If you employ staff, preventive medical examinations should take place under a written agreement with a primary occupational health service unit. This obligation existed before electronic medical certificates. The new rules further emphasise the importance of the agreement: it specifies when and how the certificate is delivered to the employer. [1][2]
An employee books an examination at a clinic of their choice, brings back a document and the company reimburses the cost. If this is how your company has organised examinations, it is worth checking both the certificates and the basis of your cooperation with the clinic.
We explain what to put in order following the introduction of electronic medical certificates, what to ask your current occupational health provider and how to prepare your company for an efficient flow of documents.
Must an employer have an occupational health agreement?
Yes. Article 12(1) of the Polish Occupational Health Service Act provides for a written agreement as the basis for pre-employment, periodic and return-to-work medical examinations and other preventive healthcare services for employees. The party responsible for providing this care — the employer in the case of employees — enters into the agreement with a primary occupational health service unit. [1]
This obligation was not introduced only in October 2026. An invoice for an individual examination does not replace such an agreement. Nor should you assume that a voluntary healthcare package automatically includes it: check the scope of your agreement.
How does structured cooperation benefit your company?
You know where to refer employees, how to provide information about their roles and who is responsible for delivering documents. HR does not have to establish the process from scratch every time.
The agreement should cover, among other things, the scope of care, appointment and service arrangements, the parties’ obligations, payments and termination rules. The Act provides for a term of at least one year. This does not in itself require purchasing a subscription — the agreement sets the financial terms. [1]
What changed on 18 October 2026?
The transition period for the format of medical certificates has ended. Electronic documents are now the rule, subject to the exceptions specified in the regulations. This change is based on the Regulation of the Minister of Health of 20 March 2026, effective from 17 April 2026 — not a new act introducing the obligation to enter into agreements. [2][4]
The doctor issues the document
The electronic certificate is signed or authenticated using a method permitted by the regulations and recorded in the Medical Information System (SIM).
The employee can access it
Information from the certificate is made available in the Internet Patient Account (IKP). At the examined person’s request, the doctor issues a printout bearing a handwritten signature.
The company receives the certificate
The clinic sends it to the employer within the timeframe and by the method agreed in the contract.
Legal basis for this process: § 3(4d–4h) of the Regulation, as amended. [2]
An employee arranged an examination on their own initiative. Is that enough?
The name used by the clinic alone does not determine whether the requirements for employee medical examinations have been met. What matters is which examination was actually carried out, on what basis and which job the document relates to.
An employee’s preventive medical examination is carried out on the basis of an employer’s referral containing information about the role and working conditions. An employee’s own request does not replace the employer’s obligation to organise preventive healthcare. [3]
Do not assess a certificate solely on the absence of an agreement
The absence of an agreement needs to be addressed, but it does not automatically mean that all previous certificates are invalid. It would be equally unsafe to assume that any document brought in by an employee is sufficient to allow them to work.
Check the referral, the role and description of working conditions, the date and content of the certificate, and the doctor’s qualifications. Clarify any doubts with the unit that issued the document and, where fitness for work is concerned, also with the person responsible for HR, occupational safety or the company’s legal affairs. Entering into an agreement today does not retrospectively confirm that earlier examinations were carried out correctly.
No agreement? Start with four steps
- Check your company’s documents. Establish whether an agreement already exists, whom it covers and whether it is still valid.
- Agree cooperation with an occupational health unit. Prepare information about employee numbers, roles, hazards and organisational needs.
- Agree how certificates will be received. Specify authorised recipients, the delivery channel and deadline, and a contact for resolving discrepancies.
- Put future referrals in order. Provide the required information about working conditions and monitor certificate validity.
The agreement organises cooperation. It does not release the employer from their obligations, including providing correct referrals and not allowing anyone to work without an appropriate, valid medical certificate. [3]
Questions employers and HR ask
Do I need an agreement even if I employ only one person?
Yes. The obligation concerning preventive medical examinations for employees does not depend on a minimum number of staff. Self-employment and civil-law contracts require a separate assessment — not all rules applying to employees automatically apply to them. [1]
Do I need to change my current clinic immediately?
Do not assume this in advance. Ask how the clinic issues electronic certificates, makes them available in IKP and delivers them to your company. Check your current agreement too. Base your decision on specific answers and documents, rather than a general claim about digitalisation.
Can a company work with several clinics?
Yes — the National Labour Inspectorate (PIP) confirms that agreements may be entered into with several units. In that case, clearly define how employees are referred and how documents are received from each clinic. [3]
Must earlier paper certificates be replaced?
The change in the format of newly issued certificates does not in itself require all previous examinations to be repeated. You must still monitor the validity of each certificate and its relevance to the role and working conditions. A change of role or other circumstances may require a separate assessment. [2][3]
Is every paper document issued after 18 October incorrect?
No. The regulations permit paper certificates in specified situations, including lack of access to the IT system. A separate case is a doctor-signed printout of an existing electronic certificate issued at the examined person’s request. Paper alone does not make a document incorrect. [2]
Does HR need access to the employee’s IKP?
There is no need to log into the employee’s account. The regulations provide for the occupational health unit to send the certificate separately to the employer, in accordance with the agreement. Do not ask employees for their IKP password. [2]
Do we need to buy new software to receive certificates?
The rules on delivering certificates do not prescribe one mandatory software package for all employers. The delivery channel and timing are agreed in the contract. Choose a solution suited to your company, taking document protection and authorised access into account. [2]
How can we check whether our occupational health provider is ready?
Ask for explanations of four things: how the document is issued and signed, how it is recorded in the system, how and when your company receives it, and what happens if the system fails or data is incorrect. Check that these arrangements are reflected in the agreement. A scan bearing a stamp is not automatically the same as a correctly issued electronic certificate.
Put employee examinations and document delivery in order
At MediCityPoint, we agree arrangements with your company for organising examinations and delivering certificates. We issue electronic medical certificates signed by doctors and made available in IKP. We send the employer a secured document to the email address specified in the agreement.
For your HR team, this means an agreed delivery channel and access to a team that can help resolve organisational questions. You do not have to build the entire process from scratch yourself.
What should you prepare for our conversation?
To begin with, information about employee numbers, types of roles and your current examination arrangements is enough. We will discuss the scope of cooperation and the agreement terms. Please do not send employees’ test results or medical records with your initial enquiry.
Ask about a cooperation agreement → 666 103 789ul. Kamienna 139/U2, Wrocław · Services for businesses at MediCityPoint
Legal basis and sources
- Occupational Health Service Act — Article 12: written agreement, scope and terms of cooperation.
- Regulation of the Minister of Health of 20 March 2026, Journal of Laws 2026, item 456: in particular § 3(4d–4h) of the amended Regulation and the amendment’s transitional provisions.
- National Labour Inspectorate (PIP): Employee medical examinations — referrals, certificates and cooperation with an occupational health unit.
- e-Health Centre: Electronic occupational health certificates mandatory, 19.10.2026.
This article concerns preventive medical examinations for employees. It does not assess any specific certificate or constitute individual legal advice. Prepared on 28 October 2026.
