMS code), or even orally—and it is valid in each of these forms.
However, it's worth distinguishing between two things: legal obligation and evidentiary weight. QES is not mandatory for a contract, but it provides what a written document cannot: reliable identification of the signer, integrity of the content (neither party can change the rate after the fact), and a reliable date. In the event of a dispute over compensation, or an audit by ZUS or PIP, this is an irrefutable argument. A reasonable model for agencies therefore looks like this: bulk contracts with Polish contractors—using a platform and a written document, with the agency providing a qualified electronic signature; higher-risk contracts—QES from both parties.
📌 Note: The flexibility regarding the form of a contract of employment ends when the employee is a foreign national whose work requires a permit or declaration. In such cases—regardless of the type of contract—the law requires that the contract be in writing. Details are provided below.
June 1, 2025. Two acts dated March 20, 2025, have entered into force: on the conditions for employing foreign nationals (Journal of Laws 2025, item 621) and on the labor market and employment services (Journal of Laws 2025, item 620). For employment agencies, this is the most significant change in regulations in years.
Applications for work permits i declarations authorizing the performance of work consists of exclusively electronically via the praca.gov.pl portal — documents submitted by other means will not be processed. The application and attachments must be electronically signed by an authorized representative using a qualified electronic signature, a trusted signature, or a personal signature. With dozens of applications per month, QES is the most convenient option—it also works outside of government systems, such as when signing a contract. We explain the differences between these tools in the article with a trusted profile and a qualified digital signature.
Declarations (the faster track without a labor market test) currently apply to citizens Armenia, Belarus, Moldova, and Ukraine — As of December 1, 2025, they no longer apply to Georgia. Work under these permits may last up to 24 months, and the fee for filing the declaration is 400 zł.
An entity that assigns work to a foreign national is required to enter into a written agreement with him before allowing him to work, under terms consistent with the permit or declaration. Before signing, the foreign national must be provided with a copy of the agreement in a version intended for him or her understandable — According to the position of the National Labor Inspectorate, the translation must be prepared by a certified translator listed by the Minister of Justice. The contract, together with the translation, must be retained for the entire duration of the foreign national’s employment, and 2 years from the end of the calendar year in which the legal relationship ceased.
Organizational Update: A copy of the signed agreement is submitted to the office (the person who issued the permit or accepted the statement) via praca.gov.pl before starting work. The system will support this requirement starting July 1, 2025, for declarations and seasonal permits, and starting August 1, 2025, for all other permits.
And again: an electronic contract with a qualified electronic signature (QES) from both parties also satisfies the written form requirement—and in a fully digital administrative process, this is the natural choice, because an electronic contract is immediately ready to be submitted through the portal.
Illegal subcontracting — and the new law also includes the following under this category Assigning work without a written contract — is subject to a fine of 3,000 to 50,000 PLN, imposed in proportion to the number of foreign nationals (at least 3,000 PLN per person). Failure to comply with reporting obligations (e.g., reporting the start of employment based on a declaration within 7 days or reporting that employment has not commenced within 14 days) is punishable by a fine of up to 5,000 PLN.
The agency's operations still require registration with KRAZ (National Register of Employment Agencies), administered by provincial marshals; the fee has increased to 1,000 PLN, and paper certificates are no longer issued (previously issued certificates remain valid until they are removed from the registry). The most important restriction: placing foreign nationals who require a permit or declaration in temporary employment is possible only 2 years after entry in the registry (Article 305(3) of the Act on the Labor Market and Employment Services). The Act also took aim at labor outsourcing: entrusting work performed for a third party to an entity that is not a temporary employment agency is subject to a fine of at least 6,000 PLN per person.
Since an electronic contract requires a QES from both parties, a practical question arises: where does an employee from Ukraine, the Philippines, or Colombia get their signature? Trusted profile out of the question — it requires the PESEL number and Polish verification. A qualified digital signature, on the other hand, can be issued based on a passport, without PESEL and without having to go to the office.
The fastest way is SimplySign QES with IDnow video verification: The operator verifies the foreign national's identity during a video call conducted in Polish or English, and the certificate is sent to the mobile app—no card reader or card required. A certificate valid for 1, 2, or 3 years costs 299, 389, or 479 zł, respectively, and IDnow video verification costs 2,100 zł. We describe the entire process step by step in our guide How can a foreigner obtain a qualified digital signature online?, and we have compiled a list of typical situations in which a foreigner needs an e-signature in a practical guide.
There are two additional options worth knowing about. First, according to eIDAS (EU Regulation 910/2014, Art. 25(3)) A qualified electronic signature issued in one EU country is recognized in all others—so an employee from Romania or Spain can sign a Polish contract using their national QES. Second, if a foreign national is unable to provide an e-signature in time, there is nothing preventing you from printing the contract and having them sign it by hand, while completing the rest of the process digitally—more in the post About Foreigners and Qualified Digital Signatures in Poland.
A well-designed process distinguishes between different types of documents—not everything requires the same level of formality:
| Document | Required format | How to Sign Digitally |
|---|---|---|
| Temporary Employment Contract | in writing (Article 13(4) of the Temporary Employees Act) | Agency QES + Employee QES |
| Contract for Services with a Polish Contractor | any | documentary form (platform) or QES for evidentiary purposes |
| Contract with a foreign national covered by a permit/declaration | in writing, before being cleared to work | QES for both parties (for a foreign national: SimplySign QES with IDnow) |
| Application for a Permit/Declaration | exclusively online (praca.gov.pl) | QES, trusted signature, or personal signature |
| Digitization of files for e-records | digital representation | QES or the agency's qualified seal |
On the agency's end, a mobile signature is all that's needed SimplySign For people signing contracts—it runs in the cloud, from a phone or computer, and allows you to sign documents in bulk. We discuss just how intensively you can use it in this article About the limits of a qualified digital signature. Mixed scenario—one party signs electronically, the other by hand—we'll discuss this here.
Digital contracts are best supplemented with electronic employee records. According to Articles 94⁸–94¹² of the Labor Code Electronic files are fully equivalent to paper files. The digitization of existing files involves creating a digital copy (scan) accompanied by QES or the agency's qualified digital signature — with thousands of pages, it can be more convenient qualified seal SimplySign, and employees must be informed that they can request a paper copy within 30 days. Records for employees hired since 2019 are kept 10 years from the end of the calendar year in which the employment relationship ended. There is one more provision that is important for the agency: if the same person is rehired within 10 years Her existing documentation is being continued — and this is an everyday occurrence in the temporary staffing industry. Starting January 27, 2026, the Labor Code will also allow for the electronic submission of more than a dozen HR forms, so the e-file will no longer be a hybrid. Before you scan your archives, read our guide On the Digital Archiving of Contracts.
The law not only allows employment agencies to fully digitize contracts—following the 2025 amendments, it actually requires them to do so, moving the legalization of foreign workers’ employment entirely online and increasing penalties for formal errors. The key is to choose the right form for the type of contract.
As authorized partner Certum We provide employment agencies with qualified digital signatures for coordinators and recruiters, organize the remote issuance of QES certificates to foreign nationals (IDnow video verification in Polish or English), and help set up a qualified digital seal for digitizing records.
📞 +48 22 417 05 55 | ✉️ [email protected] Advisors are available at the offices in Warsaw, Krakow, Wrocław, and Radom — as well as online or at a location of your choice.
Related products:
Contracts requiring written form—such as temporary employment contracts and contracts with foreign nationals covered by a permit or declaration—are signed electronically using a qualified electronic signature (QES) by both parties; this form is equivalent to the written form (Art. 78¹ of the Civil Code). Service contracts with Polish service providers may be concluded in document form, e.g., via a platform. A foreign national can obtain a QES remotely via SimplySign with IDnow video verification.
Yes. The Civil Code does not require a specific form for a contract of mandate, so a contract concluded via email, through a platform, or by text message is valid. A Qualified Electronic Signature (QES) is not mandatory, but it strengthens the agency’s evidentiary position: it confirms the identity of the signatories, the integrity of the content, and the date. Exception: a contract with a foreign national requiring a permit or declaration must be in writing.
Effective June 1, 2025, the contract must be concluded in writing (or electronically with a Qualified Electronic Signature [QES] from both parties) before the foreign national is permitted to work, after providing them with a translation into a language they understand. A copy of the contract must be submitted to the authorities via praca.gov.pl before the foreign national begins work. Employing a foreign national without a written contract constitutes illegal employment—a fine ranging from 3,000 to 50,000 PLN.
All you need is a valid passport and IDnow video verification: the operator verifies your identity during a video call in Polish or English, and the SimplySign certificate is sent to the mobile app. The entire process takes place online, without PESEL or a visit to a service center. EU citizens can also use a QES issued in their home country—in accordance with eIDAS, it is recognized throughout the EU.
Yes—an electronic document bearing the qualified electronic signatures of the agency and the employee satisfies the required written form. If the employee does not have a QES, the contract concluded otherwise remains valid, but the agency must confirm the terms and conditions to the employee in writing no later than the second day of temporary work (Article 13(4) of the Act on the Employment of Temporary Workers).
