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Feb 24, 2026

UNHCR Legal Update Signals End of Poland’s Special Act for Ukrainian Refugees and Full Digitalisation of Residence Permits

UNHCR Legal Update Signals End of Poland’s Special Act for Ukrainian Refugees and Full Digitalisation of Residence Permits
The United Nations High Commissioner for Refugees (UNHCR) released its Protection-Sector Legal Update for Poland on 23 February, consolidating every immigration change adopted since the start of 2026. The headline item is Warsaw’s decision to abolish the stand-alone 2022 “Special Act” for Ukrainians on 5 March 2026, folding its provisions into the broader Law on Foreigners. Temporary-protection beneficiaries will keep labour-market access and social benefits, but will now lose status if they remain outside Poland for more than 30 days—an important nuance for assignees sent on extended business trips.

Equally significant for corporate mobility teams is Poland’s move to a 100 percent digital residence-permit platform, the Moduł Obsługi Spraw (MOS). Since 1 February all first-time and renewal applications must be filed online with qualified e-signatures; paper submissions are deemed “not filed.” Employers that fail to create MOS accounts for foreign staff risk fines of up to PLN 30,000 per worker if status lapses.

Companies looking for hands-on assistance with navigating the new MOS requirements and higher-fee visa categories can turn to VisaHQ’s Poland desk. Through its online portal and dedicated experts, VisaHQ streamlines residence-permit applications, secures qualified e-signatures, and provides deadline alerts—services already aligned with the rules outlined here. Learn more at https://www.visahq.com/poland/

UNHCR Legal Update Signals End of Poland’s Special Act for Ukrainian Refugees and Full Digitalisation of Residence Permits


The UNHCR bulletin also confirms a steep rise in government fees: the national-visa charge will jump 90 percent to €200 on 1 March, while stricter documentary evidence will apply to family-reunification cases. HR cost forecasts for 2026 assignments therefore need urgent revision, and relocation suppliers should update their fee schedules.

For global mobility stakeholders the operational impact is threefold. First, Ukrainian employees accustomed to visa-free travel home must monitor the new 30-day absence rule or risk cancellation of protection status. Second, companies must equip staff with trusted-profile e-signatures and train them on MOS navigation and seven-day document-completion notices (wezwania). Third, budgeting models must account for higher visa fees and potential late-filing penalties when legacy paper processes are abandoned.

UNHCR recommends that employers issue written briefings, set up automatic deadline reminders, and audit all active permits before 5 March to ensure continued compliance once the Special Act sunsets.
VisaHQ's expert visas and immigration team helps individuals and companies navigate global travel, work, and residency requirements. We handle document preparation, application filings, government agencies coordination, every aspect necessary to ensure fast, compliant, and stress-free approvals.
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