What Penalties Can ZUS Impose? A Ninefold Increase in Sanctions from 2025 – What Employers Face

From 1 June 2025, new and significantly stricter regulations concerning the liability of social security contribution payers have been in force. These changes are of enormous practical importance, as the maximum fine for offenses against the provisions of the Act on the Social Insurance System has increased from PLN 5,000 to as much as PLN 46,000. This represents more than a ninefold increase in penalties and genuinely changes the approach to inspections and employer liability. For this reason, the question “What penalties can ZUS impose?” has taken on particular significance today—especially for entrepreneurs, HR departments, and individuals responsible for personnel and payroll matters.

TABLE OF CONTENTS 

1. Why have ZUS penalties increased so dramatically?
2. The most common offenses against the provisions of the Social Insurance System Act
3. What penalties can ZUS impose? – a full catalogue of sanctions
4. Employer, familiarize yourself with the regulations before it is too late
5. FAQ

Why Have ZUS Penalties Increased So Dramatically?

The legislator explicitly indicated that the previous sanctions did not fulfill their preventive function. Inspections conducted by the Social Insurance Institution (Zakład Ubezpieczeń Społecznych, ZUS) revealed numerous and recurring irregularities, such as:

• failure to register employees for social insurance,
• failure to pay contributions on time or in the full required amount,
• lack of contribution-related documentation,
• obstructing or preventing inspections,
• providing false information.

The amendment to the Act on the Social Insurance System and the Act on the Labour Market and Employment Services aims to genuinely strengthen employee protection, increase social security safety, and discipline unreliable contribution payers.

Which offenses are punishable by a fine of up to PLN 46,000? Until 31 May 2025, the acts indicated in Article 98 of the Social Insurance System Act were punishable by a fine of up to PLN 5,000. From 1 June 2025, the upper limit of the penalty is PLN 46,000.

The Most Common Offenses Against the Provisions of the Social Insurance System Act

1. Failure to pay contributions within the statutory deadline – Even partial non-payment of due contributions may be considered an offense.
2. Failure to report data or reporting false data – This includes, among other things, failure to register an employee for insurance or providing incorrect data affecting the amount of contributions.
3. Refusal to provide explanations or providing false information – Particularly significant during inspection activities.
4. Obstructing or preventing a ZUS inspection – Examples include:
   • lack of access to documents,
   • refusal to allow entry to the company’s premises,
   • preventing the conduct of an on-site inspection.
5. Failure to maintain contribution-related documentation – This refers to a complete failure to keep documentation, not merely unreliable or inaccurate documentation.
6. Late submission or failure to submit declarations and reports – Applies to settlement declarations and individual monthly reports.
7. Submitting documents in an improper form – Documents submitted in a form other than that specified by law are treated as not submitted at all.

What Penalties Can ZUS Impose? – A Full Catalogue of Sanctions

ZUS has a broad range of legal instruments at its disposal. Not all of them are financial in nature, but all are onerous.

• Late payment interest – Charged for each day of delay, starting from the day following the payment deadline until the date the arrears are settled.
• A fine of up to PLN 46,000 – Imposed, among other things, for:
  • failure to pay contributions,
  • failure to submit declarations and reports,
  • obstructing inspections,
  • providing false data.

The amount of the fine depends on the seriousness of the violation and the circumstances of the case.

• Additional fee – up to 100% of overdue contributions – Discretionary in nature and applied mainly to contribution payers who:
  • persistently evade payment,
  • grossly violate contribution-related obligations.

The decision may be appealed to a court.

• Obligation to submit corrections and make additional payments – ZUS may require the payer to:
  • submit corrected documents,
  • pay missing contributions,
  • organize and rectify documentation.
• Enforcement proceedings – In the event of long-term arrears, the following may occur:
  • seizure of a bank account,
  • garnishment of wages,
  • seizure of tax refunds,
  • enforcement against assets.
• Notification of law enforcement authorities – Applies to the most serious violations, such as:
  • persistent non-payment of contributions,
  • falsification of documents,
  • actions detrimental to employees.

Examples of Violations and Possible Sanctions

Court jurisprudence clearly confirms that ZUS actively uses the tools at its disposal. Financial penalties, enforcement actions, and criminal proceedings are real consequences of negligence – not merely theoretical threats.

Employer, Act Before It Is Too Late

This is a good moment to carry out internal verification activities and ensure that all obligations towards ZUS are being fulfilled correctly. The violations listed above are only part of the catalogue that may result in a fine of up to PLN 46,000.

If you need support—we can help organize processes, analyze risks, and prepare your organization for the new regulations. Learn more about our service: ZUS Shield – professional support during ZUS inspections.

FAQ

What penalties can ZUS impose for failure to pay contributions?
Interest, a fine of up to PLN 46,000, an additional fee of up to 100% of arrears, and enforcement measures.

Is partial payment of contributions also an offense?
Yes, failure to pay contributions in full may also be considered an offense.

Can a ZUS penalty be appealed?
Yes, ZUS decisions may be appealed to a court.

Does ZUS always impose the maximum penalty?
No, the amount of the penalty depends on the circumstances of the case and the degree of the violation.

Is obstructing an inspection a serious offense?
Yes, it is one of the more serious violations and is often severely penalized.

Do the new regulations also apply to small companies?
Yes, they apply to all contribution payers—regardless of company size.

Author:
Ewa Branicka-Kublik, Junior Manager