A Labour Inspectorate (PIP) Inspection at a Physiotherapy Practice - What the Inspector Checks

Sanepid, KIF, UODO - practice owners usually know about these inspections. The National Labour Inspectorate (PIP) appears on that list less often, and that is a mistake: one person employed on a contract of employment, a civil-law contract or even cooperating B2B is enough to put your practice within the labour inspector's remit. Autumn is also the typical season for "HR housekeeping" - after summer hires and rotations it is worth checking whether employee files are complete. A PIP inspection covers a different area than a KIF inspection or Sanepid: the inspector is not interested in the quality of therapy, but in the legality of employment, working time, wages and occupational safety.

This article explains when PIP visits a practice, which documents it checks, how an inspection runs and what you can tidy up in advance to pass it calmly.

When PIP inspects a small practice

The inspectorate runs planned and intervention inspections. For small entities the most common scenarios are:

• A complaint from an employee or ex-employee - the most frequent trigger. A dispute over overtime, unpaid wages after a parting, no written contract.
• Legality-of-employment checks - including employment of foreigners; if you employ, say, a physiotherapist from Ukraine, the inspector will also check work-legalization documents - we covered this in the article on hiring a physiotherapist from Ukraine.
• A workplace accident - a reported accident triggers an inspection of the circumstances and the post-accident documentation.
• Thematic campaigns - PIP runs cyclical actions in selected industries, including civil-law contracts performed under employment-like conditions.

A labour inspector may inspect at any time the practice operates, based on their service ID and authorization. In practice they usually make contact beforehand to set a date and a document list - but they do not have to.

What the inspector checks - five main areas

1. Legality of employment and contract types

This is the highest-risk area in physiotherapy, where B2B cooperation and mandate contracts are common. The inspector looks at how the work really runs, not what the contract is called. If a person on a B2B contract works fixed hours set by you, under your direction, at your premises and on your equipment - the inspector may find an employment relationship hidden under another contract. We described the criteria and reclassification risk in detail in contract vs employment.

2. Employee documentation

For every employee you keep personnel files and employment-related documentation. The inspector will check completeness: contracts, statements of employment conditions, confirmations of familiarization with the work rules, job scopes, OSH training records and medical certificates.

3. Working time and records

Working time records are the document the inspector asks about almost every time. At a practice where the schedule follows patient bookings, irregularities creep in easily: hours beyond the norms without overtime settlement, no 11-hour daily rest when morning and evening shifts are combined, records reconstructed "from memory" at month end.

4. Wages

Timeliness of payments, deductions, overtime pay, and for mandate contracts - the minimum hourly rate and the record of hours worked. The inspector may request transfer confirmations.

5. OSH and medical examinations

The occupational risk assessment, initial and periodic training, medical certificates of no contraindications to work, plus conditions at the practice itself: equipment condition, first-aid kit, escape route signage. We devoted a separate article to OSH and the occupational risk assessment.

The documents the inspector will ask for

Area	Documents
Employment	Employment contracts, mandate contracts, statements of employment conditions, work certificates from previous employers
Working time	Working time records, schedules, leave requests, overtime settlements
Wages	Payrolls, payment confirmations, hour records for mandate contracts
OSH	Occupational risk assessment, OSH training cards, medical certificates, accident register
Foreign workers	Documents legalizing stay and work, notifications and permits
Internal	Work rules (if required), working time notice, job scopes

If you cooperate exclusively B2B, prepare the cooperation agreements and be ready to explain how the work is organized - it is the actual organization, not the paper, that drives the inspector's assessment.

How an inspection runs

A typical flow looks like this:

1. Presentation of the ID and authorization - the inspector states the scope of the inspection.
2. Site visit and interviews - the inspector may view workstations, question staff (also without you present) and demand written explanations.
3. Document review - some documents are reviewed on site, others you may deliver by a set deadline.
4. The inspection protocol - records the findings; you have the right to raise objections before signing.
5. Post-inspection measures - depending on the findings: a formal request to remove irregularities, an order (e.g. in OSH or payment matters), an instruction, and for offences against employee rights - a fine notice or a court motion.

Example: An inspector came to Adam's practice after a complaint from a former receptionist about her final month's settlement. The inspection started with wages but, as standard, also covered working time records and OSH. It turned out the wages had been paid correctly - but the working time records were filled in once a month and did not match the schedules, and one physiotherapist's periodic medical examination had expired. The complaint was not confirmed, yet Adam received a formal request to keep records on an ongoing basis and sent the employee for examinations. The lesson: an inspection triggered by one complaint almost always covers more areas than the complaint itself.

How to prepare the practice in advance

The best moment for housekeeping is when no inspection is on the horizon:

• Review employee files - completeness, valid examinations and OSH training are easiest to verify with a quarterly checklist.
• Keep working time records current - do not reconstruct them backwards; a mismatch between schedule and records is a red flag.
• Sort out B2B and mandate contracts - check whether the cooperation shows features of employment; if it does, change the model before the inspector does it for you.
• Update the occupational risk assessment - after every change: new equipment, a new role, a new person.
• Assign one place for OSH documents - all training cards, certificates and the risk assessment in a single binder cut inspection time in half.

The same HR and OSH document set is useful beyond PIP - it partly overlaps with what Sanepid requires and belongs in every practice documentation audit.

Your rights during an inspection

An inspection is not an interrogation. As the inspected party you have rights worth using calmly:

• Check the ID and authorization - the scope stated in the authorization sets the limits of the inspection.
• Appoint a contact person - if you are treating patients during the inspection, agree with the inspector who provides explanations and when.
• Answer, but do not guess - if you do not remember a detail, say you will check and supplement your explanations in writing.
• Read the protocol before signing - you may file reasoned objections to the findings within the set deadline; a signature is not agreement with the findings.
• Respond to post-inspection measures on time - a diligent reply describing how you implemented the requests often closes the case without further steps.

Frequently asked questions

Can PIP inspect a practice with no one on an employment contract?

Yes. The labour inspectorate checks not only employers but also entities for which work is performed under civil-law contracts or by self-employed persons - among other things for legality of employment, the minimum hourly rate on mandate contracts, and whether the cooperation shows the features of an employment relationship.

Does a PIP inspector announce the inspection?

A labour inspector is entitled to inspect without notice, at any time the entity operates, based on a service ID and authorization. In practice they often make contact beforehand to arrange a date and documents, but they are not obliged to.

What are the consequences of irregularities found during a PIP inspection?

Depending on the type and weight of the findings, the inspector may issue a formal request to remove irregularities, issue an order (e.g. in OSH matters), and for offences against employee rights impose a fine notice or file a court motion. Reclassifying a civil-law contract as employment can additionally mean a court action to establish an employment relationship and contribution and tax consequences.

Which documents should I prepare before a PIP inspection at a physiotherapy practice?

The core set: contracts with everyone performing work, employee personnel files, working time records and schedules, payrolls with payment confirmations, the occupational risk assessment, OSH training cards, medical certificates and - for foreign workers - work-legalization documents. Documents kept current and stored in one place significantly shorten the inspection.

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Related articles:
- OSH in a physiotherapy practice - occupational risk assessment
- Physiotherapist contract vs. full-time employment
- Hiring a physiotherapist - contract and qualifications
- Employee job scope at a physiotherapy practice - why verbal arrangements backfire