Polish authorities have issued a series of compliance deadlines falling between June 30 and August 3, 2026 that directly affect employers with foreign national employees in Poland. HR and mobility teams should act now to audit affected populations and, where required, prompt employees to take action before each deadline passes.
1. Student Work Permit Exemption: Audit Required Before June 30, 2026
The rule: Under Polish law, foreign nationals undertaking full-time (stacjonarne) first-cycle, second-cycle, long-cycle, or doctoral studies at a qualifying institution in Poland (i.e., holding ministerial approval) may work without a work permit. Part-time, postgraduate, and MBA programs do not qualify, and individuals on those programs require a work permit to work legally.
The transitional period: Introduced alongside Poland’s June 2025 employment reforms, a transitional arrangement has been allowing students at certain institutions that do not yet hold ministerial approval to continue working without a work permit. That transitional window closes on June 30, 2026.
Note that itdoes not affect students whose immigration status already reflects a full-time student purpose of residence at an approved institution.
Action required: Employers should audit foreign national employees currently working without a work permit on the basis of student status. Where it is not clear whether an employee falls within the qualifying criteria, legal advice should be sought before the deadline.
Consequence of inaction. Fines exposure, and in repeat cases, loss of eligibility to employ foreign nationals in Poland.
2. Ukrainian Nationals: Data Update to Maintain UKR Status — Deadline August 31, 2026
The rule: Ukrainian nationals who registered their stay in Poland and obtained PESEL UKR status without presenting a valid biometric passport at the time of registration are required to confirm their identity in person at their local municipal authority. This is a requirement under Polish law following the end of the Ukrainian Special Act in March 2026. The update must be made in person. It cannot be done online or by post.
Action required: Employers should notify Ukrainian employees holding UKR status of this obligation and encourage early action, given the volume of affected individuals and likely administrative queues at municipal offices.
Consequence of inaction: Failure to update by August 31, 2026 will result in automatic status change from UKR to NUE as of September 1, 2026, with immediate loss of the right to reside and work in Poland. Affected individuals will also be unable to apply for the newly introduced CUKR card (Czasowe Uprawnienie Karty Rezydenta), a three-year residence card providing a longer-term pathway for Ukrainians remaining in Poland following the end of the Special Act framework. Timely action preserves both current status and future options.
3. EU Residence Documents: Mass Expiry Affecting EU Citizens and Their Non-EU Family Members – August 3, 2026
The rule: As part of the EU-wide harmonisation of residence document security standards, all residence documents issued in Poland to EU citizens and their non-EU family members before August 1, 2021 will expire on August 3, 2026, regardless of any longer or indefinite validity period stated on the document. This includes permanent residence documents that bear no expiry date.
Action required: Employers should identify any employee holding Polish residence documents issued before August 1, 2021, whether they are an EU national or a non-EU national family member of an EU citizen (from which their right to work derives), and advise them to submit a renewal application without delay. Polish voivodeship offices are already reporting processing backlogs, and early filing is strongly recommended.
Consequence of inaction: Missing the deadline requires a full new application with fresh supporting documentation. For non-EU family members of EU citizens, the consequences are more severe: failure to renew on time may result in being barred from re-entering Poland and the Schengen Area until a new document is issued. Employers with internationally mobile employees in this category should treat this as a priority.
For assistance with compliance audits or individual cases, please contact your Newland Chase advisor.
This document is intended for informational purposes only and should not be considered legal advice. For case-specific guidance or further information, please contact Newland Chase directly.
