For the first time in history, Christmas Eve will become a statutory public holiday in Poland. As of 2025, 24 December is officially added to the list of non-working days. For millions of employees, this is a long-awaited change. For employers, however, it is a significant legal development that requires proper organisational and compliance planning.
The new regulations not only modify the working calendar but also materially increase employers’ exposure to sanctions in the event of non-compliance – particularly in the context of inspections by the National Labour Inspectorate (Państwowa Inspekcja Pracy, “PIP”).
Christmas Eve (24 December) as a statutory public holiday
Pursuant to the Act of 6 December 2024 amending the Act on Public Holidays, Christmas Eve has been a statutory public holiday since 2025. In practice, this means that:
- employees are not required to take annual leave to have 24 December off,
- as a rule, employers may not require employees to work on that day,
- Christmas Eve is subject to the same legal regime as other public holidays.
As a result, the total number of statutory public holidays in Poland has increased to 14 days per calendar year.
Who may still work on Christmas Eve?
The legislator did not introduce separate exemptions specifically for Christmas Eve. Consequently, the general rules set out in Article 151¹⁰ of the Polish Labour Code apply, specifying situations in which work on Sundays and public holidays is permitted.
Work on Christmas Eve is allowed, among others, in the following cases:
- emergency and rescue operations (protection of life, health, property or the environment),
- continuous operations and shift work,
- transport and public communication,
- protection of persons and property,
- energy supply and breakdown removal,
- agriculture and animal breeding,
- catering, hotels and 24/7 healthcare facilities,
- public utility services necessary to meet everyday social needs.
In such cases, the employer must grant a compensatory day off within the applicable settlement period, or – if this is not possible – pay the statutory holiday work supplement.
Retail trade on Christmas Eve – a general ban with numerous exceptions
The new regulations also apply to retail employees. As a rule, Christmas Eve is a non-working day for the retail sector, and the ban also covers persons engaged under civil law contracts.
However, the law provides for numerous exceptions. The following establishments may remain open, among others:
- petrol stations,
- pharmacies and pharmacy outlets,
- bakeries, confectioneries and ice cream shops,
- shops located at railway stations, airports and ports,
- kiosks (press, tickets, tobacco products),
- postal service outlets,
- online shops and e-commerce platforms,
- vending machines,
- retail outlets operating within hotels and cultural institutions,
- shops operated personally by the owner, with unpaid assistance from immediate family members (provided they are not employed under employment or civil law contracts).
A breach of the retail trade ban may result in a fine of up to PLN 100,000.
Civil law contracts and B2B arrangements – no statutory holiday protection
It is important to note that the statutory day off applies exclusively to employees engaged under employment contracts.
As a result:
- contractors under mandate contracts (umowa zlecenia) may work on Christmas Eve if this follows from their agreement,
- individuals operating under B2B arrangements treat 24 December as a regular working day,
- there is no statutory entitlement to a holiday supplement or a compensatory day off.
This area is already under increased scrutiny by the Labour Inspectorate, particularly in sectors such as logistics and courier services, where self-employment models are prevalent.
Inspections and significant penalties
The National Labour Inspectorate clearly states that:
- unlawfully requiring an employee to work on Christmas Eve constitutes an offence,
- fines range from PLN 1,000 to PLN 30,000,
- in the retail sector, penalties may reach PLN 100,000.
In practice, this necessitates a thorough review of work schedules, internal regulations and the legal basis for performing work on 24 December.
What should employers do now?
Introducing Christmas Eve as a non-working day is more than a symbolic change. From an employer’s perspective, it is advisable to:
- assess whether the company’s activities fall within the statutory exemptions under Article 151¹⁰ of the Labour Code,
- adjust work schedules and settlement periods accordingly,
- review civil law contracts and B2B cooperation models,
- prepare for potential inspections by the Labour Inspectorate.
Summary
The first non-working Christmas Eve in Poland represents a significant social and legal change. For most employees, it offers a tangible improvement in work-life balance. For employers, however, it introduces a new compliance obligation that must be addressed carefully and in full alignment with labour law requirements.
Employers should treat 24 December 2025 not merely as “another day off”, but as a fully protected public holiday with concrete legal and financial consequences.
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