On January 28, 2026, the Polish parliament passed a law aimed at phasing out the special legal regime for beneficiaries of temporary protection from March 2026. The Polish president has to either sign the law or request amendments by February 19, 2026. The Temporary Protection mechanism remains valid until March 4, 2027, and beneficiaries retain the right to legally reside, work and study in Poland under that framework. Ukrainian nationals may continue to work in Poland without a work permit, on the simple basis of a Notification of Employment of a Ukrainian national.
The exceptional mechanism of Temporary Protection was introduced in the EU on March 4, 2022, and has since been granted to individuals who were forced to leave Ukraine due to the armed conflict with Russia. The most recent extension of the EU’s temporary protection was adopted by the Council of the European Union on July 15, 2025 (Decision (EU) 2025/1460), with a prolongation of the framework from March 4, 2026, to March 4, 2027. This extension applies to millions of Ukrainians benefiting from temporary protection across the EU.
Additionally, in September 2025, the Council of the European Union endorsed a recommendation on gradual transition planning from temporary protection to other permanent or longer-term residence statuses, and eventually, a phasing-out of the exceptional framework.
In Poland, two Temporary Protection mechanisms have been implemented in parallel since 2022:
- General Temporary Protection under EU law, which is granted to individuals who do not qualify under the Special Temporary Protection based on the Polish Special Act.
- Special Temporary Protection under Polish law (PESEL UKR status), which is granted to Ukrainians and their qualifying family members on the basis of the Polish Special Act on assistance to Ukrainians.
Transition to general immigration rules
Transition to Standard Permit
Beneficiaries of the Temporary Protection (PESEL UKR ) who are employed, run a business activity or qualify as dependants, should transition to a standard temporary residence permit under the relevant immigration category (typically valid up to 3 years).
Transition to CUKR
Alternatively, Beneficiaries of the Temporary Protection (PESEL UKR ) may transition to a special temporary residence permit (CUKR), granted for residence continuity through a simplified online procedure. The system for this procedure has yet to be set up. Current estimates indicate the system going online around mid-2026.
Ordinary Immigration
Ukrainian nationals who are not beneficiaries of Temporary Protection remain subject to standard legal statuses available to non-EU nationals (e.g. sponsored residence, or long-term EU residency for those with 5+ years).
Transition effects
Compliance changes
- Transition to Standard Permit: Once individuals transition to a standard residence permit, their right to work will be governed by the labour-market access rules applicable to that specific permit.
- Transition to CUKR: Once issued, the CUKR temporary residence permit is intended to confer the right to work in Poland without a separate work permit or employer notification, for the duration of its validity (up to three years), subject to the final implementation of the relevant executive regulations. After the expiry of the CUKR permit, labor-market access will be governed by the rules applicable to the residence status subsequently obtained.
Reductions or changes in social support and services
- Free, universal healthcare for beneficiaries of the Temporary Protection will be limited; only emergency care and healthcare connected to employment-linked insurance will remain free.
- Social welfare benefits (like child benefits such as “800+”) will be tied to formal employment and social-security contributions, rather than given automatically.
- Assistance with accommodation and food will focus on vulnerable groups (e.g., disabled, elderly, pregnant women).
Employers in Poland should prepare for an evolving legal framework, including:
- Reviewing employment compliance.
- Assessing sponsorship requirements for foreign workers transitioning to other residence statuses.
- Planning changes in benefit access tied to formal employment and contributions.
Beneficiaries of temporary protection in Poland are advised to stay informed about the effective legislative implementation of the law.
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.
