Until the act is enacted, the applicable law changes nothing: working pensioners currently pay the disability pension contribution on general terms, at a combined rate of 8%, of which 1.5% is financed by the employee and 6.5% by the employer.
In the cited cases, the exemption applied to revenues not exceeding PLN 85,528 in the tax year, and the benefits listed in Art. 21(1)(154) of the Personal Income Tax Act preclude use of the exemption.
Working pensioners will not receive any additional benefit — the bill submitted under the name "15th pension" is in essence a contribution-relief proposal, consisting of exempting seniors from financing their own portion of the disability pension insurance contribution, amounting to 1.5% of the assessment basis. The legal issue is therefore the modification of the contribution obligation set out in the Act of 13 October 1998 on the social insurance system (consolidated text announced by the Marshal of the Sejm on 9 February 2026), in particular the provisions on old-age and disability pension insurance contributions (Art. 16, Art. 17 et seq.).
The essence of the proposed regulation boils down to several elements:
Exemptions from paying contributions constructed in this manner are addressed by Art. 15 of the Act on old-age and disability pensions from the Social Insurance Fund (consolidated text of 7 November 2025), which takes into account periods covered by an exemption from paying contributions when determining the insurance record — should the bill be enacted, it would be necessary to assess whether the contribution savings would affect the verification of contribution periods. The real value of the benefit depends on earnings: at a gross salary of PLN 5,000 it is PLN 75 per month (PLN 900 per year), at PLN 10,000 gross — PLN 150 per month (PLN 1,800 per year), and at the 2026 minimum wage (PLN 4,806 gross) — PLN 72.09 per month (PLN 865.08 per year). The bill is criticized for its tax consequence: the final net increase will not be identical to the contribution amount, as it depends on the settlement of income tax and the health insurance contribution. Individual interpretations concerning the exemption for working seniors (e.g. 0115-KDIT2.4011.409.2026.3.ŁS, 0114-KDIP3-2.4011.8.2026.3.JK3, 0114-KDWP.4011.44.2026.1.AS) demonstrate the methodology by which the authorities assess similar reliefs: the right to the exemption belongs to a taxpayer covered by a title to social insurance, the provision does not differentiate by that title, and the exemption is capped — in the cited cases it applied to revenues not exceeding PLN 85,528 in the tax year. These rulings also indicate that the benefits listed exhaustively in Art. 21(1)(154) of the Personal Income Tax Act preclude use of the exemption — analogous exclusions may be carried over to the construction under discussion.
The scenarios for the further course of proceedings are at this point dependent solely on the legislative process:
In practical terms, the issue concerns several hundred thousand working pensioners and the state budget, which would assume the cost of approximately PLN 480 million per year.
May a healthcare provider financed by the NFZ (National Health Fund) commission the performance of genetic tests (including whole-exome sequencing) to a foreign entity — including one outside the EU — without notifying the subcontractor to the Fund and without informing the patient about the transfer of biological material and genetic data, and does such conduct violate the provisions on healthcare services and the GDPR?
I rely here on general principles of law, as the database does not contain the direct text of the provisions. Under the Act of 27 August 2004 on healthcare services financed from public funds (Art. 9 and Art.
15), the healthcare provider enters into an agreement with the NFZ and is responsible for the provision of services in accordance with its terms; the agreement with the regional (voivodeship) branch of the Fund specifies the rules for entrusting part of the scope of services to subcontractors, and the Supreme Audit Office (NIK) established that the INNGEN agreement permitted subcontracting only of an incomplete scope of services — entrusting the entire WES test to a German entity outside the list of subcontractors therefore means the service was performed on terms not covered by the agreement, which creates the risk of verification and suspension of reimbursement under Art. 15(5) of that Act. In parallel, Art.
9(1) GDPR classifies genetic data as special categories of data whose processing is permissible inter alia where the data subject has given explicit consent, while Art. 13 and 14 GDPR require information to be provided about recipients of data and about transfers to a third country (Art. 44 GDPR prohibits transfers without ensuring an adequate level of protection); the failure to inform the patient that the sample was sent abroad therefore constitutes a breach of the information obligations and, as a rule, the absence of a lawful basis for the transfer.
The provider's argument that "the result was issued by a Polish laboratory, so the service was performed in Poland" is now clearly weakened — the NIK has documented the practice (337 WES tests performed by the German subcontractor in 2023–2025, settled with the Lublin branch of the NFZ without notification), which the Fund may treat as improper performance of the agreement and demand reimbursement or terminate the agreement, while the patient whose sample left the country without being informed has strong grounds for a complaint to the President of the Personal Data Protection Office (UODO) for breach of Art. 13–14 and Art. 44 GDPR, with the risk of an administrative fine of up to EUR 20 million or 4% of global turnover (Art.
83(5) GDPR). In practical terms: laboratories outsourcing sequencing abroad should immediately update their lists of subcontractors with the NFZ, verify whether the agreement permits entrusting the full scope of the test at all, and implement an information clause and separate patient consent for the transfer of biological material and genetic data (ideally indicating the recipient country), and in the case of a transfer to a third country — secure a basis under Chapter V GDPR (standard contractual clauses or a Commission adequacy decision). The evidential risk on the part of the facilities is real, as the NIK indicated that the state does not know the scale of the phenomenon, which foreshadows further audits and tightened settlement requirements by the NFZ.
In the case of a referendum on the recall of an organ of a unit of local self-government, the announcement of results deciding on the recall means, pursuant to Article 67(1) of that Act, the termination of the activity of the recalled organ — in a municipality (gmina), this means the termination of the legislative organ and, by operation of law, of the executive organ.
A protest that is upheld invalidates the referendum if the breach of the provisions could have had a significant impact on its result (Article 66(1)), and until the protest is resolved, early elections are not ordered (Article 67(5)).
The residents of Częstochowa will decide in a referendum on Sunday whether to recall the city's mayor, Krzysztof Matyjaszczyk, and the city council — and the outcome of the vote will have direct systemic effects provided for in the Act of 15 September 2000 on local referendum. If, however, turnout or the result does not lead to a recall, the current city authorities remain in office. The legal issue is the validity and effects of a recall referendum conducted under the Act on local referendum, in particular Article 67, Article 66 (protests), Articles 68–70 (criminal provisions) and — to the extent unregulated — respectively, the Act of 5 January 2011 — the Electoral Code (Article 1(2) of the Act on local referendum, as amended by the Act of 26 January 2023).
The vote takes place in the permanent and separate polling districts referred to in Article 12(1) of the Electoral Code (Article 54(1) of the Act on local referendum) — hence in Częstochowa there are 126 permanent districts and 9 separate districts (hospitals, care homes for the elderly, a hospice, a remand prison), with adjusted opening hours. The ballot paper must contain the designation of the referendum, the date, the question or options with checkboxes, and instructions on how to vote (Article 53(1)), and in a recall referendum it is the electoral commissioner who orders the printing of ballot papers and determines the manner of their delivery to district commissions (Article 52(2)). The campaign prohibitions in force on the day of the vote are protected by three criminal norms:
After the close of voting, the territorial commission draws up, in four copies, a protocol of the referendum result with aggregated numerical data and the result (Article 61(1)), according to the template forms established by the resolution of the National Electoral Commission (PKW) of 20 June 2016. A protest may be lodged against the validity of the referendum; the district court examines it within 14 days of its filing, with the participation of the protester, a representative of the territorial commission and — in a recall referendum — the electoral commissioner (Article 66(3)). PKW Guidelines No. 61/2021 of 24 May 2021 clarify that in a local referendum the provisions of Article 37c and Article 37d(1) of the Electoral Code concerning announcements in the polling station and information provided by the commissions apply mutatis mutandis.
The most realistic scenarios after Sunday's vote:
These consequences are of practical significance for the residents of Częstochowa (a change in or retention of the authorities), for candidates in any early elections, and for entities publishing opinion polls, which face criminal liability in the form of a fine on the day of the vote and before the announcement of the results.
Pursuant to Article 11(5) of the Reimbursement Act, these instruments may consist of making the applicant's revenue dependent on the health outcomes achieved, on supplies at a reduced price, on the volume of turnover of the medicine, or on the repayment of part of the reimbursement obtained to the entity obliged to finance healthcare services from public funds — the payback mechanism (Article 11(5)(4)).
Where reimbursement is sought for a medicine that is already reimbursed, the Minister may require either a price reduction or such a determination of the net sales price and the effective price that the sum of the reductions amounts in total to at least 25 percentage points relative to the most recent decision.
Poland does not formally lose its competence to independently set the prices of reimbursed medicines — decisions are still issued by the Minister of Health on the basis of the national statute — but the real negotiating space will narrow as a result of external price referencing, in particular the American MFN mechanisms referring to prices in G7 countries, Switzerland and Denmark, and, in some programmes, also the Czech Republic. The expected effect is a stiffening of price negotiations and a shift of price reductions into confidential risk-sharing instruments, the legal framework of which is set out in the Act of 12 May 2011 on the reimbursement of medicines, foodstuffs for particular nutritional uses and medical devices. The legal question will therefore be how to shape net sales prices and effective prices in reimbursement decisions by means of Article 11 of that Act, in particular Article 11(2)(5) and (7) and Article 11(5).
A reimbursement decision includes, inter alia, the net sales price (Article 11(2)(5)) and risk-sharing instruments, where such instruments have been established (Article 11(2)(7)).
Following the amendment of 17 August 2023 (Article 8 of the amending Act, which amended Article 11 of the Reimbursement Act), a reduction of the net sales price as a result of a risk-sharing instrument blocks an increase in the effective price in a subsequent decision — the new effective price may not be higher than in the previous decision (Article 11(6aa) of the 2026 consolidated text). An application for reimbursement must contain a proposal for a risk-sharing instrument and information on the reimbursement of the medicine in other countries, and the Regulation of the Minister of Health of 24 October 2023 requires the submission of analyses in two variants — with and without the instrument. Decisions containing a risk-sharing instrument are served by the Minister in copy on the President of the Fund and the President of the Agency (Article 11(12)), and the Minister sets the net sales price taking into account the prices of medicines with the same international non-proprietary name and similar therapeutic effect, balancing the interests of beneficiaries and entrepreneurs as well as the payment capacity of the payer (Article 13(4)). Reimbursement confidentiality binds the ministry, whereas the entrepreneur, being the holder of a trade secret, may dispose of it and disclose it — an asymmetry of considerable significance in the context of global price referencing.
The realistic scenario is a shift of price reductions from transparent prices into confidential RSSs, paybacks and caps, with the final price potentially becoming known only after the settlement of one or two years — which will impede both comparative price analyses and the financial planning of the NFZ. For manufacturers, this entails an obligation to take international interdependencies into account when planning clinical trials, registration and the sequencing of therapy launches, and the risk of withdrawing molecules without reimbursement prospects increases. For the payer and patients, it is relevant that risk-sharing instruments reduce the manufacturer's turnover while at the same time protecting the payer's budget against the uncertainty of market estimation.
Art. 3 of the Act provides that Central European Summer Time is introduced and repealed by the Prime Minister by way of a regulation, setting the dates for a period of at least one calendar year.
The repeal of summer time consists in changing the clocks from 3:00 to 2:00 Central European Time (§ 2), and the hour from 2:00 to 3:00 is additionally designated by the letter "a" (§ 2(3)).
Residents of Poland will switch back to winter time on the night of 24–25 October 2026, because the EU proposal to abolish clock changes, put forward in 2018, has for eight years failed to secure a decision by the Member States in the Council of the EU. The consequence of this legislative impasse is the continued application of the existing statutory framework: the Act of 10 December 2003 on official time in the territory of the Republic of Poland still provides that official time is Central European Time or Central European Summer Time "for the period from its introduction until its repeal" (Art. 2(1)). The precise legal issue therefore concerns the procedure for setting the dates of clock changes: Art. 3 of the Act provides that Central European Summer Time is introduced and repealed by the Prime Minister by way of a regulation, setting the dates for a period of at least one calendar year, taking into account existing international standards.
The basis for the specific dates is the implementing regulation issued by the Prime Minister. Pursuant to the Regulation of 3 November 2016 on the introduction and repeal of Central European Summer Time in 2017–2021, the repeal of summer time consists in changing the clocks from 3:00 to 2:00 Central European Time (§ 2). The hour from 2:00 to 3:00 is additionally designated by the letter "a" (from 2a:01 to 3a:00), which resolves the issue of double designation of hours when the clocks are set back (§ 2(3)). The authority maintaining official time and disseminating its signals is the President of the Central Office of Measures (Art. 4(1) of the Act on official time), and the methods of disseminating the signals are specified by the minister responsible for economic affairs by way of a regulation (Art. 4(2)). Art. 5 of the Act repealed the earlier arrangement, as "the Act of 18 January 1996 on summer time loses force," so the entire mechanism of clock changes today rests exclusively on the 2003 Act and the regulations issued thereunder. It must nevertheless be noted that there is a practical gap: the cited 2016 regulation expressly covers the years 2017–2021, and no implementing act covering the year 2026 is to be found in the sources. In the context of the transfer of employee entitlements, practice relating to timekeeping relies on the general provisions on working time, inter alia Art. 29 of the Act on employees of state offices (consolidated text of 2025), which limits working time to 8 hours per day and an average of 40 hours per week — a change of hour within the working-time schedule does not create a separate standard, but is taken into account within the existing schedule.
Realistically: clock changes will remain part of the Polish legal order at least until agreement is reached in the Council of the EU, and a European Commission spokesperson has announced an analysis to support the Member States' decisions. This has practical significance for employers planning schedules for the Saturday-to-Sunday night (work during the "2a" hour), for operators of IT systems and timetables, and for all entities synchronising their official-time documentation with the signals of the Central Office of Measures. Scenarios for the way forward: