CWTON and PIP Inspection in STR 2026: 12 Things the Inspector Checks

CWTON and PIP Inspection in STR 2026: 12 Things the Inspector Checks

The Polish Labour Inspectorate (PIP) has been systematically inspecting STR hosts who employ cleaners on civil contracts since 2025, looking for hidden employment relationships. The fine for each unlawfully employed worker is up to PLN 30,000. See the 12-point checklist a PIP inspector goes through in 2026.

The introduction of CWTON and automatic DAC7 reporting means PIP receives a list of STR hosts together with annual nights data. On that basis it estimates how many cleaners, check-in agents and maintenance people the host must use, and concludes whether the host runs a legal employment model. From January 2026 PIP launched targeted STR inspections based on:

• Article 2(2) of the Act of 13 April 2007 on the Polish Labour Inspectorate
• Article 22(1) of the Polish Labour Code (criteria of an employment relationship)
• Article 281(1) of the Labour Code (penalties for breaches in employment)

Why STR Hosts Are on PIP's Radar

Three reasons:

1. The STR sector has a very high share of informal work (cleaners on "civil contracts")
2. DAC7 reveals the actual scale of host activity
3. Competitors notify PIP (anonymous tips)

12 PIP Inspection Points in STR

Point 1: contract type with the cleaner

The most common allegation. A cleaner who has been cleaning 5 days a week for 2 years, in hours set by the host, using their cleaning supplies and key, is in fact in an employment relationship (Article 22 of the Labour Code). The civil contract is a sham. Sanction: ZUS contributions and tax assessment, fine PLN 1,000 to 30,000.

Point 2: minimum hourly rate for civil contracts

A contractor must receive at least PLN 30.50 gross per hour (2026 rate). PIP checks payroll, hours worked and earnings. Below the minimum: fine up to PLN 30,000.

Point 3: hours register

A regular contractor must have an hours register (Article 8b of the Polish Minimum Wage Act). No register means a fine of PLN 1,000 to 30,000.

Point 4: ZUS contributions on civil contracts

If the cleaner has no other social security title, the host must pay ZUS on the contract (pension, disability, accident, health). No contributions means KKS proceedings and a ZUS fine up to PLN 5,000.

Point 5: medical exams and OHS training

Employees (employment contract) must have initial and periodic medical exams plus OHS training. Checked during PIP inspection. Fine for missing them: PLN 1,000 to 30,000.

Point 6: working time and rest

An employee cannot work more than 8h/day and 40h/week (with exceptions). Must have 11h rest between days. STR cleaners often work two flats in one day, breaching these rules.

Point 7: annual leave

20 days per year (up to 10 years tenure) or 26 days (above 10 years). The employee must actually use it. No leave means fine up to PLN 30,000.

Point 8: pay topped up to minimum wage

Polish minimum wage 2026: PLN 4,666 gross. A full-time employee must receive it regardless of hours worked (if they were ready to work).

Point 9: declaration to the civil contract

The contractor must file a declaration about other ZUS social security titles. Without the declaration, everything is treated as a full-rate contract (contributions on the full amount), which is more expensive for the host.

Point 10: pay timeliness

An employee's salary must be paid by the 10th of each month for the previous month. Contractor's pay: per the contract, but no later than one month after service performance.

Point 11: work and pay regulations

An employer with at least 50 staff must have work regulations. Smaller (20 to 49) must also have internal procedures. STR with 5 cleaners is usually below the threshold, but basic rules must still be written down.

Point 12: PIP-RPLO (compensation when civil contract is reclassified as employment)

If PIP finds that a civil contract was actually employment, the cleaner is entitled to wage top-up (leave, overtime, night shift premium). Backdated up to 3 years.

Table: Civil Contract vs Employment for an STR Cleaner

Feature	Civil contract	Employment relationship
Subordination	None (contractor decides)	Full (host directs)
Place of work	Free choice	Specified
Working time	Free	Fixed hours
Tools	Own	Employer's
Personal performance	Can subcontract	Personal only
Pay	For result	For time
Min. rate	PLN 30.50/h	PLN 4,666/m
ZUS contributions	Partial (with options)	Full
Leave, sick pay	None	Full

How to Tell Your Cleaner Is Actually an Employee

The PIP test: if all of the following are true, you have employment:

• Cleans regularly at your place at least 3 times a week
• Works at hours you set (e.g. 11:00 to 14:00 after check-out)
• Uses your supplies, cloths, vacuum cleaner
• Needs a key you gave them permanently
• Cannot subcontract a colleague, must come personally
• Works exclusively for you (no other clients)

Sanctions for Unlawful Employment

Sanction scale in 2026:

• Fine for no employment contract despite an employment relationship: PLN 1,000 to 30,000 per worker
• ZUS assessment: employer 22% and worker 13.71% (3 years backdated)
• PIT assessment from the worker (12% or 32% scale)
• Wage top-up: difference between contract and employment (leave, overtime)
• Criminal sanctions: PIP fine up to PLN 30,000, criminal fine up to PLN 30,000

Host Strategies: How to Avoid PIP Inspections

Strategy 1: B2B instead of civil contract

The cleaner registers a sole proprietorship and issues VAT invoices for services. This is a clean B2B contract not subject to PIP. It requires the cleaner to have several clients (not only you), her own tools and to organise her work independently.

Strategy 2: contract a cleaning company

You hire a cleaning company (sp. z o.o. or JDG). The company sends staff and bears responsibility for contracts and ZUS. Cost: 25% to 35% higher than individual contracts but eliminates PIP risk.

Strategy 3: full employment for 1 person

You employ 1 person full-time (PLN 4,666 gross, employer ZUS ~22% = ~PLN 5,700/m). That person cleans, does check-in, minor repairs, supply runs. Requires scale (at least 5 flats) but gives complete peace of mind.

Frequently Asked Questions

Does a retired cleaner also need ZUS contributions?

A retiree drawing a pension already has a social security title and does not need pension or disability contributions on a civil contract. Only the health contribution applies. That is why retirees are attractive cleaners from the employer cost perspective.

Does a student under 26 also need ZUS?

A student under 26 hired on a civil contract (not employment) is fully exempt from ZUS. Only PIT 12%/32% and student health contribution. Ideal for seasonal contracts.

Can I employ a cleaner "off the books" as a friend?

No, that is undeclared work (illegal employment). PIP detects it immediately if the cleaner is regular. Fine: up to PLN 30,000 per worker, ZUS arrears, taxes. The most common cause of large STR fines.

What about PIT on civil contracts?

The payer (you as host) deducts PIT 12% (or 32% above the threshold) from the gross less 20% deemed costs (for civil contracts). Pay-over: by the 20th of the next month. Without it: KKS fine.

How long does a PIP inspection in STR take?

Standard inspection: 1 day on site at the host, plus 5 to 10 days for follow-up meetings and document review. PIP decision: up to 60 days from completion. Appeal to the Chief Labour Inspector: 14 days.

Can I self-audit before PIP arrives?

Yes, PIP self-audit (form available on the PIP website) helps you spot gaps before the inspection. Filing a self-audit does not release you from liability but can be considered a mitigating circumstance.

To pass a PIP inspection without a fine, use the Standard Package HostReady. You receive the 12-point PIP checklist, a B2B contract template for cleaners, work regulations and support in preparing HR documentation.