From 18 October 2026, occupational health medical certificates will be issued electronically. Find out how they will be delivered to your company and what should be updated in your agreement with the occupational health provider.

From 18 October 2026, occupational health medical certificates will, as a rule, be issued exclusively in electronic form. Employees will be able to access them through the Patient Online Account (IKP), while employers will be notified by the medical facility where the examination was carried out. From the employer’s perspective, the key point is that the method and deadline for delivering the certificate are determined by the agreement concluded with the occupational health provider. It is therefore worth reviewing the agreement before the new rules take effect.

What is changing

The change results from the Regulation of the Minister of Health of 20 March 2026, which entered into force on 17 April 2026. A transitional period applies until 17 October: during this time, a doctor may issue a certificate either in paper or electronic form. From 18 October, electronic certificates will become the standard for pre-employment, periodic and return-to-work medical examinations.

The electronic certificate will become part of the employee’s electronic medical records. Employees will be able to access it through their Patient Online Account (IKP) under “Medical Data” > “Occupational Health”, download it as a PDF file and check its validity period. They may also request a printed copy of the certificate, signed by the doctor by hand.

Certificates previously issued in paper form will remain valid despite the change in regulations.

When paper certificates may still be issued

A paper certificate may still be issued in exceptional circumstances, for example where the doctor does not have access to the relevant IT system due to a technical failure, as well as in the case of officers and soldiers of certain special services. For most companies, however, paper certificates will become increasingly rare.

How the employer will receive the certificate

The employee will no longer be required to deliver the certificate personally. The obligation to provide the document to the employer lies with the occupational health provider, while the method and deadline for delivery are determined by the agreement concluded with that provider.

If the agreement refers only to paper documents, it may not be clear how an electronic certificate should be delivered to the company.

Employers do not have access to employees’ Patient Online Accounts. Employees may voluntarily send the downloaded PDF file to the employer, but this should not be the standard procedure. Until the certificate is received, employers should proceed with caution: under the Polish Labour Code, an employee may not be allowed to work without a valid medical certificate. In the case of a pre-employment or return-to-work examination, the date on which the certificate is received may therefore determine the employee’s first day of work.

What the employer will and will not see

The employer will not receive the employee’s full medical records, laboratory test results, such as blood test results, or information concerning diagnosed illnesses. The certificate will include, among other things:

information on whether the employee is fit for work, unfit for work, or has lost the ability to perform their current work,
the employee’s job position,
the date of the next periodic medical examination,
a recommendation to provide corrective glasses or contact lenses, where required.

Certificates issued where an employee has become unfit to perform their current work, for example due to the harmful impact of working conditions, suspected occupational disease or a workplace accident, may also include recommendations concerning workplace adjustments or transfer to another position.

A doctor may also provide the employee with individual health recommendations, including recommendations relating to activities outside work. These recommendations will not be disclosed to the employer.

The scope of the examination itself will not change. The doctor will issue the certificate following a personal examination of the employee, taking into account any additional tests or specialist consultations required and the assessment of occupational risks associated with the employee’s position. The template of the medical examination referral will also remain unchanged.

Appealing against a medical certificate

Both the employee and the employer may appeal against the certificate within 7 days of receiving it. The appeal must be submitted through the occupational health provider that issued the certificate.

For this reason, employers should record the date on which each electronic certificate is received by the company.

What employers should do before 18 October

Review the agreement with your occupational health provider. Does it specify how and when electronic certificates will be delivered?
Amend or update the agreement if these provisions are missing, for example by specifying the email address to which certificates should be sent and the deadline for delivery.
Appoint a person responsible for receiving certificates and recording their date of receipt.
Establish a procedure for archiving electronic certificates in employees’ personnel files.
Inform employees that they will be able to access their certificates through the Patient Online Account (IKP), while the occupational health provider will send the certificate to the employer, for example by email.
Take into account any recommendations addressed to the employer included in the certificate, such as the need to provide corrective glasses for work involving a computer screen.

Do you have any questions?

If you would like to discuss how the changes effective from 18 October 2026 may affect your company, contact us at: [email protected].

Legal basis:
Regulation of the Minister of Health of 20 March 2026 amending the regulation on medical examinations of employees, the scope of preventive healthcare for employees and medical certificates issued for the purposes provided for in the Polish Labour Code (Journal of Laws of 2026, item 456); Article 229 of the Polish Labour Code.