Implementing the eFile is now one of the key steps in digitizing HR documents and transitioning from paper personnel files to electronic employee documentation. Although the law has allowed electronic personnel files for several years, the majority of companies still keep documents in binders. At the same time, more and more organizations recognize the benefits of such a change: quick access to documents from anywhere, reduced archiving costs, greater data security, and compliance with the Labor Code and GDPR. Below, you will find a coherent, practical guide on how to prepare for the implementation of the eFile, how to plan the digitization of personnel files, what the process looks like from a technical and legal perspective, and what, when, and where to report—including to the National Labor Inspectorate (PIP).
From Paper to eFile – Where to Start?
The first step is to realize that digitizing personnel files is not just a technical IT project, but a change in the way the entire HR department works. In a medium-sized company, the entire process of implementing the eFile—from needs analysis, system selection, document digitization, testing, and training, to full launch—can take about 12–15 weeks. It is worth starting with the preparatory stage: discussions with the HR department, management, and the legal department to clearly define which types of documents should be kept in electronic form (personal files parts A, B, C, D, E, and other employee documentation: time tracking, leave, payroll, health and safety). At the same time, it is necessary to ensure that the project complies with GDPR, the Labor Code, and the regulation on employee documentation—this is usually where support from the legal department and the system provider, who presents relevant compliance certificates, comes in.
Choosing the eFile System and the Role of the eFOB Platform
The next step is selecting the tool in which electronic personnel files will be managed. The eFOB Platform, described in this article, is an example of a solution designed for Polish labor law that has undergone an independent compliance audit.
A well-chosen eFile platform should provide:
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- Compliance with the regulation on employee documentation,
- User-friendly operation for the HR department,
- Features supporting the digitization of HR documents (e.g., splitting a large PDF file into individual documents),
- Configuration of document types in accordance with regulations,
- Support for electronic signatures compliant with eIDAS—SES, AES, and QES—along with integration with the employer’s qualified electronic seal (Qualified Electronic Seal),
- Data security (encryption, backups, strict access control) and scalability as the number of employees and documents grows,
- Integration with payroll systems, recruitment tools, or employee portals—making the eFile the central element of digital HR.
Organizing Paper Documentation Before Scanning
Before the scanner arrives, “homework” must be done in the archive. When digitizing personnel files, the key is to carefully organize each employee’s file. This means reviewing all documents, removing staples, paper clips, plastic sleeves, and arranging documents chronologically in parts A, B, C, and D in accordance with the current regulation. This is the stage where the HR team spends the most time, but it is here that the quality of future electronic employee documentation is built—if the paper file is chaotic, transferring the mess to the system will only make work more difficult.
Scanning should be organized so that the documentation of one employee is scanned in one session, preferably using a scanner with an automatic feeder and multi-page scanning to a single PDF file. Later, in the eFile system, such a file is split into individual documents.
Form vs. Type of Document – When Is a Qualified Signature Required?
When implementing electronic employee documentation, two issues must be distinguished: the form of the document and its type. The Labor Code, in some cases, requires maintaining the written form, for example, for employment contracts, non-compete agreements, or voluntary deduction agreements. In the electronic world, this means the need to use a qualified electronic signature (on the part of the employee and employer, if both parties make declarations). On the other hand, many other documents and applications—such as numerous leave requests, remote work requests, some parental applications, or information on employment conditions—only require maintaining an electronic form, not a written one. They can therefore be submitted and accepted via the system, employee portal, or email, without the need for qualified signatures on both sides.
A well-designed eFile system must therefore handle both scenarios: store documents signed with a qualified signature and allow convenient management of documents that only require an electronic form.
Table: Paper Documentation vs. eFile
Security, GDPR, and Document Retention
GDPR and employee documentation regulations impose specific requirements on eFile systems regarding security and accountability. The system should ensure data confidentiality (protection against unauthorized access), integrity (protection against unauthorized changes), and availability. In practice, this means the need for strict role-based access control, logging all changes and reads, the ability to search documents by metadata, regular backups, and preparing a business continuity plan.
More about security in the eFOB Platform: https://www.efob.pl/en/is-storing-documents-in-the-efob-platform-secure/
An important element is also the issue of document retention—i.e., the periods for storing files. For employment relationships established after January 1, 2019, employee documentation must be stored for the duration of employment and then for 10 years from the end of the calendar year in which the employment relationship ended. For older periods, 10- or 50-year rules apply, depending on whether information reports were submitted to ZUS. A system like the eFOB Platform has built-in support for legally compliant retention—it automatically monitors document storage deadlines, reminds of upcoming deletion periods, and helps maintain the data minimization principle required by GDPR.
More details and official information can be found on the gov.pl website at https://www.gov.pl/web/rodzina/akta-osobowe
Notifying the Change in Documentation Form to PIP
One of the important elements of preparing for the implementation of the eFile is fulfilling formalities with the National Labor Inspectorate. Converting the form of employee documentation from paper to electronic requires an official notification to PIP, resulting from Art. 94¹¹ of the Labor Code. The employer is obliged to inform the inspection of the change within 30 days from the date of starting to keep documentation in electronic form.
There is no strictly defined template for such a notification, but the practice is a written form—sent by registered mail or delivered in person to the appropriate regional labor inspectorate.
The notification should include:
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- Employer’s details (name, address, NIP, REGON),
- Information about the change in the form of keeping and storing documentation from paper to electronic,
- The date of starting to keep documents in electronic form,
- Confirmation that the electronic documentation will be kept in accordance with the requirements of the regulation on employee documentation—including those regarding confidentiality, integrity, completeness, and availability.
At the end of the document, there should be the signature of a person authorized to represent the employer.
It is also worth remembering that the digitization of personnel files is associated with readiness for a possible PIP inspection.
What Happens to Paper Files After Implementing the eFile?
After completing the digitization of personnel files and formally transitioning to electronic employee documentation, employees have the right to collect their paper files. The employer should organize this process so that employees have a real opportunity to collect the documentation at a convenient time—regulations indicate that at least 30 days must be given for this. If, after the specified period, the employee does not collect the documentation, the employer may destroy it based on Art. 94¹⁰ of the Labor Code. However, the regulations do not require immediate destruction—in justified cases, the employer may decide to continue storing both paper and electronic documentation, provided that compliance with data protection and retention regulations is maintained.
A New Company Without Paper – eFile from Day One
New companies that are just starting their operations are in a particularly privileged position. They do not have an archive that needs to be digitized, as they can keep electronic personnel files from day one. In their case, implementing the eFile primarily involves selecting the right system (e.g., eFOB Platform), configuring the documentation structure (parts A–E, thematic subfolders), and designing processes in a “digital version” from the start. The employment contract can be prepared and stored electronically, depending on the mode: signed in the office, then scanned and stamped with the employer’s qualified seal, while the original is handed to the employee, or signed remotely using a qualified electronic signature on both sides. Personal questionnaires, ZUS registrations, tax declarations, or leave applications can be entered electronically from the start, without going through paper.
When ending cooperation with an employee, the eFOB Platform facilitates the issuance and delivery of an electronic work certificate with a qualified signature and, upon the employee’s request, the issuance of a copy of the documentation in a form compliant with the regulation—as a package of documents with XML metadata files, compressed and stamped with a qualified seal.
Implementing the eFile from the HR Perspective – Initial Effort, Daily Relief
From the HR team’s perspective, implementing the eFile may initially seem like a huge amount of additional work: the archive needs to be digitized, procedures changed, managers and employees trained, the system integrated with the existing IT infrastructure, compliance with regulations ensured, and all this in a relatively short time. However, already in the first weeks after the system is launched, the HR department begins to feel real, daily benefits. Trips to the archive and tedious searches for files come to an end—documents are available in a few clicks. Audits cease to be a source of stress, as instead of compiling hundreds of paper files, the auditor can be provided with the appropriate data in electronic form.
Thanks to automation and data consistency in the eFile, there are fewer errors and inconsistencies in documents, and new HR employees learn the system faster and take over responsibilities. Working with a modern solution like the eFOB Platform develops digital skills, facilitates remote and hybrid work, and translates into higher job satisfaction. As a result, implementing electronic personnel files is not only about meeting legal requirements, but above all, an investment in the convenience and efficiency of the HR department’s daily work.
Summary
In summary, preparing for the implementation of the eFile includes analyzing needs, selecting a legally compliant system, organizing and scanning paper files, certifying their compliance with the original, assigning metadata, configuring the structure of electronic employee documentation, notifying the change of form to PIP, and regulating the issue of paper files and retention. Although the first stage is a significant organizational effort, a well-conducted implementation of the eFile transforms the HR department into a modern, digital document management center, not a “paper archive.”
FAQ – Frequently Asked Questions
Is the eFile mandatory?
No, but electronic documentation is equivalent to paper and facilitates HR work.
Do all files need to be scanned?
No. When switching to the eFile, there is no obligation to scan the entire archive at once. Digitization can be implemented in stages—for example, only for new employees, selected departments, or gradually according to an adopted plan.
Can documentation be kept partially on paper and partially electronically?
Yes, but with one limitation. For a given employee, each specific set of documentation (e.g., personnel files, leave documentation) must be kept in one form—paper or electronic. Forms cannot be mixed within one set, but different sets can be kept in different forms.
How long are eFiles stored?
Usually 10 years from the end of the employment relationship (for documentation after 2019).
Does PIP accept eFiles?
Yes—provided the system complies with the regulation and GDPR.
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