Poland mandates electronic filings for Guaranteed Employee Benefits Fund claims

Poland is moving the Guaranteed Employee Benefits Fund (Fundusz Gwarantowanych Świadczeń Pracowniczych, FGŚP) procedure fully online. A regulation of the Minister of Family, Labour and Social Policy of 13 August 2026, published in Dziennik Ustaw on 11 September 2026 (item 1200), makes the electronic submission of collective lists, supplementary lists, individual applications and supporting documents mandatory, signed with a qualified electronic, trusted or personal signature. The rules enter into force three months after publication.

The measure amends the regulation of 24 October 2017 on lists, applications and payments of benefits from the FGŚP (Dz. U. item 2041), and is issued on the basis of Article 22 of the Act of 13 July 2006 on the protection of employee claims in the event of employer insolvency (Dz. U. 2026 item 186). It was signed by Minister Agnieszka Dziemianowicz-Bąk.

Who must file electronically

The obligation falls on the “submitting entity” — the employer, administrator, syndic, liquidator or any other person managing the employer’s assets — acting for employees whose employer has become insolvent. These entities must now send the collective list and the supplementary list to the competent marshal of the voivodeship in electronic form.

• Collective list (zbiorczy wykaz) and supplementary list (wykaz uzupełniający) are submitted electronically to the marshal of the voivodeship.
• Individual applications (wniosek indywidualny) may be filed in paper or electronic form; when electronic, they must carry the required signature.
• Digital copies of the supporting documents are attached to the electronic filings, signed with a qualified electronic, trusted or personal signature.

Technical channels and deadlines

Electronic filings are routed through the IT system referred to in Article 26(1)(7)(c) of the Act of 20 March 2025 on the labour market and employment services, or to the electronic delivery address of the competent voivodeship labour office. The marshal of the voivodeship sends confirmations of approved Fund amounts through the same channels.

• Benefits must be paid to entitled persons within 7 days of receiving the funds.
• The difference between funds received and amounts paid out must be returned to the Fund account within 15 days, together with an explanation of the reasons.
• The submitting entity must also provide proof of payment to entitled persons, including copies of cash receipts, bank transfer confirmations and postal transfer confirmations.

New templates and verification powers

The regulation replaces the templates in annexes 1–3, including the model collective list of unpaid employee claims, which now records the entity’s REGON and NIP numbers, the bank name and the payment account number. The marshal of the voivodeship may also request additional documents from the submitting entity or from an authorised representative of a foreign entrepreneur, credit institution or foreign insurance establishment named in the individual application, to verify the date and circumstances of the employer’s insolvency.

Impact

For workers whose employers have become insolvent, the change means faster and fully traceable processing of their guaranteed claims through the FGŚP, with clear deadlines for payment. For employers, administrators, syndics and liquidators, it introduces a firm obligation to file electronically with qualified signatures, ending the paper-based route for collective and supplementary lists. The three-month transition period gives the affected entities time to adapt their procedures and IT tools before the new rules take effect.

Source: Dziennik Ustaw, No. 1200 of 11 September 2026, section I, p. 1200 (official reference: Dz. U. 2026 poz. 1200).