In a landmark judgment delivered on 25 November 2025, the Court of Justice of the European Union (ECJ) ruled that all EU member states—regardless of their domestic marriage laws—must recognise same-sex marriages legally performed elsewhere in the bloc. The ruling stemmed from Cupriak-Trojan & Trojan v. Wojewoda Mazowiecki, a case brought by two Polish citizens who married in Germany in 2018 but were denied registration of their marriage on their return to Poland. The ECJ found that Poland’s refusal violated Article 21 of the Treaty on the Functioning of the EU, which guarantees free movement and the right to maintain a “normal family life” when exercising that freedom.
For global mobility managers the decision has immediate implications. Recognition of marriage certificates is a gateway to a host of residence-based benefits—from dependant visas and social-security coordination to joint tax filing and family health-care coverage. Multinational companies relocating employees to Poland will now be able to secure spousal residence cards for same-sex partners via the standard EU-family route rather than patchwork work-around solutions such as long-stay humanitarian visas. The ruling also removes uncertainty for business travellers whose marital status affects hotel registration, insurance and inheritance planning.
![ECJ forces Poland to recognise same-sex marriages from other EU states]()
The judgment does not compel Poland (or any other member state) to open domestic marriage law to same-sex couples, but it does oblige authorities to give identical cross-border recognition to marriage certificates, just as they already do for heterosexual unions. That means provincial civil-registry offices must now transcribe foreign same-sex marriage certificates and issue Polish civil-status documents, a prerequisite for many administrative procedures such as obtaining a PESEL number or registering property purchases.
Legal analysts expect a wave of follow-on litigation in areas ranging from parental rights to pension survivor benefits. Employers should anticipate updates to HR policy manuals, particularly those dealing with family allowances and medical insurance eligibility. Immigration advisers, meanwhile, are urging clients to prepare documentation early: the judgment is self-executing, but local offices may take weeks to update IT systems and application forms.
In practical terms, couples relocating after 25 November 2025 should travel with an original or certified copy of their foreign marriage certificate plus an apostille and sworn translation; Polish border officers must recognise the relationship for entry purposes, and Voivodeship authorities must issue residence cards within statutory deadlines. While some political resistance is expected, EU infringement procedures and potential financial penalties give the ruling real teeth—and make non-compliance costly for Poland’s government.
For global mobility managers the decision has immediate implications. Recognition of marriage certificates is a gateway to a host of residence-based benefits—from dependant visas and social-security coordination to joint tax filing and family health-care coverage. Multinational companies relocating employees to Poland will now be able to secure spousal residence cards for same-sex partners via the standard EU-family route rather than patchwork work-around solutions such as long-stay humanitarian visas. The ruling also removes uncertainty for business travellers whose marital status affects hotel registration, insurance and inheritance planning.
The judgment does not compel Poland (or any other member state) to open domestic marriage law to same-sex couples, but it does oblige authorities to give identical cross-border recognition to marriage certificates, just as they already do for heterosexual unions. That means provincial civil-registry offices must now transcribe foreign same-sex marriage certificates and issue Polish civil-status documents, a prerequisite for many administrative procedures such as obtaining a PESEL number or registering property purchases.
Legal analysts expect a wave of follow-on litigation in areas ranging from parental rights to pension survivor benefits. Employers should anticipate updates to HR policy manuals, particularly those dealing with family allowances and medical insurance eligibility. Immigration advisers, meanwhile, are urging clients to prepare documentation early: the judgment is self-executing, but local offices may take weeks to update IT systems and application forms.
In practical terms, couples relocating after 25 November 2025 should travel with an original or certified copy of their foreign marriage certificate plus an apostille and sworn translation; Polish border officers must recognise the relationship for entry purposes, and Voivodeship authorities must issue residence cards within statutory deadlines. While some political resistance is expected, EU infringement procedures and potential financial penalties give the ruling real teeth—and make non-compliance costly for Poland’s government.
