- online OHS training
- OHS e-learning
- periodic OHS training
- szkolenia BHP
"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: instruction (instruktaż), 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 instruction (instruktaż) 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, administrative-office staff and the other exposed or safety-responsible employees listed in § 14(2)(6) - may take their periodic training as a course, a seminar or guided self-study.
| Job group | Permitted periodic training formats |
|---|---|
| Manual workers | instruction (instruktaż) only |
| Employers, supervisors, engineering and technical staff, OHS service | course, seminar or guided self-study |
| Other employees covered by § 14(2)(6) | 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 practical component, including discussion of safe work methods and solutions to workplace problems. 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.
Initial training: the remote-work exception matters
Initial training generally consists of general and job-specific instruction, not guided self-study. However, art. 67³¹ § 2 of the Labour Code permits initial training entirely by electronic communication for an administrative-office employee whose remote work was agreed when concluding the employment contract. The employee confirms completion on paper or electronically. This is a specific statutory exception, not permission to replace every initial instruction with a generic online course.
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 completion is confirmed and recorded in accordance with § 12, including the permitted electronic confirmation. 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 appropriate knowledge, professional experience and teaching preparation, 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. The regulation does not prescribe a universal test-plus-interview sequence. The organiser must actually conduct the examination before the appointed commission and assess the required knowledge and skills; an automatically issued certificate after opening files is not enough.
Training of employers, OHS-service employees and instructors/lecturers in OHS topics is conducted by the training units specified in § 4(2); the general rule permitting employer-organised training must not be read as removing that restriction.
How to document online OHS training?
The documentation depends on the type of training. Since 12 December 2025, § 12 permits paper or electronic confirmation of initial instruction and admission to work. For electronic confirmation, the employer makes an annotation in the card’s signature field and attaches the electronic confirmation document or its reproduction; the complete record is kept in the personnel file. After periodic training, the organiser issues the certificate following a positive examination, and a copy is kept in part B. Initial periodic-training deadlines are six months for employers/managers and twelve months for the other groups subject to training. See 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 instruction (instruktaż), 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 permitted form for periodic training of the groups in § 14(2)(1) and (3)–(6), and for the training of an employer intending to perform OHS-service tasks under § 13. The specific electronic initial-training exception is a different legal route.
- Manual workers renew periodic training exclusively through instruction (instruktaż), and initial training normally requires general and job-specific instruction, with the specific remote administrative-office exception described above.
- 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? It can be valid if the statutory form, eligible group, programme, consultations, examination and documentation requirements are met. Guided self-study is available for the specified periodic-training groups and the § 13 employer training; the electronic initial-training exception has its own conditions.
Can initial OHS training be completed entirely online? Yes in the specific case in art. 67³¹ § 2: an administrative-office employee with remote work agreed at conclusion of the employment contract. Outside that exception, online materials alone do not replace the required initial instruction.
Who cannot take periodic OHS training online? Employees at manual work stations - their periodic training is conducted exclusively as instruction (instruktaż), 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
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Labour Code, including art. 67³¹: Journal of Laws 2026 item 1245
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Electronic initial confirmation amendment: Journal of Laws 2025 item 1640
Legal status checked: 15 October 2026. This article is for information only and does not constitute legal advice. For individual cases consult a lawyer or an OHS specialist.