Undeclared work: New obligations for employers apply from October

Payroll agenda

By: Anna Beránková

A significant change in the area of foreigner employment came into effect on 1 October 2025. The amendment to the Employment Act introduces a new legal concept – “undeclared work” – and substantially tightens the reporting obligation of employers to the Labour Office. If the employer fails to comply with the newly established conditions, it runs the risk of a fine of up to CZK 3,000,000.

What has changed

Under the original legislation, it was sufficient for the employer to inform the Labor Office of the foreigner’s commencement of employment no later than on the day of commencement. However, from October onwards, notification must be given before the actual commencement of work. Therefore, once a foreigner starts working without prior notification, it is automatically undeclared work.

Who is affected by the new obligation

The obligation to notify the start of work applies to all employers who employ:

  • EU nationals and their family members,
  • foreigners with free access to the labour market or or family members of Czech citizens,
  • holders of an employee card, blue card, employment permit or intra-corporate transfer card.

Employers must also continue to report any changes in the employment of foreigners – e.g. termination of employment or change of legal status – within 10 days of the date, on which the change occurred.

Penalties for violations

Enabling undeclared work will be considered an offence. Whereas previously the maximum fine for failure to comply with the notification obligation was CZK 100,000, the Labour Office can now impose a penalty of up to CZK 3,000,000. This represents a major tightening and a clear signal that the state wants to increase supervision over the legal employment of foreigners.

How to prepare

In order to avoid the risk of sanctions, employers should review and adjust their internal processes regarding the recruitment of new employees from abroad and ensure that notifications of recruitment are sent well in advance.

The new regulation is already in effect, as of 1 October 2025. In practice, this means that any late notification of a foreigner’s work commencement will be treated as undeclared work – regardless of whether the error was due to an administrative delay or a misunderstanding. Employers are therefore advised to pay close attention to this change.