Occupational medical examinations of employees in Poland - scope and duties

Occupational (preventive) medical examinations of employees are a key element of the health protection system at work in Poland. The employer bears full responsibility for ensuring that no employee is allowed to perform their duties without a valid medical certificate. This obligation applies to absolutely all employees, regardless of the type of work or position. The system of occupational examinations includes a comprehensive health assessment aimed at protecting both the employee and their co-workers against potential health hazards arising from the nature of the work. A separate matter is delivering a sick leave certificate to the employer – we cover the deadlines and formats in another article.

The comprehensive system of occupational examinations in Poland is based on detailed legal regulations that precisely define both the scope of the examinations and the procedures for carrying them out. Employers must be aware of their responsibility not only for organising the examinations, but also for keeping appropriate documentation and meeting all deadlines for periodic and follow-up examinations.

Classification of employee medical examinations

The system of occupational examinations in Poland is based on three basic categories, each serving a specific purpose and carried out at different stages of employment. Each type of examination has its own specific requirements and procedures, which employers must strictly follow.

Pre-employment medical examinations are the first stage of the health assessment of a person starting work. They are compulsory for all new employees and in certain situations related to a change of position. Periodic medical examinations are cyclical and serve to monitor employees' health during the employment relationship. Follow-up medical examinations are carried out in special circumstances, mainly after a longer absence due to illness.

Each of these types of examination requires an appropriate referral issued by the employer and must be carried out by an authorised occupational medicine doctor. Documentation of the examinations must be kept in line with the applicable rules, and the results directly affect whether the person can work in a given position.

1. The employer prepares a referral for the examination
2. The employee reports to the occupational medicine doctor
3. The examination is carried out within the specified scope
4. The authorised doctor issues a medical certificate
5. The certificate is handed over to the employer and the employee (from 17 April 2026, as a rule in electronic form)
6. The results are recorded in the appropriate medical documentation

Pre-employment medical examinations - requirements and exceptions

Pre-employment medical examinations are a fundamental element of the system protecting employees' health and are required in strictly defined situations. The Labour Code (Kodeks pracy) clearly states that pre-employment examinations apply above all to people being hired and juvenile employees transferred to other positions. They also apply to other employees transferred to positions with factors harmful to health or arduous conditions. When a doctor refers an employee to a sanatorium, it is worth knowing the employee rights during spa treatment.

However, the system provides for certain exceptions to the obligation to carry out pre-employment examinations, which are intended to streamline procedures while maintaining health safety. The first exception concerns people re-hired by the same employer for the same position or a position with the same working conditions, provided this happens within 30 days after the termination or expiry of the previous employment relationship.

The second exception concerns people hired by a different employer for a given position within 30 days after the end of their previous employment relationship. In this case, they must have a valid medical certificate confirming no contraindications to work in the conditions described in the referral for the medical examination. In addition, the employer must confirm that these conditions correspond to those in the given position.

The third exception concerns people being hired while also employed by another employer. As in the previous case, a valid medical certificate is required, and the employer must confirm that the working conditions match. An important limitation in the second and third exceptions is the exclusion of people hired to perform particularly dangerous work - when changing employer or working for two employers at the same time, such people always undergo pre-employment examinations. The exception for re-employment by the same employer (Article 229 § 1¹ point 1 of the Labour Code) contains no such reservation.

For people coming from another employer or employed in parallel by another employer, the employer must request a valid medical certificate confirming no contraindications to work in the given position, together with the referral on the basis of which that certificate was issued (Article 229 § 1³ of the Labour Code). If the conditions described in that referral do not correspond to the conditions in the new position, the employer returns the referral and the certificate, and the person being hired undergoes pre-employment examinations.

Periodic and follow-up medical examinations

The system of periodic and follow-up medical examinations provides ongoing monitoring of employees' health during the employment relationship. Periodic medical examinations are cyclical and are carried out according to a set schedule, which depends on the nature of the work and the harmful or arduous factors present in the position. The frequency of these examinations is set by the methodological guidelines in Annex 1 to the regulation on medical examinations of employees.

Follow-up medical examinations are ad hoc and are carried out in special situations, mainly in the case of incapacity for work lasting longer than 30 days due to illness. Their purpose is to establish whether the employee is able to work in their current position after the period of illness. Follow-up examinations may also show the need to transfer the employee to another position or to introduce additional health protection measures.

An important organisational aspect is carrying out the examinations during working hours where possible. For the time not worked because of the examinations, the employee keeps the right to pay. If the employee has to travel to another town for the examinations, they are entitled to reimbursement of travel costs under the rules applicable to business trips.

An absolute requirement is that the employer cannot allow an employee to work without a valid medical certificate confirming no contraindications to work in a specific position in the working conditions described in the referral for the medical examination. Breaching this obligation may have serious legal and financial consequences for the employer.

• Periodic medical examinations are cyclical and compulsory for all employees
• Follow-up examinations are carried out after an absence due to illness longer than 30 days
• Examinations should take place during working hours, with the right to pay retained
• The employer covers the costs of travelling to examinations in another town
• The employer cannot allow anyone to work without a valid medical certificate

Special rules apply to employers whose employees work exposed to carcinogenic substances and agents or fibrogenic dusts. Such employers must provide their employees with periodic medical examinations also after they stop working in contact with these substances, agents or dusts. In addition, these examinations must continue after the employment relationship ends if the person concerned applies to be covered by them.

Referral procedure for medical examinations

All types of occupational examinations of employees - pre-employment, periodic and follow-up - are carried out only on the basis of a referral issued by the employer. This referral is a key document that must contain the detailed information needed to carry out the examination properly and issue the appropriate medical certificate. We can take over employment contracts, personnel files and payroll as part of our HR and payroll services.

Each referral for a medical examination must state the type of occupational examination to be carried out. This information allows the occupational medicine doctor to apply the right scope of examinations under the applicable methodological guidelines. For people being hired or employees transferred to other positions, the referral must state the position in which the person is to be employed.

The employer can indicate two or more positions in the referral, in the order that corresponds to the needs of the workplace. This solution gives more flexibility in recruitment and allows the best use of human resources. For employees already employed, the referral must state the position in which the employee currently works.

The most important element of the referral is a description of the working conditions including information on dangerous, harmful or arduous factors. This description must be detailed and include information on the level of exposure and the current results of tests and measurements of factors harmful to health carried out in the relevant positions. This information is crucial for the examining doctor, as it allows a proper assessment of the health risk and adjustment of the scope of the examination to the specific position.

A manufacturing company employing workers in a production hall must include in the referral all harmful factors present, such as noise level, dust, the presence of chemicals and the results of measurements of these factors carried out by the health and safety (BHP) services. Without this information, the doctor will not be able to properly assess the employee's health.

Detailed scope of occupational examinations

The scope and frequency of occupational examinations are set out in detail in the methodological guidelines contained in the Regulation of the Minister of Health and Social Welfare of 30 May 1996 on medical examinations of employees, the scope of preventive health care for employees and medical certificates issued for the purposes of the Labour Code (consolidated text Dz.U. (Journal of Laws) 2023 item 607, amendments: Dz.U. 2026 items 456 and 726). These guidelines are the basis on which occupational medicine doctors determine the specific scope of examinations for each employee.

The doctor examining an employee has considerable freedom to extend the scope of the examination with additional elements if they consider it necessary for a proper assessment of health. They can order additional specialist consultations, in particular ENT, neurological, ophthalmological, dermatological, allergological or psychological ones. The decision to extend the scope should be justified by the specific position or the health of the person examined.

In addition, the doctor has the right to set an earlier date for the next examination than specified in the methodological guidelines if they consider it necessary for a proper assessment of the health of the person being hired or the employee. This flexibility allows an individual approach to each case and an appropriate level of health care.

In recent years there has been discussion of significant changes to the scope of occupational examinations of employees, including compulsory lipid profile, blood glucose tests and body mass index (BMI). As at November 2026, such tests have not been added to the compulsory scope in the methodological guidelines. From 17 April 2026, a doctor who identifies a need for health-promoting action gives the person examined individual recommendations – also concerning health outside work (§ 3 section 2a of the regulation).

1. Basic medical examination in line with the methodological guidelines
2. Assessment of additional risk factors by the doctor
3. Ordering specialist consultations if needed
4. Carrying out additional diagnostic tests
5. Analysing all results and issuing the certificate
6. Setting the date of the next periodic examination

The discussed package of additional tests differentiated by sex (mammography and cytology for women, a PSA test for men, as well as a chest X-ray or colorectal cancer screening) has not become part of the compulsory examinations. The Labour Code does, however, provide (Article 229 § 6¹–6⁵) that the occupational medicine doctor refers the employee – with their consent – to a health programme or health policy programme if the employee meets its conditions. Tests carried out under such a programme are financed under the programme's rules, and the doctor orders any missing tests separately.

Medical documentation of occupational examinations

Keeping proper medical documentation is an integral part of the system of occupational examinations of employees. The medical documentation kept by doctors carrying out occupational examinations consists of two basic elements: the occupational examination record and the register of certificates issued. Both documents must be kept in line with the applicable rules and contain all required information.

The occupational examination record is detailed documentation of each examination carried out and must contain comprehensive information about the unit performing the examination and the doctor providing the services. For medical units, the following are required: name, address, REGON (statistical number) and the doctor's details - first name and surname and the doctor's designation (symbols of the voivodeship, qualifications and register number, from 17 April 2026 in line with § 3 section 4a point 14 of the regulation). For doctors in private practice, the address and REGON number are also required.

The record must also contain the full personal data of the employee examined: first name and surname, date of birth, sex and home address. Information about the workplace is also required - the employer's name, address and REGON number. This data allows the person examined to be clearly identified and the results to be linked to a specific position.

Particularly important are data on the employment history of the person examined and the assessment of health hazards for the employee based on the employer's information about harmful or arduous factors in the position. The record must also contain data from the medical interview and physical examination, the results of diagnostic tests and consultations, and the justification for any extension of the scope or shortening of the frequency of examinations.

• Information about the unit performing the examination and the doctor
• Personal data of the employee examined
• Information about the workplace and employer
• Data on employment history
• Assessment of health hazards in the position
• Results of the medical interview and physical examination
• Results of diagnostic tests and consultations
• Justification for changing the scope of examinations
• Content of the medical certificate issued and recommendations for the employer

The register of certificates issued is the second element of the documentation and is used to record all medical certificates issued. This register must be kept chronologically and contain information that allows each certificate issued to be identified and linked to the relevant occupational examination record. From 17 April 2026, the doctor issues the certificate itself as a rule in electronic form – it goes to the Medical Information System (System Informacji Medycznej) and the Online Patient Account (Internetowe Konto Pacjenta), and the employer receives it from the occupational medicine unit on the date and in the manner set out in the agreement with that unit. Paper form is an exception, for example when there is no access to the system.

Appeal procedure against medical certificates

The system of occupational examinations provides for the possibility of appealing against the certificate of the occupational medicine doctor by both the employee and the employer. The employee's examinations end with a medical certificate stating either no contraindications to work in a specific position or the existence of contraindications to work in a specific position. If they disagree with the certificate issued, the parties have the right to appeal.

The right to appeal is available to both the employee and the employer who issued the referral for the medical examination. The appeal must be in writing and include a justification. This is an important procedural safeguard that ensures objectivity and fairness in assessing fitness for work. The deadline for filing an appeal is 7 days from the date of receiving the medical certificate.

Under the appeal procedure, from 17 April 2026 the appeal is filed through the primary occupational medicine unit where the contested certificate was issued (previously: through the doctor who issued it). Within 7 days of receiving the appeal, that unit must forward it, together with the documentation on which the medical certificate was based, to the competent appeal body. This mechanism ensures that the body examining the appeal has access to the full medical documentation.

The system provides for different appeal bodies depending on who issued the original certificate. The main appeal bodies are the voivodeship occupational medicine centres competent for the place of work or the registered office of the organisational unit employing the employee. For appeals against certificates issued by doctors employed in voivodeship occupational medicine centres, the competent bodies are research institutes in the field of occupational medicine or the University Centre for Maritime and Tropical Medicine in Gdynia.

Special rules apply to the Railway Occupational Medicine Unit (Kolejowy Zakład Medycyny Pracy) - appeals against its certificates are examined by the Scientific Centre for Railway Medicine (Centrum Naukowe Medycyny Kolejowej). Appeal bodies also include medical entities set up and designated by the Minister of National Defence and, from 17 April 2026 – in cases of officers of ABW, AW and CBA (Poland's internal security, intelligence and anti-corruption services) – a medical entity supervised by the heads of those services. After receiving the appeal, the competent body carries out examinations in the appeal procedure within 14 days of receiving the appeal.

An employer running a logistics company disagreed with a medical certificate stating contraindications to work as a driver after periodic examinations. They filed a written appeal with a justification within 7 days. The occupational medicine unit where the certificate was issued forwarded the appeal with the documentation to the voivodeship occupational medicine centre, which carried out new examinations within 14 days. The certificate issued in the appeal procedure was final and confirmed the contraindications to work as a driver.

A medical certificate issued in the appeal procedure is final and no further appeal is available. This mechanism ensures that disputes about fitness for work are definitively resolved while keeping a two-stage procedure.

Frequently asked questions