
The Polish government has taken the first formal step toward ending the extraordinary legal regime that has applied to Ukrainian citizens since the full-scale invasion of Ukraine in 2022. On 23 January 2026 the Ministry of the Interior published a draft bill that would repeal large sections of the Special Act on Assistance to Ukrainian Citizens. That Act currently grants Ukrainians rights that almost match those of Polish nationals—including visa-free entry, immediate work authorization, cash benefits and unrestricted access to public healthcare.
Under the proposal, most preferential measures would be replaced by a mainstream “integration pathway” aligned with Poland’s general Aliens Act. Ukrainians would still be able to work without a labour-market test after notifying the labour office, but family benefits (such as the popular "800+" child allowance) would become conditional on the parents’ being in employment or actively seeking work. Free housing in collective centres would be limited to vulnerable groups, and adult refugees outside those groups would be required to contribute to accommodation costs after an initial transition period.
If the draft passes Parliament unchanged, the phase-out will begin on 5 March 2026—the date that temporary protection under the EU Council Decision is currently due to lapse. Officials emphasise that no one will be forced to leave the country; instead, Ukrainians will be encouraged to shift to standard residence permits (for work, study or family) or to apply for EU long-term-resident status if they meet the criteria. The bill also creates a one-time, two-year residence permit for those who cannot immediately meet the ordinary requirements, giving employers a bridge period to regularise key staff.
Navigating the shift from the Special Act to the mainstream Aliens Act will demand timely paperwork and strategic selection of permit categories. VisaHQ’s Poland team (https://www.visahq.com/poland/) can coordinate the entire filing process—booking appointments, compiling documentation and tracking approvals—so that Ukrainian employees and their dependants maintain uninterrupted status. The platform also offers bulk-management tools for HR departments, allowing mobility managers to monitor progress across large assignee populations in real time.
For global mobility managers the implications are significant. HR teams must audit their Ukrainian assignee population to confirm that each employee—and any dependent family members—will hold an appropriate residence title after March 2026. Payroll departments should prepare for the possibility that some assignees will lose social-security family benefits, affecting net-pay calculations. Companies providing housing may find their obligations increase if state-run centres scale back. Finally, talent strategies may have to adjust if some Ukrainians opt to relocate to other EU countries offering more favourable support.
While the bill still requires approval by both chambers of Parliament and the President, Interior Ministry sources predict fast-tracking in February. Multinational employers should therefore begin contingency planning now, rather than waiting for the final text to become law.
Under the proposal, most preferential measures would be replaced by a mainstream “integration pathway” aligned with Poland’s general Aliens Act. Ukrainians would still be able to work without a labour-market test after notifying the labour office, but family benefits (such as the popular "800+" child allowance) would become conditional on the parents’ being in employment or actively seeking work. Free housing in collective centres would be limited to vulnerable groups, and adult refugees outside those groups would be required to contribute to accommodation costs after an initial transition period.
If the draft passes Parliament unchanged, the phase-out will begin on 5 March 2026—the date that temporary protection under the EU Council Decision is currently due to lapse. Officials emphasise that no one will be forced to leave the country; instead, Ukrainians will be encouraged to shift to standard residence permits (for work, study or family) or to apply for EU long-term-resident status if they meet the criteria. The bill also creates a one-time, two-year residence permit for those who cannot immediately meet the ordinary requirements, giving employers a bridge period to regularise key staff.
Navigating the shift from the Special Act to the mainstream Aliens Act will demand timely paperwork and strategic selection of permit categories. VisaHQ’s Poland team (https://www.visahq.com/poland/) can coordinate the entire filing process—booking appointments, compiling documentation and tracking approvals—so that Ukrainian employees and their dependants maintain uninterrupted status. The platform also offers bulk-management tools for HR departments, allowing mobility managers to monitor progress across large assignee populations in real time.
For global mobility managers the implications are significant. HR teams must audit their Ukrainian assignee population to confirm that each employee—and any dependent family members—will hold an appropriate residence title after March 2026. Payroll departments should prepare for the possibility that some assignees will lose social-security family benefits, affecting net-pay calculations. Companies providing housing may find their obligations increase if state-run centres scale back. Finally, talent strategies may have to adjust if some Ukrainians opt to relocate to other EU countries offering more favourable support.
While the bill still requires approval by both chambers of Parliament and the President, Interior Ministry sources predict fast-tracking in February. Multinational employers should therefore begin contingency planning now, rather than waiting for the final text to become law.







