New Obligation for Employers from 1 July 2026

What Was Valid Until Now and What Is Changing

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

However, the legislator opted for a delayed effective date for some provisions. Specifically, Section 19(1) to (3) will only take effect on 1 July 2026. Until now, the following rule applied to the registration of new employees: for Czech citizens, registration within 8 days of starting work was sufficient, while a stricter obligation existed for foreign employees—they had to be registered no later than before the moment they started work.

From 1 July 2026, this stricter rule will be extended to all employees without distinction. The state wants to have information about every employment relationship even before the employee performs their first work task. Companies accustomed to conveniently registering employees after they have actually started work must overhaul their processes.

Online labour law training for HR teams can help companies adapt to the new rules and ensure they are compliant with the law.

Obligations under Section 19(1): What and When Exactly

The basic rule of Section 19(1) is clear: the employer is obliged to register the employee in the employee register no later than before the moment they commence 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 AM, the registration application must be delivered to the Czech Social Security Administration (ČSSZ) before this time — at the latest on Sunday evening, or Monday morning, but always before the person actually starts working.

A registration made after work has started, for example, on Monday at 9:00 AM, is considered late under the law and constitutes an offence. We also discuss the practical impacts of the new deadlines and the setup of processes at employers in our follow-up article Unified Monthly Report in Practice: What to Watch Out for When Communicating with Payroll System Suppliers.

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

In connection with this topic, information on the immediate termination of employment may be useful, as it is another important aspect of labour law.

Partial Registration: A Practical Solution for Czech Employees

The law considers the situation where an employer does not yet have all the legally required employee data available just before the start date. Therefore, for citizens of the Czech Republic (but not for foreign employees), Section 19(2) introduces the institute of so-called partial registration.

With partial registration, the employer provides only the basic identification data before the employee starts:

·        first name, surname, birth surname,

·        birth number,

·        place of birth,

·        nationality,

·        expected start date of employment,

·        employer's variable symbol.

The employer is obliged to supplement the remaining data required for full registration within 8 days from the date the employee actually started work. With this two-step procedure, the law responds to practical difficulties—for example, situations where an employee provides the necessary documents (health insurance certificate, bank account details, etc.) only upon starting work.

The partial registration institute cannot be used for foreign employees — they must be fully registered no later than before they start work.

Obtaining Data from the Employee: What Section 19(3) Allows

The new obligation to register an employee before they start work brings a practical problem: how to ensure the employer has the necessary data at all? Section 19(3) answers this question by explicitly giving the employer the right to request the necessary data from the employee even before they start work.

This legal provision is particularly important from a data protection perspective. Although the employer is entitled to request the data in advance, the law also sets an explicit condition: the employer may use this data exclusively for the purpose of registering the employee in the employee register. Any other use of the collected data is unauthorised and establishes the employer's liability.

In practice, this means that the employer should have a structured form or online questionnaire ready, through which the new employee provides the necessary identification and labour-law data before they actually start—for example, after signing the employment contract. The lawyers at our Prague-based ARROWS law firm recommend that this procedure always be supported by transparent information on the processing of personal data under GDPR, with a clear definition of the purpose of processing.

Final Summary

The change introduced by Section 19 of the Act on the JMHZ from 1 July 2026 is simple in its wording but organisationally demanding. The existing eight-day deadlines for registering new employees after they start work are being abolished and replaced by the obligation to register every employee before the moment they first start working. The law offers relief in the form of a two-step procedure—partial registration for Czech employees—but even this requires prior organisational preparation and the establishment of a reliable process for collecting data from future employees.

For employers who relied on "somehow" managing the registration within eight days of the start date, this change brings a real risk of penalties. Fines for non-registration can reach up to CZK 100,000, and when combined with penalties for undeclared work, the company's total liability can quickly climb to significantly higher amounts.

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