“Complete all your OHS training online, without leaving the office” - practically every employer in Poland hears that promise today. Yet in the Polish regulation governing occupational health and safety training, the word “e-learning” never appears. That does not make online training illegal - it means its validity depends on the type of training and the job group. And since fines rose to PLN 60,000 (from 8 July 2026), choosing the wrong training format has become noticeably more expensive.

Where does “online OHS training” come from, if the regulations never mention it?

The legal basis for OHS training is the regulation of the Minister of Economy and Labour of 27 July 2004 on training in the field of occupational health and safety (consolidated text: Journal of Laws 2024 item 1327). It defines a closed catalogue of training forms: on-the-job instruction, a course, a seminar and guided self-study. E-learning is the colloquial name for that last form - the training industry adopted it for delivering a course over the internet, but in documents and during a labour inspection what counts is the statutory term “guided self-study” (samokształcenie kierowane).

Under the regulation, guided self-study is a training form that allows knowledge and skills in occupational health and safety to be acquired, updated or supplemented on the basis of materials provided by the training organiser, in particular by post or internet - combined with consultations provided by persons meeting the requirements for instructors. This provision has two consequences that are easy to overlook. First, the online course alone is not enough: the organiser must provide instructor consultations, because without them the form loses its legal basis. Second, the materials and delivery method must follow a programme based on the framework curriculum set out in the regulation - the e-learning platform does not replace the curriculum, it is only a tool for delivering it.

Who can take OHS training online, and who cannot?

The decisive restriction sits in the regulation’s provisions on periodic training. For manual workers, only on-the-job instruction is provided, repeated no less often than every 3 years (and annually for particularly hazardous work). The remaining groups - employers and anyone supervising employees, engineering and technical staff, the in-house OHS service and administrative and office staff - may take their periodic training as a course, a seminar or guided self-study.

Job group	Permitted periodic training formats
Manual workers	on-the-job instruction only
Employers, supervisors, engineering and technical staff, OHS service	course, seminar or guided self-study
Administrative and office staff	course, seminar or guided self-study

In practice, an office worker can renew their periodic training without leaving home, while a machine operator or a construction worker cannot. This is not a matter of goodwill or convenience: the instruction-only format for manual positions follows from the structure of the regulations themselves, because training for this group has a strong practical component at the specific work station. Full deadlines and the exemption that releases some offices from periodic training altogether are described in our article Periodic OHS training: how often? Deadlines for every job group.

And initial training? No e-learning there

Initial OHS training consists of general instruction and job-specific instruction, and the regulation provides for it exclusively the form of on-the-job instruction - conducted before the employee is allowed to work by the persons indicated in the regulations: the OHS service employee, the employer or a designated person with appropriate preparation. The catalogue of training forms does include guided self-study, but the provisions on initial training do not invoke it - unlike periodic training, where this form is listed explicitly.

This means “initial OHS training in 15 minutes online” is a product an employer should treat with particular caution. Some organisers combine online materials with live instruction - then the electronic element is only a teaching aid and the training formally remains instruction. What matters is that the mandatory scope is preserved (general and job-specific), the knowledge check after job-specific instruction takes place, and written confirmation is recorded on the initial training card. Allowing an employee to work without the required training risks a fine - we cover the new amounts in our article New OHS fines 2026. For details on initial training itself, see our guide Initial OHS training in Poland: what it covers, how long it takes and who conducts it.

Who may organise online training and how does it run?

OHS training is organised and conducted by the employer or - on the employer’s commission - a unit conducting training activity in the field of OHS, for example an entrepreneur running educational activity. With periodic training in the guided self-study form, the organiser is responsible for several things at once: a programme adapted to the job groups and working conditions, instructors with teaching qualifications, consultations available to participants and documentation of the training process.

The delivery form is only one element. Regardless of whether periodic training takes place in a room, on a webinar or on an e-learning platform, it ends with an exam verifying the knowledge acquired - conducted before a commission appointed by the training organiser. Only a positive exam result entitles the organiser to issue the certificate of completion in the template defined by the regulation. With e-learning, this exam usually takes the form of a test followed by an interview or verification involving the commission - what matters is that the commission genuinely functions, rather than existing only in the terms of service.

How to document online OHS training?

Documentation does not differ from classroom training, because the legal form matters, not the transmission channel. After initial training, the employee confirms in writing the completion of general and job-specific instruction on the initial training card, kept in part B of the personnel file. After periodic training, the organiser issues the certificate after a positive exam, and a copy also goes to part B of the personnel file. Note that the first periodic training for employers and persons supervising employees falls within 6 months of starting the position, and for other groups within 12 months. If you need to calculate specific deadlines for your team, use our interactive OHS training deadline calculator or check our OHS training offer.

How to implement online OHS training safely - a checklist

Before a company chooses an “online OHS” offer, it should work through a few steps. Check whether guided self-study is permissible in your case at all: manual workers need on-the-job instruction, so periodic e-learning is off the table for them. Verify the organiser - whether they conduct training activity in the field of OHS and deliver a programme based on the framework curriculum from the regulation. Make sure instructor consultations are included in the price, because that is a condition of this form’s validity. Ask how the exam before the commission works and when you will receive the certificate. Finally, arrange the document flow: the initial training card or a copy of the certificate must reach part B of each employee’s personnel file.

Key takeaways

E-learning OHS is legally guided self-study - a form allowed only for periodic training of employers, supervisors, engineering and technical staff, the OHS service and office workers.
Manual workers renew periodic training exclusively through on-the-job instruction, and initial training always takes the form of general and job-specific instruction.
Safe online training requires instructor consultations, an exam before a commission and complete documentation - missing any one element risks the training being deemed not taken.

Want to organise online OHS training for your company?

Lenax provides initial and periodic OHS training - on site, as webinars and in convenient e-learning form for the groups for which the regulations allow it. We will advise which format fits the positions in your company and take care of complete documentation. Check our OHS training offer or contact us.

FAQ - most common questions about online OHS training

Is OHS training taken over the internet valid? Yes, provided it takes place as guided self-study during periodic training for a job group whose members the regulations allow this form, and the organiser provided instructor consultations and an exam before a commission. A certificate from such training is fully valid.

Can initial OHS training be completed entirely online? The regulations provide for initial training exclusively the form of general and job-specific instruction, conducted by the persons indicated in the regulation. Online materials can be a teaching aid, but they do not replace instruction.

Who cannot take periodic OHS training online? Employees at manual work stations - their periodic training is conducted exclusively as on-the-job instruction, no less often than every 3 years, and annually at work stations where particular risks to safety or health occur.

How does the exam work with online OHS training? The same as with other forms: periodic training ends with an exam before a commission appointed by the organiser, and a positive result results in a certificate issued in the template from the regulation.

Must the employer pay for online OHS training? Yes. All OHS training takes place during working hours and at the employer’s expense - sending an employee to a paid training “after hours” violates the Labour Code.

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.

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