Temperature in the Workplace — What Changes in the Regulations from 11 January 2027? - JWW Accounting office Poland, Wroclaw, Warsaw

Temperature in the Workplace — What Changes in the Regulations from 11 January 2027?

Until now, occupational health and safety (OHS) regulations set only a minimum permissible temperature in the workplace, without regulating the upper limit of acceptable values. This will change on 11 January 2027, when new regulations take effect introducing maximum permissible working temperatures and imposing specific obligations on employers to protect workers from the effects of high temperatures.

This is a change that should be approached in advance — especially in companies employing manual laborers, warehouse workers, or people working outdoors. Below we explain exactly what is changing, when employers must start taking action, and what a Labor Inspectorate (PIP) inspector may look for during an inspection.

Why Temperature Matters Legally at All

The work environment includes certain physical, chemical, and biological conditions which, depending on the nature and intensity of their impact, may be classified as dangerous, harmful, or burdensome to an employee’s health. Microclimate — understood as the temperature, humidity, air movement, and thermal radiation present in a given room — is classified as a harmful physical factor and is considered the third most common environmental hazard in the workplace.

High temperature affects not only comfort but also the course and quality of the work performed. It reduces concentration, slows reactions, and increases the risk of errors, regardless of the nature of the duties performed. In extreme cases it can lead to dehydration, fainting, heatstroke, or the worsening of cardiac symptoms, which increases the risk of a workplace accident.

Maximum Working Temperatures — New Threshold Values

The regulations in force until now set only a minimum temperature for workrooms — 14°C for work requiring physical effort and 18°C for light and office work — without indicating an upper limit of acceptable values. The amendment to the Regulation of the Minister of Labor and Social Policy of 26 September 1997 on general occupational health and safety regulations introduces the following maximum values:

Type of Work Performed	Minimum Temperature	Maximum Temperature
Physical work indoors	14°C	35°C
Light work and office work	18°C	35°C
Outdoor work involving physical effort exceeding 1500 kcal/shift (men) or 1000 kcal/shift (women)	—	32°C

Once these thresholds are exceeded, work under such conditions simply should not be performed. In practice, this means that exceeding the maximum temperature may be grounds for deeming working conditions non-compliant with OHS regulations and posing a direct threat to health or life — which in turn opens the way for the employee to exercise the rights under Article 210 of the Labor Code (i.e., among others, the right to refrain from work).

Intervention Threshold — Employer Obligations Before Reaching the Maximum Temperature

The obligation to take action arises, however, earlier than the point at which the maximum values are reached. Once 28°C is exceeded in a workroom — or, for work involving the physical effort indicated above, once 25°C is exceeded — the employer is required to apply at least one of the following solutions:

Technical solutions limiting the rise in temperature, unless technological considerations prevent this, or
Organizational solutions minimizing the impact of temperature on workers’ health, adapted to the specifics of the given position.

The regulations deliberately do not contain a closed list of such solutions — the legislator recognized that it is not possible to describe in advance every possible way of coping with heat in every industry. In practice, the most commonly used measures are:

Examples of organizational solutions:

additional work breaks,
shortened working hours or shift work,
remote work (where possible),
rest in an air-conditioned or shaded area,
limiting physical effort during the hottest hours,
personal protective equipment.

Examples of technical solutions:

ventilation — natural, mechanical, or individual,
central air conditioning, portable fans, or cooling devices,
blinds, shutters, and sun-protective films, heat-absorbing shields,
positioning workstations away from direct sunlight,
equipment reducing physical effort (e.g., forklifts, automated devices).

The rule is simple: collective protective measures should be applied first, followed by individual measures. Particular attention should be paid to workers who are more vulnerable to the effects of heat — pregnant women, minors, older employees, and people with cardiovascular conditions. In this respect, it is good practice to consult the physician providing preventive healthcare to the workforce.

Mandatory Update of the Occupational Risk Assessment

The new limits are a signal to review OHS documentation. If a given position (especially outdoors, or with additional heat sources from technological processes) carries a risk of overheating, the occupational risk assessment should be updated, and employees informed about the new hazards and the procedures to follow.

Obligation to Consult with Employees

The decision on which specific organizational solutions to adopt cannot be made unilaterally by the employer. The new regulations explicitly require that these solutions — both for work performed indoors and outdoors — be established after consultation with employees, within the occupational health and safety committee (mandatory for employers with more than 250 employees) or, in its absence, through the standard consultation procedure.

It is also advisable, although not explicitly regulated, to agree on the adopted solutions with the physician providing preventive healthcare to employees, who has knowledge of the specifics of individual positions and is able to assess the related health risks.

IMPORTANT

The regulations do not impose a specific form, but in the event of a PIP inspection, what matters is not only what was done, but also whether the given solution was previously analyzed, consulted, and effectively communicated to employees.

Who the New Limits Will Not Cover

The regulations on maximum temperatures will not apply directly to all types of activity. Exclusions include, among others:

rescue operations and failure/breakdown removal,
work in continuous operations, transport, and communications,
company fire brigades and rescue services,
protection of persons and property,
agriculture and livestock farming,
catering and hospitality,
municipal services,
healthcare facilities providing round-the-clock care,
nurseries and children’s clubs,
uniformed services officers and soldiers.

What a PIP Inspector Will Check

In addition to technically measuring temperature, a labor inspector may assess the employer’s overall actions:

whether hazards related to high temperature were identified at all,
whether adequate technical or organizational solutions were implemented,
whether the required consultations with employees were carried out,
whether employees were informed of the procedures to follow,
how all these actions were documented and whether they proved effective.

An inspection may be planned (arising from PIP’s annual plan), triggered by an employee complaint, or be part of a comprehensive or issue-specific inspection concerning thermal comfort alone. Identified irregularities are recorded in a report, against which the inspected entity may raise substantiated objections within 7 days of its presentation.

IMPORTANT

In extreme cases, where a violation constitutes a direct threat to life or health, the inspector may order an immediate stoppage of work. In other situations, time-limited orders will be applied. Regardless of this, failure to comply with OHS regulations is an offense under Article 283 of the Labor Code, punishable by a fine of PLN 2,000 to PLN 60,000.

What Is Worth Doing Now

There is still some time before the regulations enter into force, but this is a good moment to:

check which positions in the company are actually exposed to high temperatures,
update occupational risk assessments where necessary,
think through specific organizational and technical solutions tailored to the company’s specifics,
plan a consultation procedure with employees (OHS committee or individual consultations),
establish a way of documenting the actions taken — this may prove decisive in the course of any PIP inspection.

Legal basis:
1 of the Regulation of the Minister of Family, Labor and Social Policy of 9 July 2026 amending the regulation on general occupational health and safety regulations (pending entry into force); Articles 207 and 210 of the Act of 26 June 1974 — Labor Code; §§ 30 and 30a of the Regulation of the Minister of Labor and Social Policy of 26 September 1997 on general occupational health and safety regulations.