A labour inspector from the State Labour Inspectorate asks about the initial OHS training of a new employee, and the business owner replies: “it was done, the foreman walked them through it on day one”. The inspector’s first request then sounds like this: “Please show me the initial OHS training card”. Without it there is no proof that the instruction took place - and allowing an employee to start work without the required training is an offence carrying a fine of PLN 2,000 to PLN 60,000 (art. 283 § 1 of the Labour Code), twice as high as before July 2026.

What the initial OHS training card is for

The duty to train an employee before allowing them to start work follows directly from art. 237³ § 2 of the Labour Code, and the way this training must be documented is set out in the regulation on training in the field of occupational health and safety. Under § 12 sec. 1 of that regulation, the completion of the general instruction and the job-specific instruction is confirmed by the employee and the head of the organisational unit on paper or - since 12 December 2025 (Journal of Laws 2025 item 1640) - also electronically. In the paper variant the confirmation is made in writing in the initial training card, which is kept in the employee’s personal file. In the electronic variant the employer adds an annotation in the card where the signature would go and attaches an electronic document, or a reproduction thereof, containing the confirmation of the completed training. In practice the card goes into part B of the personal file - the same place where certificates of completed periodic OHS training are filed.

The card serves three roles at once. For the labour inspectorate it is evidence that the training duty has been fulfilled. For the employer it is a safeguard in accident proceedings, because the accident report establishes, among other things, whether the employee knew the safety rules applicable to their work station. For the employee, in turn, it is a confirmation that they received the instruction and know what their work involves.

What the template looks like - section by section

The card template is defined in annex no. 2 to the regulation, in the wording given by the regulation of 29 May 2019 (Journal of Laws 2019 item 1099). The form is short, but every section has its job:

Template section	What it contains
Header	identification of the employer
1	name and surname of the person taking the training
2	name of the organisational unit
3	general instruction: date of delivery, name of the instructor, signature of the trained person
4	job-specific instruction: work station, days of delivery, instructor, result of the knowledge test and permission to work, signature of the trained person, plus the date and signature of the head of the organisational unit

Section four comes in two variants: the basic one and a supplementary one, filled in for the cases listed in § 11 sec. 1 point 2 and sec. 2-3 of the regulation - that is, when an employee is transferred to a manual work station or one exposed to harmful factors, when they work at several stations, and when technical or organisational conditions change. The employee’s signature is not decoration here - under the template it confirms that the instruction took place and that the employee has read the safety regulations and rules relevant to their work.

How to fill in the card step by step

The card is filled in “along the way” as the instructions are delivered, but a well-prepared employer has the form ready before the new person crosses the company threshold. The sequence looks like this:

Prepare the form before the first day of work - use the template from annex no. 2 to the regulation and fill in the employer’s details, the employee’s data and the name of the organisational unit.
Record the general instruction - it is conducted by the in-house OHS service employee, a person performing the OHS service’s duties, the employer personally, or a designated employee holding a valid certificate of completing the required OHS training (§ 10 sec. 2); the entry includes the date, the instructor’s details and the employee’s confirmation.
Carry out the job-specific instruction - this is done by a designated person supervising the employees or by the employer, provided they have the qualifications, professional experience and training in instruction methods (§ 11 sec. 5); the card receives the work station, the days of delivery and the instructor’s details.
Close the training with the test and the permission to work - job-specific instruction ends with a test of knowledge and skills (§ 11 sec. 6), and a positive result is recorded in the card together with the employee’s signature, the date and the signature of the head of the organisational unit.
File the card in part B of the personal file - and remember that every subsequent job-specific instruction, required after a transfer, a change of conditions or work at several stations, is documented in section 4 of the same card.

If any section remains empty, it is worth asking not “when will it get filled in”, but “what does it prove”. A missing date at the general instruction undermines the “training first, work afterwards” order, and a missing signature of the unit head leaves the permission to work without a formal closure.

The most common mistakes in initial training cards

The most frequently encountered mistake is filling in the cards late, in batches at the end of the week or the month. A date of instruction later than the day the employee started work destroys the whole construction of the duty under art. 237³ § 2 of the Labour Code, because the provision assumes the training happened before work began. In the event of an accident, such a card works against the employer instead of protecting them.

The second mistake is treating the card as a one-off document. After an employee is transferred to another work station or a new machine is introduced, nobody returns to section 4, even though § 11 of the regulation requires another job-specific instruction in such cases - and a new trace in the card.

The third mistake is mixing up documents. The initial training card confirms the instructions delivered before starting work, whereas completed periodic training is documented by a certificate issued according to the template in annex no. 3 to the regulation, granted after an examination before a commission. It is also worth using the current template: the one in force comes from the 2019 amending regulation, which entered into force on 28 June 2019, so older forms “from the internet” are out of date.

Key takeaways

The initial OHS training card is the proof that general and job-specific instruction took place - without it the training “does not exist”, even if it actually happened.
The template has four sections, and section 4 documents the knowledge test and the formal permission to work, confirmed by the signatures of the employee and the head of the organisational unit.
The card is kept in part B of the personal file and completed at every repeated job-specific instruction.

FAQ - the most common questions about the initial OHS training card in Poland

Does the initial OHS training card have to be on paper? Not since 12 December 2025. The regulation (as amended by the Journal of Laws 2025 item 1640) allows the completion of both instructions to be confirmed on paper or electronically (§ 12 sec. 1). In the paper variant the card with handwritten signatures in part B of the personal file still applies; in the electronic variant the employer places an annotation in the card where the signature would go and attaches an electronic confirmation document or its reproduction.

Who fills in the initial OHS training card? The employer fills in the employee’s and the organisational unit’s data. The date and signature at the general instruction are entered by the person conducting it, and the same applies to the job-specific instruction. The employee confirms with their signature that the instructions took place, and the head of the organisational unit formalises the permission to work with the date and signature.

Is a new card opened when an employee is transferred to another work station? No. A new card is created with a new employment relationship. A transfer to a manual or exposed work station, work at several stations and a significant change of technical or organisational conditions require another job-specific instruction, documented in section 4 of the same card (§ 11 sec. 1 point 2 and sec. 2-3 of the regulation).

Does the card replace the certificate of completed OHS training? No. The card concerns initial training. Periodic training ends with an examination before a commission appointed by the training organiser, and its completion is confirmed by a certificate issued according to the template in annex no. 3 to the regulation, which also goes into part B of the personal file.

What are the consequences of a missing card or missing signatures? If the instructions are not documented, the company cannot demonstrate that it has met the duty under art. 237³ § 2 of the Labour Code - a violation of OHS regulations carrying a fine of PLN 2,000 to PLN 60,000 (art. 283 § 1 of the Labour Code). After an accident, the card is one of the first documents examined in the accident proceedings.

Keeping the documentation in order starts with checking that every employee has a card with a complete set of signatures and dates. If you are unsure what initial OHS training in Poland must cover, read our guide to initial OHS training: what it covers, how long it takes and who conducts it. For the training deadlines of each job group, see our OHS training offer, and if you have questions about training documentation in your company, contact us.

Sources

Legal status: September 2026. This article is for information only and does not constitute legal advice. For individual cases consult a lawyer or an OHS specialist.