Polish authorities have issued three compliance deadlines in summer 2026 affecting employers with foreign national employees in Poland. Employers are advised to audit affected workers and ensure required actions are taken before the relevant deadlines.
Student work permit exemption deadline: 30 June 2026
Foreign nationals undertaking full-time studies in Poland may work without a work permit if they are enrolled in qualifying institutions with ministerial approval. The exemption applies to:
- Full-time first-cycle studies
- Full-time second-cycle studies
- Full-time long-cycle studies
- Full-time doctoral studies
Part-time, postgraduate, and MBA programs do not qualify. Students in those programs require a work permit to work legally.
A transitional arrangement introduced with Poland’s June 2025 employment reforms has allowed some students at institutions without ministerial approval to continue working without a work permit. That transitional period ends on 30 June 2026.
The change does not affect students whose immigration status already reflects full-time student residence at an approved institution.
Employers should audit foreign national employees who are currently working without a permit based on student status. Where eligibility is unclear, legal advice should be sought before the deadline.
Failure to act may expose employers to fines. In repeat cases, employers may lose eligibility to employ foreign nationals in Poland.
Ukrainian nationals with UKR status: identity update by 31 August 2026
Ukrainian nationals who registered their stay in Poland and obtained PESEL UKR status without presenting a valid biometric passport must confirm their identity in person at their local municipal authority.
This requirement follows the end of the Ukrainian Special Act in March 2026. The update must be completed in person and cannot be done online or by post.
Employers should notify Ukrainian employees holding UKR status and encourage early action, as municipal offices may face high demand and administrative queues.
If the update is not completed by 31 August 2026, the person’s status will automatically change from UKR to NUE on 1 September 2026. This would result in immediate loss of the right to reside and work in Poland.
Affected individuals would also lose the ability to apply for the newly introduced CUKR card, or Czasowe Uprawnienie Karty Rezydenta. The CUKR card is a three-year residence card intended to provide a longer-term pathway for Ukrainians remaining in Poland after the end of the Special Act framework.
EU residence document expiry: 3 August 2026
As part of EU-wide harmonisation of residence document security standards, all residence documents issued in Poland to EU citizens and their non-EU family members before 1 August 2021 will expire on 3 August 2026.
This applies regardless of any longer or indefinite validity period printed on the document, including permanent residence documents with no expiry date.
Employers should identify employees holding Polish residence documents issued before 1 August 2021. This includes:
- EU nationals
- Non-EU family members of EU citizens whose right to work derives from that status
Affected employees should submit renewal applications without delay. Polish voivodeship offices are already reporting processing backlogs, so early filing is strongly recommended.
Missing the deadline may require a full new application with fresh supporting documents.
For non-EU family members of EU citizens, the consequences may be more serious. Failure to renew on time may prevent re-entry to Poland and the Schengen Area until a new document is issued. Employers with internationally mobile employees in this category should treat the deadline as a priority.
Employer action points
Employers with foreign national staff in Poland should review their workforce before the deadlines and identify:
- Foreign students working without permits based on student status
- Ukrainian employees with PESEL UKR status who registered without a valid biometric passport
- EU citizens and non-EU family members holding Polish residence documents issued before 1 August 2021
The main risks are loss of work authorization, loss of residence rights, fines, re-entry issues, and possible employer restrictions in future foreign national hiring.
Source article: newlandchase.com
