Where the act comes from and what exactly it changes
The Sejm and the Senate passed it, the President of Poland signed it on 30 April 2026, and on 6 May 2026 the amendment was published in the Journal of Laws as Journal of Laws 2026, item 605. It enters into force on 21 May 2026 — i.e. 14 days after publication (Art. 25).
Its full title is “Act of 13 March 2026 amending the act on collective water supply and collective wastewater disposal and certain other acts”. The direct reason: the implementation of Directive 2020/2184 on the quality of water intended for human consumption.
For water testing laboratories, however, the most important part is not the changes to the water supply and sewerage act itself, but what the amendment brings into the act on the State Sanitary Inspection. It is there, in the new Chapter 3a (Art. 37aa–37an), that an entire quality system for water testing appears — including the register, report requirements and financial sanctions.
What disappeared from the old act
The mechanism of “approval of the quality system by the PIS” (the repealed Art. 12a–12c of the old act) is no longer sufficient as a basis for testing drinking water. It is replaced by mandatory PCA accreditation and entry in the GIS register.
The rest of the article covers three structural changes, a calendar of dates and a checklist for the first three months. For every specific requirement we give the article number — so that you can easily verify it in the text of the act.
Three changes that directly affect your laboratory
Change 1. PCA accreditation becomes mandatory
Under Art. 37aa para. 1, the quality of drinking water and of bathing water may be tested only by laboratories that meet all four conditions:
- they hold accreditation from the Polish Centre for Accreditation (or a body from another EU Member State) for compliance with PN-EN ISO/IEC 17025 — covering, respectively, drinking water (reference methods from the regulation, alternative methods approved by the Commission or validated with performance characteristics) or bathing water;
- they ensure that samples are taken by accredited samplers using methods representative of the parameters;
- they draw up partial and complete test reports in accordance with Art. 37ag;
- they are entered in the register of laboratories kept by the Chief Sanitary Inspector.
It sounds simple, but it has one serious consequence for many water and sewerage laboratories: if you currently operate on the basis of PIS approval without full PCA accreditation, you have a limited four-year transitional window (more on that shortly). After that — accreditation or the end of your work in drinking water testing.
Change 2. Entry in the GIS register — a new formal obligation
The register of laboratories (Art. 37aa paras. 2–8) replaces the former “approval” mechanism. It is a declaratory register (not an administrative one — the Code of Administrative Procedure does not apply to it, Art. 37aa para. 7), but without an entry you cannot carry out tests.
What goes into the register (Art. 37aa para. 2):
- details of the operating entity (name, address, KRS or CEIDG registration, tax ID);
- persons authorised to represent the entity;
- the laboratory’s address and contact details;
- the scope of water tests performed;
- the current accreditation certificate together with its scope;
- participation in proficiency testing (or interlaboratory comparisons) over the last 2 years — with the assessment obtained;
- persons authorised to submit test reports;
- the register entry number.
Registration procedure (Art. 37aa paras. 3–6)
The application is submitted by the entity operating the laboratory — on paper with a handwritten signature, or electronically with a qualified, trusted or personal signature. A certified copy (or digital copy) of the accreditation certificate together with its scope is attached. The GIS has 30 days to accept the application, return it for completion (with a further 30-day deadline) or reject it.
An important consequence: the laboratories’ data from the register are published in the GIS Public Information Bulletin (BIP) (Art. 37ab) — together with the accreditation certificate, proficiency testing results, the entry number and the date the application was accepted. This means your proficiency testing results become publicly available. Clients, auditors, competitors — anyone can check how you perform in interlaboratory comparisons.
Change 3. Partial and complete test reports — new rigour
This is the part that press commentary most often skips, and yet it is the one that changes the laboratory’s day-to-day work the most.
The act distinguishes two types of water test reports (Art. 37ag):
- Complete test report — covers all determinations within one order and is drawn up once the ordered tests are completed (para. 1).
- Partial test report — drawn up at the moment the test of a specific parameter is completed and a result indicating non-compliance with the parametric value is obtained (paras. 2–3). It applies to microbiological parameters (E. coli, intestinal enterococci, coliform bacteria), chemical and radiological parametric values, and parameters from the risk assessment.
Minimum content of the report (Art. 37af):
- the laboratory’s GIS register entry number;
- the name of the person who took the sample (an accredited sampler) together with the sampling method;
- the name of the person who authorised the report;
- the sampling point;
- the method’s limit of quantification — for chemical and indicator parameters;
- the method’s limit of detection — for microbiological parameters.
The deadlines for submitting reports to the competent sanitary inspector (Art. 37ag para. 4) are tight — and they are what the fine directly sanctions:
| Situation | Deadline for the sanitary inspectorate |
|---|---|
| Non-compliance with the parametric values for E. coli or intestinal enterococci | on the day it is drawn up |
| Number of coliform bacteria ≥ 10 CFU (MPN)/100 ml | on the day it is drawn up |
| Non-compliance with the parametric value for Legionella in domestic hot water | on the day it is drawn up |
| Other non-compliance with parametric values | 7 days after drawing up |
The report is submitted as an electronic document (in accordance with the act on providing services by electronic means) or by fax (Art. 37ag para. 6). In urgent cases, first by phone, then with electronic confirmation.
Fines — for the first time ever
The new Art. 37azb introduces something that Polish sanitary and epidemiological law has never had for laboratories — a direct financial sanction imposed on the entity operating the laboratory for reporting failures.
The fine is imposed by decision of the competent State district, border or provincial sanitary inspector. The sanction applies specifically to failure to fulfil the obligations under Art. 37ag paras. 3 and 4 (drawing up a partial report, meeting the submission deadline) — or to fulfilling them late.
What this means in practice
Every missed “same day” for a microbiological non-compliance is a potential administrative decision. The upper limit of PLN 10,000 is not dramatically high as a one-off sanction, but imposed repeatedly — e.g. on a water utility laboratory with hundreds of samples a month — it becomes a real operational risk. More importantly, the decisions are public and weigh on the reputation of a laboratory entered in the register.
Adaptation timeline — what and when
The amendment divides laboratories into three groups, with different transitional periods.
Samplers and laboratories without PCA accreditation are subject to the provisions on reports (Art. 37af, 37ag) and fines (Art. 37azb) from the day of entry into force — the transitional periods do not suspend the new reporting obligations; they only maintain the right to carry out tests.
Checklist — what to do in the next 3 months
If you run a water testing laboratory — whether at a water utility, a municipal waterworks laboratory, a microbiology laboratory or an external commercial one — the order of actions until 21 August 2026 is fairly clear.
- Verify your scope of accreditation. Check whether your current PCA certificate covers all the water test parameters that you perform or plan to declare in the register. If the scope is narrower than your actual work — start an extension with the PCA as early as possible.
- Gather the documentation of your proficiency testing from the last 2 years — with the assessments obtained. It is a mandatory attachment to the application (Art. 37aa para. 2 point 6). Note that these data will be public in the BIP.
- Name the persons authorised to submit reports — individually. Check who in your laboratory can sign with a qualified or trusted electronic signature, because communication with the sanitary inspectorate is to be electronic.
- Verify your samplers’ qualifications. You have 2 years for full accreditation of sampling staff, but the report procedures require the sampler to be named from 21 May 2026.
- Implement a procedure for partial test reports. This is the biggest operational change. You need a clear description of who recognises non-compliance and how, who authorises the partial report, how it reaches the sanitary inspectorate in the same work shift, and how you archive proof of sending.
- Check whether your reporting system meets the minimum of Art. 37af. The register entry number, the limits of quantification and detection, the details of the sampler and of the authorising person — all of this must appear in the report automatically. Filling in these fields by hand for every result is a guarantee of errors and a risk of fines.
- Prepare for the electronic format. The act requires communication “by means of electronic communication” — the detailed format will probably be set by a regulation of the Minister of Health. But it is already worth checking whether your LIMS exports reports as PDF that can be signed with a qualified signature, or as XML compatible with the Polish ePUAP/EZD platforms.
A system element worth planning
If you enter results by hand into a spreadsheet or an old LIMS, an “off by one day” mistake on an E. coli non-compliance can mean a fine. A modern LIMS — such as CleverLAB — triggers the partial test report automatically the moment an entered result exceeds the parametric value (in line with Art. 37ag para. 3), sends an e-mail notification to the authorising person and prepares an electronic document ready to be signed. This eliminates a class of error that organisational discipline cannot remove.
What we do not know yet — and when we will find out
The act itself is only a framework. The specific reference methods, sampling frequencies, compliance monitoring requirements and the electronic format of reports will be set by a new regulation of the Minister of Health. Work is currently under way on the draft numbered MZ 1841 — the consultation ended on 8 April 2026.
The existing regulation of 7 December 2017 (Journal of Laws 2017, item 2294) remains in force for a maximum of 18 months from the entry into force of the act (Art. 23) — i.e. until November 2027 at the latest. A new implementing act will appear before then. It is worth following the legislative path at legislacja.gov.pl/projekt/12404055.
The second area that the act opens but does not close is priority premises — non-residential buildings with more than 50 users a day (hospitals, hotels, prisons, care homes). Their owners and managers face a separate path of obligations: risk assessments, Legionella and lead testing, and qualifications for the person carrying out the assessment (Art. 4l of the new water supply and sewerage act). That is a topic for a separate article — but for many laboratories it means a new category of clients.
Summary
The water act of 13 March 2026 does not create a new reality overnight. It gives laboratories without PCA accreditation four years to adapt fully, and samplers two years. But three elements apply without a transitional period from 21 May 2026: partial test reports, the “on the day it is drawn up” deadlines for microbiological non-compliance, and fines for missing them.
The next three months mean working on two tracks in parallel: registering in the GIS register (a formality, but with a hard deadline) and implementing the partial test report procedure (a change in day-to-day operations, most often requiring the LIMS to be adapted).
The CleverLAB team is working on a Water Compliance Pack tailored to the new requirements of the act — with a ready-made partial report template, automatic non-compliance notifications and support for the register of samplers. If you would like to talk about electronic reporting compliant with Art. 37ag, write to us.
Preparing the laboratory for the water act 2026
We will go through the partial test report procedure, the electronic format, integration with ePUAP and the GIS register requirements with you — based on your current workflow.
Related articles
LIMS compliance with ISO/IEC 17025
A comprehensive guide to the standard’s requirements — the foundation of PCA accreditation for water testing.
System security for accreditation
How a service agreement with the LIMS provider covers 70% of the ISO/IEC 17025 security requirements.
Electronic signatures in the laboratory
Qualified, trusted, personal — how the authorisation of electronic test reports works.
Legal basis and sources
- Act of 13 March 2026 amending the act on collective water supply and collective wastewater disposal and certain other acts — Journal of Laws 2026, item 605 (published on 6 May 2026, signed by the President of Poland on 30 April 2026).
- Draft regulation of the Minister of Health on the quality of water intended for human consumption — MZ 1841 (legislacja.gov.pl), consultation ended on 8 April 2026.
- Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the quality of water intended for human consumption — EUR-Lex.
- Regulation of the Minister of Health of 7 December 2017 (in force so far, for a maximum of 18 months from the entry into force of the act) — Journal of Laws 2017, item 2294.
- Polish Centre for Accreditation — information on the accreditation of testing laboratories to PN-EN ISO/IEC 17025: pca.gov.pl.
- Statement of the Chamber of Commerce “Polish Waterworks” of 7 May 2026 — igwp.org.pl.
About this article
The article is based on the text published in the Journal of Laws 2026, item 605, and on draft regulation MZ 1841. The specific technical requirements (reference methods, monitoring frequencies, the format of electronic reports) will be specified in the implementing regulation — we will update the article after its publication.
The CleverLAB team develops LIMS software for laboratories accredited to ISO/IEC 17025. Our clients include water, wastewater and microbiology laboratories, physico-chemical laboratories and technical cleanliness laboratories.