KSeF and PIP: How Inspections Target Firms

Remember how people used to say: "small firm, two blokes on site, who'd ever come looking at us"? That doesn't work anymore. From 2026 the PIP (the Polish Labour Inspectorate) no longer walks construction sites blindly - it targets firms using data. And one of the main sources of that data is invoices from KSeF (the Polish e-invoicing system). In this text I explain, without conspiracy theories, how it really works and what to do so you don't end up at the top of the list. If you'd rather not sort it out from scratch, we have ready-made OSH (occupational safety and health) documentation templates for PKD 43 - I'll say where below.

Key points in brief

• From 8 July 2026 (the PIP reform, Journal of Laws 2026 item 473) the inspectorate targets firms based on data patterns, it doesn't draw lots.
• KSeF (the National e-Invoicing System) gives a picture of what a firm buys and sells - material for risk analysis.
• Warning signal: lots of revenue from construction work and ZERO costs for OSH training, medical examinations and PPE (personal protective equipment).
• The plan for 2026 is 50,000 PIP inspections, with a fine of up to 5 000 zł for violations - the "invisible small firm" has ceased to exist.
• The simplest defence: have OSH documentation and real OSH costs in your invoices, so your profile looks normal.

What has changed: PIP has stopped drawing lots

For years a PIP inspection was a bit of a lottery. Either someone reported you, or there was an accident, or you got picked "ex officio" along the way. A small construction firm could operate for years and never see an inspector. It counted on being too small for anyone to bother with.

The PIP reform from 8 July 2026 changes the logic. The inspectorate stops acting at random and starts aiming. Instead of rolling the dice, it analyses where, statistically, something is most often wrong - and sends people there. It's simple maths: since resources are limited and the plan is 50,000 inspections in 2026, it's better to go where the chance of a violation is greatest. I wrote more about the reform itself in the text on what the PIP reform changes.

And this is where KSeF comes in.

Where PIP gets the data: KSeF as a map

KSeF, the National e-Invoicing System, is a central register of invoices. Every invoice you issue and every one you receive passes through this system. That means there is one place that shows what your firm sells and what it buys.

It's not that someone reads your invoices one by one over coffee. It's about patterns. From a mass of data you can extract a firm's profile: how much revenue it makes, from what, what its costs are, whether the spending structure fits the industry. The algorithm doesn't know whether you're honest. It only knows whether your profile looks like that of a firm with OSH under control, or like a firm that doesn't spend a penny on OSH.

This is pattern analysis, not surveillance of a particular site boss. Nobody is sitting there tracking your Toyota. But the numbers tell a story on their own - and sometimes they tell a worse one than the truth.

Which signals raise your risk

Imagine you are that algorithm. You're handed a construction firm's profile and asked to judge whether it's worth sending an inspector there. What do you look at?

1. Lots of construction work, zero OSH costs

This is the strongest signal. A firm issues invoices for site work - roofs, facades, finishing - while the costs show nothing when it comes to OSH. No invoices for:

• OSH training (induction, periodic),
• medical examinations of workers,
• personal protective equipment (PPE) - helmets, harnesses, gloves, footwear,
• OSH professional services or OSH supervision.

If someone works at height and for a whole year hasn't bought a single harness or helmet, that's a red flag to the algorithm. Because either people work without protection, or someone's playing games. Either way - worth checking.

2. Subcontracting and chains of orders

Construction runs on subcontracting. The main contractor takes the job, subcontracts, that party subcontracts further. The data shows these chains. A firm that mainly subcontracts to large developers and has no OSH costs of its own is more interesting to the inspectorate than a firm with a proper spending structure. Because it's often in these chains that responsibility for safety gets lost.

3. Rapid revenue growth without a rise in labour costs

A firm suddenly does twice as much, but labour and OSH costs stay put. This can mean undeclared work or overloading the same people. The algorithm will flag it as an anomaly.

4. PKD 43 in itself

Let's be honest - PKD 43, specialised construction work, is the industry with the highest accident rate. The mere fact that you hold this code places you in a group of heightened interest. This is not a punishment, it's statistics. But it's worth knowing.

Why "small firm = invisible" has stopped working

The old logic rested on the fact that the inspector physically can't get around everyone. That's true - they can't. But the algorithm doesn't have to get around anyone. It processes the data of all firms at once, at the same time, and points out the most suspicious. Your size has stopped protecting you, because you're no longer a needle in a haystack - you're one row in a table that the system can read.

On top of that comes a second thing: inspections no longer have to mean a visit to the site. PIP conducts part of its activity remotely - summonses, requests for documents, conversations. I wrote about this separately, because it's important especially for firms with a Ukrainian crew: see the text on how PIP remote inspections work. In short: today it's easier to check you than it used to be, because nobody has to travel anywhere to reach you.

So no - being small no longer hides you. But that doesn't mean you should panic.

What this means in practice for your firm

Take it easy. It's not that if you have PKD 43 you'll have an inspector on your doorstep tomorrow. It means this: if your profile in the data looks healthy, you're low on the list. If it looks suspicious, you're higher. That's it. Your job is to look like a firm that takes OSH seriously - because if you're going to do it safely anyway, then just let it show.

The worst-case scenario is a firm that actually does buy helmets and send people to training, but does it "off the books", in cash, with no invoices. In the data it then looks like a firm that does nothing - and lands high on the list, even though it's fine. A stupid loss.

How not to be first on the list: a concrete checklist

It's not about gaming the system. It's about doing OSH normally and having it show in the paperwork. Here's what really lowers your risk profile:

1. Buy PPE on an invoice. Helmets, harnesses, gloves, boots, goggles - all invoiced to the firm. It's both a cost and proof that you look after your people.
2. OSH training on an invoice. Induction for every new hire, periodic on time. Leave a trace in KSeF.
3. Medical examinations. Induction and periodic, on an invoice from the clinic. No medicals is a classic reason for a fine.
4. Have OSH documentation ready. Occupational risk assessment, job-specific instructions, registers, a BIOZ plan (health and safety plan) where needed, IBWR (safe-work instructions) for specific works. It's the first thing the inspector asks for.
5. Sort out subcontracting. If you subcontract, be clear about who is responsible for whose OSH - in writing.
6. Don't work off the books. It sounds trite, but in the KSeF era every gap in labour costs against rising revenue is a signal.

Notice that these are all things you should be doing anyway to be safe. The difference is that now doing them "on paper and on an invoice" additionally keeps you away from the inspection list. Two birds with one stone.

What NOT to do - so you don't get caught out stupidly

• Don't pretend there's no issue. "This doesn't apply to me, I'm too small" is exactly the thinking the reform breaks down.
• Don't knock up documents at the last minute, the day before an inspection. Dates and logic have to hold together.
• Don't cut OSH costs to make your bottom line look nicer. On OSH, cost-cutting shows up most clearly in the data.
• Don't leave the papers for "later". A fine of up to 5 000 zł for missing basics is more than proper documentation costs at the start.

Ready-made OSH documentation: sort it once, sleep easy

I know how it is. You work on site all day, and in the evening you still have to sit down to paperwork you don't understand. That's why we made ready-made OSH documentation packages for micro construction firms under PKD 43 - you fill in your details and you have a complete set that will stand up to an inspection.

• STARTER - 299 zł. 10 files: occupational risk assessment, job-specific instructions, registers and a PIP checklist. The minimum to have the basics and not show a blank in the paperwork.
• STANDARD - 449 zł. 27 files: everything in STARTER plus training, medicals, a BIOZ plan and PPE. This is the version that really reflects that you do OSH - which is exactly what lowers your risk profile in targeting.

There's also FULL for 749 zł with IBWR for 6 types of work, a package for developers, documents in Ukrainian and a ready-made kit for responding to PIP - if you subcontract to the big players or have a Ukrainian crew, this is the version for you. The promotion runs until 7 July 2026, right up to the start of the reform.

See BudoReady packages

The cheapest and calmest route is to have this sorted before the algorithm takes an interest in you. After that, you're just putting out fires.

This article is for information only and does not replace advice from an OSH specialist or the current state of the law. Document templates require individual adaptation to the realities of your firm and specific jobs, and the current legal state is worth verifying as at the date of use.