New Employer Obligation from July 1, 2026:

What has been in place and what is changing

Act No. 323/2025 Coll. on the Unified Monthly Employer Report is effective from January 1, 2026. Employers have been using it since April 2026 for centralized electronic submission of monthly reports to the Czech Social Security Administration. Most obligations are thus already in practice.

However, the legislator chose deferred effectiveness for some provisions. Specifically, § 19 paragraphs 1 to 3 become effective only on July 1, 2026. Until now, the following rule applied for registering new employees: for Czech citizens, registration within 8 days of starting was sufficient, while for foreign employees, a stricter obligation existed — they had to be registered no later than before the commencement of work.

From July 1, 2026, the stricter rule extends to all employees without distinction. The state wants information about every employment even before the employee performs the first task at work. Companies accustomed to registering employees conveniently after their actual start must revise their process.

Online labor law training for the HR team can help companies adapt to the new rules and ensure compliance with the law.

Obligations under § 19 paragraph 1: what exactly and when

The basic rule of § 19 paragraph 1 is clear: the employer is obliged to register the employee in the employee register no later than before the commencement of their work. An employee can be registered no earlier than 8 calendar days before the expected start date.

In practice, this means that if an employee starts on Monday at 8:00, the registration submission must be delivered to the CSSA before this moment — at the latest on Sunday evening or Monday morning, but always before the person actually starts working. Registration made after the start of work, for example, on Monday at 9:00, is considered late under the law and constitutes an offense. We also discuss the practical impacts of the new deadlines and process settings for employers in the related update Unified Monthly Reporting in Practice: What to Watch Out for When Communicating with Payroll System Providers.

If an employee starts working before registration takes place, they are considered "unregistered" — and in such a case, companies face not only a fine for non-registration but also penalties for unreported work under the Employment Act, which can reach up to CZK 3,000,000.

In connection with this topic, information on immediate termination of employment may be useful, which is another important aspect of labor law.

Partial registration: practical solution for Czech employees

The law considers a situation where the employer does not yet have all the legally required information about the employee shortly before the start. For citizens of the Czech Republic (not for foreign employees), § 19 paragraph 2 introduces the concept of so-called partial registration.

In partial registration, the employer provides only basic identification information before the employee's start:

·        first name, last name, birth surname,

·        birth number,

·        place of birth,

·        nationality,

·        expected start date of employment,

·        employer's variable symbol.

The remaining information required for full registration must be supplemented by the employer within 8 days from the day the employee actually starts work. This two-step procedure responds to practical difficulties — for example, situations where the employee provides the necessary documents (health insurance confirmation, bank account details, etc.) only upon starting.

The concept of partial registration cannot be used for foreign employees — they must be registered in full, no later than before the commencement of work.

Obtaining information from the employee: what § 19 paragraph 3 allows

The new obligation to register employees before starting brings a practical problem: how to ensure that the employer has the necessary information? § 19 paragraph 3 answers this question by explicitly granting the employer the right to request the necessary information from the employee before the commencement of work.

This legal provision is particularly important from the perspective of personal data protection. While the employer is entitled to request the information in advance, the law also sets an explicit condition: this information may only be used for the purpose of registering the employee in the employee register. Any other use of the collected data is unauthorized and establishes the employer's liability.

In practice, this means that the employer should have a structured form or online questionnaire prepared, through which the new employee provides the necessary identification and employment-related information even before the actual start — for example, after signing the employment contract. Lawyers from ARROWS law firm recommend that this procedure is always supported by transparent information on personal data processing according to GDPR, with a clear definition of the purpose of processing.

Final Summary

The change brought by § 19 of the JMHZ Act from July 1, 2026, is simple in wording but challenging organizationally. The existing eight-day deadlines for registering new employees after their start are abolished and replaced by the obligation to register every employee before they first start working. The law offers relief in the form of a two-step procedure — partial registration for Czech employees, but this also requires prior organizational preparation and the establishment of a reliable data collection process from future employees.

For employers who relied on managing registration "somehow" within eight days after starting, this change poses a real risk of sanctions. Fines for non-registration can reach up to CZK 100,000, and combined with penalties for unreported work, the total liability of the company can quickly escalate to significantly higher amounts.

Lawyers from ARROWS law firm address the issue of JMHZ comprehensively — from setting up internal HR processes and GDPR documentation to representation during inspections or defense against imposed sanctions. If you are unsure whether your company is prepared for the change from July 1, contact consultation@arws.cz.