The inspection regime for 2026 combines immigration (aliens policing) controls with labour‑supervision mechanisms, creating a unified system through which authorities examine the legality, structure, and execution of employment relationships.
Authorities will focus not merely on formal documentation but on the underlying employment realities. Immigration bodies will scrutinise whether each foreign national’s presence and work activity rests on a valid legal basis. This involves reviewing whether residence permits, Type D visa–based work authorisations, and labour‑lending arrangements correspond to the actual tasks performed, the genuine workplace, and the accommodation declared in official procedures. They will analyse whether the declared job description aligns with day‑to‑day duties, whether workers appear at the worksites listed in their applications, and whether residence permits are used strictly for their intended purposes. These elements collectively form the substantive legal relationship between the worker and employer, and discrepancies may trigger administrative or criminal consequences.
Concurrently, labour‑supervision authorities will examine the lawfulness of domestic employment relationships. Their emphasis lies on detecting undeclared work, as well as identifying cases in which the declared legal relationship differs materially from the real‑world performance of work. The authorities will assess whether the legal grounds for employment—be it an employment contract, agency relationship, posting arrangement or other work structure—reflect actual working time, remuneration, and working conditions. Particular importance is placed on the authenticity and accuracy of working‑time records, the correctness of wage payments, and compliance with mandatory guarantees such as rest periods and annual paid leave. Labour authorities treat these as central components of the legal relationship, and inconsistencies may evidence attempts to conceal unlawful employment.
Additional scrutiny applies to temporary agency work and labour‑lending relationships. Authorities will verify whether the lending entity possesses the requisite certification, whether the recipient employer utilizes the workers in conformity with statutory rules, and whether the work performed matches the scope permitted by the worker’s authorisation. Posting arrangements and cross‑border assignments will be evaluated to determine whether they constitute genuine postings or de‑facto local employment since these structures have different consequences from an immigration, tax and social security perspective.
Both inspection branches analyse the worker’s right to work as an integral element of the legal relationship. This involves validating identification documents, checking the validity periods of authorisations, and confirming that the employer performed right‑to‑work verifications prior to onboarding. Authorities may request evidence of internal controls, including onboarding procedures, document‑retention practices, and internal compliance policies. Failures in these areas may give rise to findings of unlawful employment even where other documents appear formally compliant.
The integrated nature of the 2026 inspection regime means that authorities no longer consider immigration and labour supervision in isolation. Instead, they examine the coherence of all employment‑related legal structures: the alignment between immigration documents, employment contracts and the actual circumstances under which work is performed. Inconsistencies between these elements—such as a worker registered for part‑time hours while performing full‑time duties, or a workplace listed in immigration filings that does not correspond to the worker’s actual location—are treated as indicators of systemic non‑compliance.
Employers are therefore advised to conduct comprehensive internal reviews of all employment relationships, testing not only legal documentation but the real execution of work. An integrated compliance review should encompass immigration compliance, employment‑law conformity, and tax and social‑security obligations. This includes validating the legitimacy of work permits, verifying the accuracy of time‑and‑attendance systems, reviewing payroll consistency, and ensuring that accommodation and workplace declarations match reality. Such reviews provide early identification of risks that might otherwise emerge during an inspection and demonstrate good‑faith efforts toward compliance.
In summary, the 2026 integrated labour inspections will place significant emphasis on the authenticity, legality, and coherence of employment relationships. Employers should take proactive steps to ensure that each element of the employment structure—from legal basis to operational execution—can withstand scrutiny. A coordinated compliance approach is essential to mitigate regulatory risk and ensure lawful, transparent employment practices.
If you would like to assess your organization’s compliance risks or need support in preparing for integrated employment inspections, our team of experts is ready to assist you.
Please feel free to contact us.
László Szűcs
Director
Email: laszlo.szucs@pwc.com
Tamás Balog
Manager
Email: tamas.a.balog@pwc.com