
On 19 January 2026 the specialist immigration portal LegalizacjaPolska reminded employers and foreign residents that all statutory time limits for Polish residence-permit and international-protection cases remain suspended until 4 March 2026. The measure, embedded in Article 100da of the so-called Ukrainian Special Act, was last amended in September 2025 and has not been lifted. In practice, it means that voivodeship offices and the Office for Foreigners can process applications at their own pace without risking ‘silence of the authorities’ complaints, while applicants must still respect every deadline that applies to them.
The freeze covers decisions on temporary and permanent residence permits, EU long-term-resident status and amendments thereto, as well as refugee or subsidiary-protection determinations. It does not pause deadlines imposed on the applicant (for example, to supply missing documents) and it does not cover removal, entry-ban or fine proceedings.
While the statutory clocks stay stopped, companies still need visas for incoming staff and short-term assignments. VisaHQ, through its Polish portal (https://www.visahq.com/poland/), can fast-track business-visa applications, track changing documentation rules and coordinate courier deliveries, helping mobility managers keep projects moving despite the longer-term permit standstill.
Corporate mobility teams should therefore adjust expectations: even well-prepared filings may sit in queue for months with no legal recourse for delay. The suspension also complicates merger and posting timelines because the usual tactic of filing a complaint for administrative inaction is unavailable until after 4 March 2026—or any later date should Parliament vote another extension.
Legal analysts warn that the arrangement disproportionately protects the authorities, undermining the right to an effective remedy and chilling investment decisions that hinge on predictable processing times. The Ombudsman and several provincial courts have criticised the blanket approach, but for now it stands. Companies are advised to keep meticulous records, over-communicate expected lead-times to business units, and explore alternative EU postings where feasible.
Whether the freeze will end or be rolled forward again is politically uncertain: any change would require a full legislative amendment. Stakeholders should monitor parliamentary calendars closely in February, when debates on the war-related special measures are expected.
The freeze covers decisions on temporary and permanent residence permits, EU long-term-resident status and amendments thereto, as well as refugee or subsidiary-protection determinations. It does not pause deadlines imposed on the applicant (for example, to supply missing documents) and it does not cover removal, entry-ban or fine proceedings.
While the statutory clocks stay stopped, companies still need visas for incoming staff and short-term assignments. VisaHQ, through its Polish portal (https://www.visahq.com/poland/), can fast-track business-visa applications, track changing documentation rules and coordinate courier deliveries, helping mobility managers keep projects moving despite the longer-term permit standstill.
Corporate mobility teams should therefore adjust expectations: even well-prepared filings may sit in queue for months with no legal recourse for delay. The suspension also complicates merger and posting timelines because the usual tactic of filing a complaint for administrative inaction is unavailable until after 4 March 2026—or any later date should Parliament vote another extension.
Legal analysts warn that the arrangement disproportionately protects the authorities, undermining the right to an effective remedy and chilling investment decisions that hinge on predictable processing times. The Ombudsman and several provincial courts have criticised the blanket approach, but for now it stands. Companies are advised to keep meticulous records, over-communicate expected lead-times to business units, and explore alternative EU postings where feasible.
Whether the freeze will end or be rolled forward again is politically uncertain: any change would require a full legislative amendment. Stakeholders should monitor parliamentary calendars closely in February, when debates on the war-related special measures are expected.










