The new Psychologist Act, without the panic: what Art. 28 asks of your notes

The Act on the profession of psychologist was published on 18 February 2026 (Dz.U. 2026 poz. 187). Most of it enters into force two years and three months after publication — on 19 May 2028. Only the organising provisions, such as the committee that prepares the chamber and the census, apply already.

So if someone tells you that your notes are "non-compliant" today, they are selling fear. The useful way to read Art. 28 is as a description of good documentation that you can start keeping now, so 2028 is a non-event.

What the record must contain

Art. 28 is unusually specific. Psychological documentation must include at least:

• the client's identity — name, date of birth, address and PESEL (or an identity-document number);
• legal representatives, when the client is a minor;
• your name and your number in the Register of Psychologists;
• the name and address of the practice;
• a description of the services provided;
• the date the entry was prepared, and a signature.

Formal record vs. working notes

Clients have the right to see their documentation — except test sheets and your short-term working notes ("notatki robocze psychologa o znaczeniu krótkotrwałym"). That carve-out matters: it means your hypotheses and reminders to yourself can live separately from the formal entry the client may one day read.

In Sessio every session has two fields: the formal record (Art. 28, visible to the client on request) and private working notes. The AI draft never mixes them.

How long to keep it — and how to let it go

Records are kept for five years, counted from the end of the year in which services ended. After that, destruction requires a written protocol. Paper or electronic storage are both allowed, and you may entrust storage to a processor under a data-processing agreement.

A calm checklist for this year

• Separate formal entries from working notes, starting with your next client.
• Write the date and a short description of the service in every entry.
• Collect identity details once, at the first session, and store them securely.
• Keep electronic records with an EU processor that signs a data-processing agreement.
• Leave a field for your Register number — you will apply between 2028 and 2030.

None of this needs new software. But if you would rather your booking, payments and notes lived in one place, that is what we are building.