Dear Sir or Madam,
Below you will find an overview of the key legislative changes currently underway (as of September 2026) that are of particular importance to businesses, including employers and those involved in product manufacturing and distribution.
1. Amendment to the Commercial Companies Code – reduced formalities and broader use of electronic communication
On September 4, 2026, the Sejm passed an act amending the Commercial Companies Code (hereinafter the “CCC”), aimed at reducing formal requirements primarily in the operation of limited liability companies and adapting legal regulations to modern electronic communication standards. The bill has been referred to the Senate, with the deadline for its consideration expiring on October 4, 2026.
One of the key changes to the CCC will be the option for a shareholder to consent to receiving notices of shareholders’ meetings in documentary form, rather than exclusively in written form as is currently required. This solution is intended to facilitate communication with shareholders via email or other electronic means of communication.
The required form of power of attorney to participate in a limited liability company’s shareholders’ meeting is also set to change. By default, it may be granted in documentary form, unless the articles of association stipulate stricter requirements. An analogous solution has been provided for powers of attorney in a simple joint-stock company.
In practice, this means a further move away from the requirement to use documents bearing a handwritten signature wherever electronic communication can be used.
We will keep you updated on an ongoing basis regarding the entry into force of these amendments to the CCC.
2. New obligations regarding equal pay for men and women
Draft Bill UC127 is also currently under consideration, aiming to transpose into the Polish legal system Directive (EU) 2023/970 of the European Parliament and of the Council on pay transparency and strengthening the application of the principle of equal pay for equal work or work of equal value between men and women. The current version of the draft bill was published on May 25, 2026, and its adoption by the Council of Ministers is scheduled for the fourth quarter of 2026.
The draft bill provides for a number of new obligations for employers. Specifically, the following measures are planned:
- introducing an obligation to provide employees with information on pay-setting rules and the criteria used to determine pay levels and pay progression,
- granting employees the right to obtain information regarding their individual pay level and average pay levels for comparable categories of employees,
- introducing obligations to prepare gender pay gap reports,
- establishing additional mechanisms to address unjustified pay disparities.
The obligation to prepare gender pay gap reports is to apply to employers with at least 100 employees. For employers with 100 to 249 employees, reporting is to be conducted every three years, whereas employers employing at least 250 employees will be required to submit such information annually.
Another key measure will be the joint pay assessment mechanism. The obligation to conduct it will arise, among other instances, when a pay gap of at least 5% occurs in a given category of employees that cannot be justified by objective and gender-neutral criteria, and the employer fails to remedy the unjustified disparity within 6 months
The aforementioned draft bill remains at the stage of the government legislative process, and we will keep you updated on its progress.
3. New rules on liability for defective products – including software and AI systems
Another significant change set to enter our legal system is Draft Bill UC163, currently under consideration, regarding amendments to the Civil Code and the Code of Civil Procedure in connection with the implementation of Directive (EU) 2024/2853 of the European Parliament and of the Council on liability for defective products. The draft bill was published on August 25, 2026, and its adoption by the Council of Ministers is scheduled for the fourth quarter of 2026.
The planned changes are intended to significantly overhaul the current product liability regime. The draft bill provides for the repeal of the existing Articles 449¹–449¹⁰ of the Civil Code and their replacement with a new set of provisions—Articles 449¹²–449²⁷ of the Civil Code. Simultaneously, a new Section IVh, comprising Articles 479¹³⁰–479¹³⁵, is to be added to the Code of Civil Procedure.
In particular, the draft bill provides for:
- expanding the definition of a product to also cover, among other things, software;
- considering the specific nature of products incorporating digital components and artificial intelligence systems;
- expanding the scope of entities that may be held liable for damage caused by a defective product;
- expanding the scope of protected interests;
- introducing new mechanisms to facilitate the pursuit of claims by injured parties, including the right to request disclosure of evidence and specific presumptions of product defectiveness and causation.
The above-mentioned changes will be of particular significance for manufacturers, importers, distributors, and businesses offering products containing digital elements or software.
The new regulation is intended to implement Directive 2024/2853, which provides for the application of the new rules to products placed on the market or put into service after December 8, 2026. Member States, in turn, are to adopt provisions implementing the Directive by December 9, 2026.
We will keep you updated on the further legislative progress of the aforementioned draft bill.
Should the topics outlined above be of interest to you, we encourage you to contact our Law Firm.