Every employer must train an employee in health and safety (BHP) before allowing them to work, and then repeat the training periodically. This follows from Article 237³ of the Labour Code, while the details — types of training, frequency and documentation — are set out in the training regulation of 2004 (consolidated text: Journal of Laws 2024, item 1327). The time of the training is working time, and its cost is covered by the employer. Since December 2025, participation in the instruction can also be confirmed electronically.
Who is covered by the obligation
The obligation covers employees under an employment contract (umowa o pracę), as well as apprentices in practical vocational training and students on internships. The training must also be completed by the employer themselves — within the scope needed to perform their duties, with periodic refreshers. An entrepreneur employing up to 10 people (or up to 50 people in an industry with a risk category no higher than third) who has completed the appropriate training may perform the tasks of the H&S service themselves, including delivering general instruction.
Initial training: two instruction sessions before the start
- General instruction — for each new hire, before being admitted to work. It covers the basic H&S provisions from the Labour Code and from internal rules, the rules applicable in the workplace and first aid. It is delivered by an H&S service employee, by the employer who performs its tasks or by a designated employee with a valid periodic training.
- Workplace instruction — for employees in manual positions and other positions where harmful, burdensome or dangerous factors occur, as well as when being transferred to such a position. It introduces the hazards and the safe methods of work at the specific position; it is repeated when the technology or machines change significantly.
Initial training is not required when the employee concludes a new employment contract with the same employer and returns to the position held immediately before.
Periodic training — how often
| Group of positions | First periodic training | Subsequent — no less often than |
|---|---|---|
| manual positions involving particularly dangerous work | within 12 months of starting work | once a year |
| other manual positions | within 12 months | once every 3 years |
| employers and managers of employees (managers, foremen, team leaders) | within 6 months | once every 5 years |
| engineering and technical employees, H&S service | within 12 months | once every 5 years |
| administrative and office positions | within 12 months | once every 6 years (unless the exemption applies) |
Periodic training for manual workers takes the form of instruction, and for other groups — a course, seminar or guided self-study. It ends with an exam and a certificate, a copy of which goes into the personnel file.
Exemption for office workers
The Labour Code exempts administrative and office workers from periodic training if the employer's predominant activity falls into a group with a risk category no higher than third (under the accident insurance regulations) — unless the occupational risk assessment indicates that training is necessary. If the risk category rises or the risk assessment shows such a need, training must be delivered within 6 months. The exemption does not cover the general instruction on hiring.
Documentation — what changed in 2025
The amending regulation of 24 November 2025 allowed confirmation of general and workplace instruction and admission to work in paper or electronic form:
- in the paper version, signatures are placed in the initial training card,
- in the electronic version the employer makes a note in the card in the place of the signature and attaches an electronic document with the confirmation or its reproduction,
- the initial training card together with its attachments is kept in the employee's personnel file.
An employer who organises the training themselves also keeps its documentation: training programmes, class diaries, examination minutes and the register of certificates issued. The employee may confirm familiarisation with the regulations and the rules of H&S also in paper or electronic form.
Who can deliver training and how much it costs the company
Training is organised by the employer or — on their order — by an H&S training unit. The training of the employer themselves and of the H&S service staff is delivered only by such units. From a tax perspective:
- the expense on mandatory training is a cost of running the business,
- training delivered in forms and on terms set out in separate regulations is exempt from VAT as vocational training, so the invoice from a training company usually does not include VAT; services such as risk assessment or permanent H&S support are taxed separately.
Example: a small service company
Mr Piotr runs an installation company and employs two fitters and one office worker. He has completed the training for employers performing H&S service tasks, so he conducts the general instruction of each new employee himself. He conducts the workplace instruction of the fitters before their first trip to the construction site and collects the confirmations electronically, attaching them to the cards in the personnel files. The fitters undergo periodic training at the latest after 12 months, and then every 3 years. The office worker — if the company's predominant PKD has a risk category up to the third and the risk assessment does not require it — does not have to attend periodic training.
Most common shortcomings
- Instruction "after the fact" — the employee starts work on Monday and signs the initial training card after a week. The regulations require training before admission to work.
- Expired periodic training — the deadlines are counted from the start of work in the position and from the previous training; it is worth keeping a simple register with dates.
- No training for the employer themselves — an entrepreneur who delivers the general instruction must have an up-to-date training.
- Automatic use of the office exemption — without checking the risk category for the predominant PKD and without an up-to-date occupational risk assessment.
- One programme for everyone — training programmes should match the groups of positions and the real hazards in the company.
Penalties and risks
Failure to comply with H&S regulations or rules may result in a fine from PLN 2,000 to PLN 60,000 for the person responsible for H&S or for managing employees. The lack of training also matters in case of an accident at work — it hampers the employer's defence in post-accident proceedings and in any employee claims.
How Good Balance can help
We help to tidy up HR documentation, including initial training cards and the deadlines for periodic training in personnel files. The details of HR services are described on the employee services page, and for the interpretation of labour-law provisions we invite you to HR advisory services. The rules of employment on an employment contract are recalled in the article on the employment contract.