The EU Temporary Protection mechanism was activated in March 2022 in response to the large-scale displacement of Ukrainian citizens caused by the armed conflict with Russia. It provides beneficiaries with immediate protection, including the right to reside, access the labor market, and benefit from social security systems, without the need to go through individual asylum procedures.
Since its activation, the mechanism has been extended several times. Most recently, the Council of the European Union (the Council) adopted a Council Implementing Decision in July 2025, extending the Temporary Protection until March 4, 2027. At the same time, in September 2025, the Council adopted a recommendation on a coordinated transition out of Temporary Protection, encouraging Member States to begin preparing for an orderly phase-out of the framework, and to put in place pathways either to alternative legal statuses or to voluntary return, once conditions allow.
Temporary Protection was conceived as an exceptional and time-limited emergency instrument. Four years later, EU institutions and member states have acknowledged that continued extensions alone are no longer sufficient. As a result, the policy focus has shifted from prolongation to transition. Importantly, the Council recommendation does not impose a uniform exit model. Instead, it leaves implementation to member states, which is leading to diverging national approaches.
Currently, three broad approaches can be observed
Countries actively planning structured transition mechanisms
Some countries are developing specific legal pathways allowing beneficiaries of Temporary Protection to move into longer-term or standard residence statuses. These pathways may include facilitated access to temporary residence permits linked to employment, business activity, or family ties.
In some cases, special “continuity” permits are being designed to prevent gaps in lawful stay for individuals who do not meet standard immigration criteria. For example, Czechia and Poland have already announced or introduced specific legal pathways allowing beneficiaries of Temporary Protection to transition to longer-term residence statuses, subject to defined eligibility conditions.
Countries allowing transition under existing immigration law
Other countries have not yet created new post-Temporary Protection statuses, but already allow beneficiaries to apply for standard residence permits (e.g., work-based or family-based permits) under ordinary immigration rules. Temporary Protection remains in place until 2027, but beneficiaries are encouraged to transition early if they qualify. No dedicated “exit permit” exists; the transition relies on existing legal categories. This approach is common in several large EU member states (e.g., Germany).
Countries focusing primarily on extension of Temporary Protection
A third group of countries has, so far, limited its response to extending Temporary Protection until March 2027, without publicly detailing national transition frameworks.
Planning is ongoing, often at an administrative or policy level. Employers and beneficiaries may face uncertainty until further guidance is issued.
In summary, Temporary Protection will remain in place until March 2027, but the legal and operational environment is already changing. Access to the labour market will eventually shift from status-based rights (Temporary Protection) to permit-based rights, depending on the residence title held after transition. Access to healthcare, social security, and family-related benefits is likely to become increasingly tied to formal employment and social-security contributions, aligning beneficiaries with standard non-EU frameworks.
Employers should not treat the extension as a signal that no action is required. Instead, 2026–2027 should be seen as a transition period, during which:
- Employee populations should be mapped by legal status and country
- Future residence and work authorization options should be anticipated
- Internal HR, payroll, and compliance processes should be reviewed
Many member states have not yet publicly disclosed the full details of their post-Temporary Protection transition frameworks. Newland Chase will continue to monitor developments closely as new guidance and procedures emerge.
This immigration update is for informational purposes only and is not a substitute for legal or scenario-specific advice. Furthermore, it is important to note that immigration announcements are subject to sudden and unexpected changes. Readers are encouraged to reach out to Newland Chase for any case- or company-specific assessments.
