Legal Updates for Businesses in the Czech Republic: November 2026

The status of legislation and legislative proposals is captured as of November 11, 2026. This edition covers developments since October 16, 2026, i.e., from the date of publication of the previous edition inclusive. It also includes two decisions of the Supreme Court from early October, which were not covered in the previous edition.

Under the proposal, you will have to inform candidates of their salary before they sign a contract

The amendment to the Labor Code, which transposes the European Pay Transparency Directive into Czech law, passed its first reading in October 2026, and the Chamber of Deputies referred it to committees with a shortened thirty-day deadline. The Committee on Social Policy discussed it on November 11 and adopted no resolution – the proposal to recommend approval to the Chamber of Deputies failed by a vote of 7 to 9 (Committee Record No. 56, Chamber Print 300). This is a government proposal – the final version will only be known after approval; the committee result shows that there is no consensus on its form yet.

According to the proposal, most obligations are to apply from January 1, 2027, to all employers regardless of size. You would have to demonstrably inform job applicants about the minimum wage or salary level and other monetary benefits and perks they would be entitled to in the offered position from the start of employment – this does not refer to the statutory minimum wage, but to the lower limit of remuneration for the specific position.

You would have to provide this information at the latest before concluding the employment contract. You would not be allowed to ask about the salary from current or previous employment. The same is to apply to agreements on work performed outside an employment relationship (DPP and DPČ). Beware of a common misconception: the proposal does not require stating the salary in the job advertisement – it is sufficient if the candidate demonstrably receives it before signing the contract.

The second proposed novelty is a mandatory remuneration system. Jobs at an employer are to be divided into groups according to value, i.e., complexity, responsibility, and difficulty, and the system must be established in an internal regulation or a collective agreement. If you provide employees with benefits beyond their salary, you would need a separate system for them with objective and non-discriminatory criteria.

A second wave is to follow from January 1, 2028: employees will be able to request in writing information about their remuneration and the average remuneration of women and men in their job category, and the employer must respond within two months. Employers with 150 or more employees are to be included in pay gap reporting as early as 2028, and those with 100 to 149 employees in 2031. An unjustified gap of at least 5% that the company does not explain or remedy within six months will trigger a mandatory pay assessment with employee representatives.

For failing to create a remuneration system, failing to prepare a gender pay gap report, or failing to carry out an assessment, the government proposes a fine of up to CZK 1,000,000, and for other violations up to CZK 200,000 or CZK 400,000. The same proposal simultaneously rewrites the statutory characteristics of dependent work and, together with a separate act on platform work (Chamber Print 301), targets work mediated by applications.

By the end of the year, you should manage to do three things that make sense even if the effective date is postponed: remove the question about previous salary from recruitment questionnaires, prepare an offer template with the lowest salary for the given position and benefits, and map positions into job categories. You will then also use the job catalog for reporting from 2028. We covered this topic in more detail in the article Pay Transparency in 2026.

An employee fainting does not relieve you of liability for an occupational accident

By a judgment dated October 6, 2026, Case No. 21 Cdo 1913/2026, the Supreme Court overturned the decisions of both the regional and district courts and remanded the case for a new trial. A production operator fainted at work, fell onto a concrete floor, and suffered a serious head injury; she claimed CZK 661,013 for pain and suffering. The lower courts dismissed the lawsuit, stating that the fall was caused by an internal medical indisposition, not an external influence.

The Supreme Court rejected this. The element of "short-term, sudden, and violent action of external influences" under Section 271k of the Labor Code is assessed in relation to the injury itself, not the cause that led the employee to fall. The impact of the body on the floor is always an external influence – whether the employee slipped, tripped, or lost consciousness. It is different where the damage to health is a mere manifestation of an illness, typically a heart attack, and an external event is missing. Even then, however, it can be an occupational accident if it was preceded by a sudden exertion of strength, great effort, or unusual strain.

An employer's liability for an occupational accident is strict (objective liability) and can only be waived for reasons explicitly stated in Section 270 of the Labor Code, for example, in the event of a culpable violation of occupational safety regulations. The court recalled that the reason for exemption cannot be that the employee suffers from physical or mental deficiencies. The case was assessed under the wording of the Labor Code in force until June 30, 2024; the definition of an occupational accident remains the same today.

The argument "she fainted, so it is not an accident" will no longer hold up in court. In practice, this means: if an employee is injured by an impact during a fall while performing work tasks or in direct connection therewith, do not rule out an occupational accident just because the fall was preceded by nausea.

Investigate the event, record it in the accident log, and, depending on the consequences, prepare a report and fulfill reporting obligations (Section 105 of the Labor Code). However, the mere presence of an employee at the workplace is not sufficient for an occupational accident – it must always involve the performance of work tasks or a direct connection therewith. If you want to use an exemption, you need documented training and monitoring of compliance with occupational safety regulations.

You must be able to defend a discount for a board member as being in the company's interest

By a judgment dated October 1, 2026, Case No. 27 Cdo 629/2026, the Supreme Court overturned the decision of the High Court in Prague in a dispute between a cooperative, an authorized car dealer, and former members of its board of directors. Two of them and a close person purchased cars from the cooperative at approximately 72%, 88.5%, and 57.6% of the usual price, according to expert opinions submitted by the cooperative. The High Court excused the sales on the grounds that executives driving cars of the brand sold advertise the company and strengthen its goodwill.

According to the Supreme Court, the court cannot substitute such reasoning on its own. Under Section 52 of the Business Corporations Act, the burden of proof that they acted with due managerial care lies with the member of the body: they must assert and substantiate specific circumstances showing that the sale was in the interest of the corporation. If the appellate court concludes that the cooperative is not entitled to damages, it must also assess whether this constitutes unjust enrichment or another benefit to a member of the body, which under Section 61 of the same Act requires the consent of the body approving the service contract and the opinion of the supervisory body.

The member of the body must assert and prove themselves that a boss in a cheap car advertises the brand – the court will not invent this for them. At the same time, the Supreme Court confirmed that the sale of cars was a matter of ordinary business relations for the car dealership, so special rules on conflicts of interest did not apply. However, the duty of due managerial care does not disappear. The Supreme Court did not conclude that the discounts were an unauthorized benefit – that is yet to be assessed by the appellate court.

If you provide members of corporate bodies with discounts or other benefits, assess and document their business rationale and compliance with due managerial care. If it is another benefit under Section 61 of the Business Corporations Act, also follow the rules for its approval. Otherwise, you risk liability for damages and having to surrender the benefit.

Platforms and marketplaces will get a Czech regulator with fines based on a percentage of turnover

On November 4, 2026, the Chamber of Deputies approved the Digital Economy Act (Chamber Print 69). The Act supplements the European Digital Services Act, which has been directly applicable since February 2024 – it designates the Czech supervisory authorities, procedural rules, and sanctions. The bill was delivered to the Senate on November 12, 2026, and the Senate has until December 12, 2026, to consider it.

It applies to providers of intermediary services: connection, hosting and cloud, online platforms including marketplaces, social networks, and search engines. The government proposal envisages a fine of up to 6% of annual global turnover for most offenses; according to reports from the Chamber of Deputies, an amendment that aimed to cap fines at CZK 10 million did not pass. According to the government proposal, the Act is to take effect on the fifteenth day after its promulgation, which is very soon. Specific obligations depend on the service category: simple connection has different rules than hosting, online platforms have others, and marketplaces through which consumers conclude contracts with traders face the most extensive requirements.

If you operate a hosting service or a platform with user content, check your contact point for authorities, the mechanism for reporting illegal content, and moderation rules; for marketplaces, also check the verification of traders selling through you. Beware of a common misconception: these obligations do not apply only from the effective date of the Czech act – they flow directly from the European regulation. The act merely adds supervision and sanctions to them.

Briefly on other changes

Windfall tax for oil refiners. The government has proposed an extraordinary sector tax of 50% on the portion of the margin exceeding the 2025 level for oil refiners whose total annual revenues reach at least CZK 2 billion and whose refining revenues reach at least CZK 50 million per year, for the years 2026 and 2027. On November 11, the Budget Committee recommended approving the proposal, and it is scheduled for a meeting starting November 13. It does not affect other companies.

Access to the Register of Beneficial Owners. An amendment to the Act on the Register of Beneficial Owners introduces a procedure for verifying legitimate interest to access data and preserves special rules for selected authorized entities. On October 30, the Committee on Legal and Constitutional Affairs recommended its approval, with further discussion possible from December 15, 2026. Therefore, when conducting counterparty checks and in acquisitions, expect that you will need to verify under which legal title you have access to the data.

Energy audit. Since November 1, 2026, a new Decree No. 183/2026 Coll. on energy audits and energy management systems has been in force. The consumption of entrepreneurs linked by a share of at least 50% is aggregated even when linked through a foreign parent company, and the overall balance of proposed measures must show a saving of at least 10% of final energy consumption or CO2 emissions, otherwise the energy specialist must provide a justification. Audits already in progress will be completed under the old decree.

Third-country workers for agriculture, forestry, and food industry. Government Regulation No. 212/2026 Coll. introduces an extraordinary work visa from January 1, 2027, until the end of 2028 for citizens of Ukraine, Bosnia and Herzegovina, Georgia, Moldova, and North Macedonia. It can only be used by an employer involved in the government program, not by an employment agency.

Noise limits remain. By judgment Pl. ÚS 1/25, published in the Collection of Laws on October 26, 2026, the Constitutional Court rejected the senators' proposal to repeal the regulation on health protection against noise and vibration. Limits for workplaces and the surroundings of buildings remain unchanged.

Clarifying the deadline for sales registration. Following up on the October edition: notification of opting for a surcharge of CZK 1,400 per month instead of sales registration is submitted by flat-rate taxpayers in the first band whose last year's income from independent activity did not exceed CZK 1,000,000, by the tenth day of the tax period (Section 2b of the Income Taxes Act). It is also possible to opt in via the notification of entry into the flat-rate regime or a change of band. Since January 10, 2027, is a Sunday, the deadline is shifted under Section 33 of the Tax Code to Monday, January 11, 2027.

Deadlines for businesses to watch in the next 90 days

Summary

November has two distinct dimensions. Immediate action is required in response to two October decisions of the Supreme Court: in the case of injuries from a fall at work, do not rule out an occupational accident due to the medical cause of the fall, and for benefits provided to members of corporate bodies, document the business rationale and, if applicable, their approval. Before January 2027, finalize preparations for sales registration, the new minimum wage, and the withdrawal button. For now, it is sufficient to monitor the proposed amendment to the Labor Code on pay transparency and the Digital Economy Act – but both have proposed effective dates so close that it is worth starting preparatory steps now.

That is why we regularly prepare Legal News for Businesses in the Czech Republic. Without unnecessary legal theory. With an emphasis on what the change means for your business and what needs to be done.

Our Prague-based Czech legal team at ARROWS connects labor law, corporate affairs, digital services regulation, and taxes into a single perspective, so that the client does not receive several separate opinions, but a single decision with business sense. We will prepare your remuneration system, set up the approval of benefits for members of corporate bodies, represent you in occupational accident disputes, and review your platform. For professional liability, ARROWS law firm is insured with a limit of CZK 350,000,000. Write to us at consultation@arws.cz and we will go through your specific situation with you.

Related editions for the same month: Legal News for Businesses in Europe: November 2026 and Legal News for Businesses Worldwide: November 2026. The archive of all editions can be found at Legal News for Businesses in the Czech Republic.