When Poland’s landmark Act on the Conditions for the Admissibility of Entrusting Work to Foreigners took effect on 1 June 2025, lawmakers gave the government six months to publish the executive regulations that would translate the law into day-to-day practice. With the 2 December deadline now less than two weeks away, most of those regulations are still missing.
If the secondary acts are not issued and in force by 1 December, the existing rules—issued under the older Employment Promotion and Labour Market Institutions Act—will automatically expire, creating a legal vacuum. Employers would have no procedural guidance on which documents to file, which activities qualify for seasonal permits, or even what fees to pay.
![Regulatory Gap Looms as Executive Acts on Foreign Employment Near Expiry]()
Immigration lawyers warn that provincial labour offices could stop accepting or adjudicating applications until new guidelines arrive, jeopardising onboarding schedules and renewals for thousands of foreign specialists. The draft regulations seen by industry bodies introduce digital-only filings, new exemption categories for short-term assignments and an expanded list of seasonal industries, but their final text remains unpublished.
Businesses are therefore advised to accelerate any filings that can still be made under the current framework, prepare alternative assignment models (e.g., business-visitor status or service contracts) and monitor the Ministry of Family and Social Policy’s bulletin daily. Once the new decrees appear, companies should expect updated e-forms, higher fees and potentially new data-privacy consents linked to the MOS e-filing platform.
While officials insist the gap will be ‘hours, not days,’ HR teams managing large foreign workforces are bracing for processing freezes during the switchover. The episode underscores the importance of programme agility and the need for real-time legislative monitoring in Poland’s fast-evolving mobility landscape.
If the secondary acts are not issued and in force by 1 December, the existing rules—issued under the older Employment Promotion and Labour Market Institutions Act—will automatically expire, creating a legal vacuum. Employers would have no procedural guidance on which documents to file, which activities qualify for seasonal permits, or even what fees to pay.
Immigration lawyers warn that provincial labour offices could stop accepting or adjudicating applications until new guidelines arrive, jeopardising onboarding schedules and renewals for thousands of foreign specialists. The draft regulations seen by industry bodies introduce digital-only filings, new exemption categories for short-term assignments and an expanded list of seasonal industries, but their final text remains unpublished.
Businesses are therefore advised to accelerate any filings that can still be made under the current framework, prepare alternative assignment models (e.g., business-visitor status or service contracts) and monitor the Ministry of Family and Social Policy’s bulletin daily. Once the new decrees appear, companies should expect updated e-forms, higher fees and potentially new data-privacy consents linked to the MOS e-filing platform.
While officials insist the gap will be ‘hours, not days,’ HR teams managing large foreign workforces are bracing for processing freezes during the switchover. The episode underscores the importance of programme agility and the need for real-time legislative monitoring in Poland’s fast-evolving mobility landscape.
