Hourly absence in an employee's ZUS RSA report in Poland

Correctly reporting employee absences in documents sent to ZUS (Social Insurance Institution) is one of the key obligations of every contribution payer. Reporting hourly absences that do not exceed a full working day, however, proves particularly problematic. The ZUS reporting system has certain technical limitations that affect how this type of absence is documented.

Contribution payers often face the dilemma of how to correctly show in monthly personal reports situations in which an employee was absent for only a few hours during a working day. This problem is particularly important in the context of reporting obligations and the need to comply with social insurance law.

The issue of hourly absences requires particular attention because of the way the ZUS reporting system works. The forms intended for this purpose are not fully adapted to recording absences in hours, which creates practical difficulties for employers that keep detailed working time records for their employees.

The legal basis for reporting to ZUS

Contribution payers' obligations to submit reporting documents to ZUS follow directly from the Act of 13 October 1998 on the social insurance system. This Act is the fundamental legal basis for the entire social insurance system in Poland and sets out the detailed obligations of all participants in the system.

The Act also contains the authorisation to issue implementing regulations specifying the type of reporting documents and the scope of information to be included in individual forms. This authorisation has been used to create a comprehensive reporting system covering various aspects of employment and social insurance.

The Regulation of the Minister of Family, Labour and Social Policy is a detailed technical regulation that specifies not only the templates of individual documents but also the codes used to complete them; the deadlines for submitting them to ZUS are set out in the Act (Article 47(1)). This document is regularly updated in response to changes in labour and social insurance law.

In the context of hourly absences, two forms set out in the regulation are particularly important. The first is the settlement declaration marked ZUS DRA, which is annex no. 16 to the regulation. The second key document is the monthly personal report on benefits paid and breaks in paying contributions, marked ZUS RSA and constituting annex no. 14 to the regulation.

Key legal acts governing reporting:

1. The Act of 13 October 1998 on the social insurance system
2. The Regulation of the Minister of Family, Labour and Social Policy of 9 April 2026 (Dz.U. 2026, item 518)
3. The Labour Code (Kodeks pracy) as regards working time records
4. The Act of 20 March 2025 on the labour market and employment services (on 1 June 2025 it replaced the Act on employment promotion and labour market institutions)
5. Implementing regulations on document templates

The ZUS DRA settlement declaration

The ZUS DRA settlement declaration is the basic reporting document that a contribution payer submits to ZUS by set deadlines. It contains a comprehensive summary of all contributions due for a given month and information on benefits paid that are settled against social insurance contributions.

The structure of the ZUS DRA declaration is designed to give a full picture of the payer's contribution position. First, the document requires the payer's identification data, which allow the declaration to be unambiguously assigned to a specific business or institution.

Another important element of the declaration is the summary of benefits paid that are settled against social insurance contributions. This part of the document is particularly important for employee absences, as it covers various benefits paid during sickness absence or other excused absences from work.

The declaration also includes a section on contributions to the Bridging Pension Fund, which concerns certain occupational groups entitled to retire early. The last element of the document is the annual settlement of the health insurance contribution of business owners, which is shown in the declaration filed for the month in which the deadline for filing the PIT return falls, i.e. in practice for April (Article 81(2k)–(2ka) of the Act on publicly funded healthcare services).

The ZUS RSA monthly personal report

The monthly personal report on benefits paid and breaks in paying contributions, marked ZUS RSA, is a key document for reporting employee absences. This report is attached to the ZUS DRA declaration in certain situations and contains detailed information on individual insured persons.

The obligation to prepare and submit the ZUS RSA report arises in two basic situations. The first is where an employee was paid benefits or remuneration for sickness absence. The second covers all cases of breaks in paying contributions, regardless of their cause – reported as from–to periods, i.e. in full days.

The practical use of the ZUS RSA report can be illustrated by the example of an employee who fell ill and was certified as unfit for work. In the month in which the illness occurs, such an employee may first receive sick pay paid by the employer and then sickness benefit paid by ZUS or – where the payer registers more than 20 insured persons for sickness insurance – by the payer itself (Article 61 of the Sickness Benefits Act). For such a month, the contribution payer must prepare a ZUS RSA personal report showing the relevant periods in which these amounts were received.

Main elements of the ZUS RSA report:

• Personal data of the insured person (PESEL (national ID number), surname, first name)
• The period covered by the report
• Type of benefit or break (code)
• Number of benefit days or number of payments
• Amount of the benefit
• Insurance title code and the period of the break or benefit (from–to date)

For an IT employee who was on sick leave (L4, e-ZLA) for 10 days in February 2025, the employer must prepare a ZUS RSA report. If the employee has not previously used up the limit of 33 days of sick pay in that year (14 days for an employee aged 50 or over – Article 92 § 1 of the Labour Code), all 10 days are reported as sick pay (code 331); days above the limit are reported as sickness benefit (code 313). Each period requires the appropriate code and a precise number of days.

Completing both the ZUS DRA declaration and the ZUS RSA personal report requires special codes, the complete list of which is in annex no. 24 to the regulation. These codes make it possible to specify precisely the type of benefit or the reason for a break in paying contributions, which is essential for the social insurance system to function properly.

Deadlines for submitting documents to ZUS

Submitting reporting documents to ZUS on time is a key element of contribution payers' compliance. The rules set the same deadlines for submitting the ZUS DRA settlement declaration and the monthly personal reports, including the ZUS RSA report.

The deadlines differ depending on the type of contribution payer, reflecting the different organisational and technical capabilities of the various types of entities. The shortest deadline applies to budgetary units and local government budgetary establishments, which must submit their documents by the 5th of the following month.

Procedure for submitting ZUS documents – step by step:

1. Preparing and checking data on remuneration paid
2. Preparing the ZUS DRA declaration including all contributions
3. Checking whether a ZUS RSA report must be attached
4. Completing the ZUS RSA report with the appropriate benefit codes
5. Checking the deadlines for submitting documents by type of payer
6. Submitting the documents to ZUS electronically or on paper
7. Receiving confirmation from ZUS that the documents have been accepted

The different deadlines reflect practical considerations related to the different complexity of accounting and reporting processes in various types of organisations. Budgetary units, which usually have larger accounts departments and stable procedures, can prepare the required documents more quickly.

Capital companies and other entities with legal personality were given a slightly longer deadline, which takes into account how they operate and the need to coordinate between different departments. The longest deadline applies to other payers, mainly individuals running a business, who often do not have extensive accounting structures.

Failure to meet the deadlines for submitting documents to ZUS may result in financial sanctions, so contribution payers should take particular care to meet their reporting obligations on time. Remember also that where a deadline falls on a non-working day, it is moved in line with the general rules for calculating deadlines.

Types of breaks in paying contributions

The social insurance system provides a detailed classification of the various types of breaks in paying contributions, which must be properly coded and shown in ZUS RSA monthly personal reports. Each type of break has its own unique code that specifies precisely the reason for the employee's absence.

Unpaid leave is one of the most common types of break in paying contributions and is marked with code 111. This type of absence occurs when an employee receives the employer's consent to be temporarily released from the obligation to work without the right to remuneration. No social insurance contributions are paid during unpaid leave, which must be properly reflected in the reports.

The most common types of breaks in paying contributions:

• Code 111 - Unpaid leave
• Code 121/122 - Parental leave (urlop wychowawczy)
• Code 151 - Excused absence without remuneration
• Code 152 - Unexcused absence from work
• Code 131 - Carer's leave (Article 173¹ of the Labour Code)
• Code 311 - Maternity benefit for the period of maternity leave
• Code 319 - Maternity benefit for the period of parental leave (urlop rodzicielski)
• Code 313 - Sickness benefit from sickness insurance

Parental leave (urlop wychowawczy), a special type of unpaid leave, requires the appropriate code depending on the legal basis on which it was granted. This distinction allows ZUS to establish on what basis the employee is on leave – for this period pension and disability contributions are financed by the state budget (Article 16(8) of the Social Insurance System Act).

A period of excused absence from work without the right to remuneration or benefit, marked with code 151, covers various situations in which an employee has good reasons for not coming to work but is not entitled to any remuneration for that time. This may include, for example, illness during the waiting period for the right to sick pay and benefit, dealing with official matters or other circumstances provided for in labour law.

Unexcused absence from work, marked with code 152, concerns situations in which an employee does not come to work without giving good reasons or without the employer's consent. This type of absence may have serious consequences for the employment relationship and must also be properly shown in ZUS documents.

Technical limitations of the reporting system

Despite its comprehensiveness, the ZUS reporting system has certain technical limitations that affect the ability to report some types of employee absence. Absences measured in hours that do not exceed a full working day prove particularly problematic.

The ZUS RSA form (annex no. 14 to the regulation of 9 April 2026) is designed to report absences in days – the period of a break is given by "from" and "to" dates – which means that the system allows information to be entered on full days of absence and on the number of benefit days or number of payments. However, the structure of the document is not adapted to recording absences in hours.

Main technical limitations of the system:

1. No option to report absence in hours
2. The system works only with full calendar days
3. Break periods are given as dates (from–to), not as a number of hours
4. Limited options for reporting flexible forms of work
5. No integration with modern working time recording systems

This technical limitation has practical consequences for employers that keep detailed working time records for their employees. Where an employee is absent for a few hours during a working day, the employer cannot report this directly in the ZUS RSA report, even if the absence was excused and no remuneration is due for it.

This approach follows from the principles of the social insurance system: an employee's contributions are calculated on the income actually earned (Article 18(1) in conjunction with Article 4(9) of the Social Insurance System Act), not on the number of hours worked. The ZUS RSA report is used to show full-day breaks and benefits, not to reproduce working time records.

The practical consequences of these limitations are therefore smaller than they might seem. If an employee is not entitled to remuneration for a few hours of absence, their income for the month is lower, and so is the contribution base shown in the ZUS RCA report – without these hours having to be shown separately in ZUS RSA. Another unusual case in settlement reports is ZUS code 30 00 after employment ends.

Practical examples of hourly absences

To better understand the issue of hourly absences in the context of reporting to ZUS, it is worth looking at specific situations that may arise in practice. These examples illustrate both the challenges employers face and the limitations of the current reporting system.

Consider an employee working full time on a standard schedule of five days a week, Monday to Friday. On 14 February 2025 this employee was absent from the company for 3 hours. The employee excused this absence but was not paid for that time, and there was no option to make up the hours.

In the situation described, the appropriate benefit or break code would be 151, meaning a period of excused absence from work without the right to remuneration or benefit. This code matches the nature of an absence that the employee has excused but that does not generate any costs for the employer in the form of remuneration or benefits.

However, the practical use of this code runs into the technical limitations of the reporting system mentioned above. The ZUS RSA form does not allow an absence of 3 hours to be reported, because it is designed to work only with full days of absence.

An employee in the accounts department of a medium-sized manufacturing company had to leave work for 4 hours in the middle of the working day to deal with an urgent matter at a public office. The absence was excused by the line manager, but the employee was not paid for that time. Although the situation was clearly documented in the working time records, the employer could not report this information in the ZUS RSA report because of the technical limitations of the form.

Typical hourly absence scenarios:

• Medical appointments during working hours
• Dealing with official matters
• Caring for a sick family member
• Attending external training
• Transport problems (delays, breakdowns)
• Family matters requiring urgent attention

Consequences of the system's limitations

The technical limitations of the ZUS reporting system regarding hourly absences have certain practical consequences for employers and for the social insurance system as a whole. These consequences concern both administrative and financial aspects of running a business.

From the employer's perspective, being unable to report hourly absences in ZUS reports does not mean paying higher contributions. Contributions are calculated on the remuneration actually due for the month, so unpaid hours of absence reduce the contribution base. The real challenge is calculating remuneration correctly for a month with hourly absence – especially where absences are regular – and keeping working time records consistent with the payroll. We can keep working time records and the payroll for you — details on our HR and payroll page.

Main consequences of the system's limitations:

1. Financial - The need to reduce remuneration correctly for hours not worked
2. Administrative - Hourly absence recorded only in the working time records
3. Inspection-related - The need to explain differences between working time records and ZUS reports
4. Legal - Potential problems during inspections by state authorities
5. Organisational - Additional workload for HR and accounts departments

ZUS does not receive information on insured persons' hourly absences. For employees' future pension benefits, however, what matters above all are the contributions recorded on their accounts, and these are calculated on the income actually earned, as shown in the ZUS RCA report.

From a documentation point of view, hourly absences are recorded in the working time records, which the employer keeps for the purpose of correctly determining remuneration (Article 149 § 1 of the Labour Code); these records also include the type and extent of excused and unexcused absences (§ 6 point 1(a) of the regulation on employee records). There is no need to keep separate records "for ZUS", but remember that ZUS reports show hourly absence only indirectly, and inaccurate records increase the risk of errors in remuneration and contributions. How such an absence affects the benefit base is explained in our post on the salary supplement for unexcused absence.

The system's limitations also affect inspections by state authorities. Labour inspectors or ZUS inspectors comparing the employer's internal documentation with the reports submitted to ZUS may encounter discrepancies resulting from the impossibility of fully reflecting reality in official forms.

Recommendations for employers

Given the technical limitations of the ZUS reporting system, employers should develop practical solutions that allow them to meet their reporting obligations correctly while keeping precise working time records. These recommendations concern both organisational and documentation aspects.

The basic recommendation is to keep detailed internal working time records covering all employee absences, including hourly ones. These records should contain information on the reasons for absences, whether they were excused and their effect on the employee's remuneration.

Practical recommendations for employers:

1. Developing internal procedures for documenting hourly absences
2. Implementing IT systems for working time records
3. Regular training for HR and accounts staff
4. Monitoring changes in the law and in ZUS forms
5. Consulting experts in labour and social insurance law
6. Organising work efficiently to minimise hourly absences
7. Documenting all decisions related to employee absences

Where hourly absences are regular, it is worth considering flexible working time systems or other organisational solutions that better match working time records to what the reporting system can handle. This may include introducing a system for making up hours or modifying work schedules.

It is also important to train HR and accounts staff regularly on current ZUS reporting requirements. This training should cover both the technical aspects of completing forms and practical ways of dealing with the system's limitations.

Example organisational solutions:

• Flexible working time - minimising conflicts between private and work obligations
• Making up hours - an option to compensate for hourly absences
• Scheduling medical appointments outside working hours or on days off
• Remote work - less need to leave the workplace
• Grouping absences - combining short absences into longer periods

Employers should also monitor changes in the law and any modifications to ZUS forms that might in future allow hourly absences to be reported more precisely. Keeping track of legislative changes will allow internal procedures to be adapted quickly to new requirements.

Outlook for the system

The limitations of the current ZUS reporting system regarding hourly absences point to the need to modernise it and adapt it to modern forms of work organisation. Technological development and the changing needs of the labour market suggest that the system may be extended with additional functions in the future.

The digitisation of administrative processes and the development of IT systems create opportunities for more flexible solutions for reporting working time. Modern systems could cover not only full days of absence but also precise recording of hours worked and hours of absence.

Directions for developing the reporting system:

• Digitisation of processes - electronic working time recording systems
• Automated reporting - direct transfer of data from HR systems
• Flexible forms - the option to report in different units of time
• System integration - linking internal records with ZUS reporting
• Data analysis - using big data to optimise the system
• Mobility - mobile apps for working time records

As of November 2026, however, the rules do not provide for reporting absences in hours in ZUS RSA – the new report template under the regulation of 9 April 2026 still requires break periods to be given as from–to dates.

The development of forms of employment such as remote work, flexible working time or project-based employment requires appropriate adaptation of recording and reporting systems. Future changes to the ZUS system may take these new labour market realities into account.

Flexible forms of employment are becoming more important. The social insurance system should be adapted to them to ensure proper protection for employees while maintaining administrative efficiency.

Greater integration of various IT systems can also be expected, which could allow working time data to be transferred automatically from HR and payroll systems directly to ZUS systems. Such solutions could significantly simplify administrative processes and make reporting more precise.

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