Polish President Karol Nawrocki has signed the 23 January 2026 amendment to the Act on Foreigners, kicking off the biggest overhaul of work-authorisation rules for Ukrainians since the full-scale Russian invasion. From 5 March 2026, employers must adapt to a dual-track system: refugees under temporary protection keep their PESEL-UKR-based right to work, while newcomers without that status need a new CUKR residence card or a standard work permit.
The headline change is speed. Notifications to hire Ukrainians—once valid indefinitely—now expire after three years and must be filed within seven days of any material change in contract terms. The Ministry of Labour’s online notice form has been simplified, but stiff penalties of up to PLN 3,000 apply for late or inaccurate filings.
Employers and individuals who need assistance navigating Poland’s evolving immigration landscape can streamline the process through VisaHQ. The platform’s Poland desk (https://www.visahq.com/poland/) offers step-by-step support for residence cards, work permits and PESEL registrations, giving both HR departments and Ukrainian nationals a single online interface for document checklists, application tracking and expert advice.
![New employment rules for Ukrainian nationals take effect on 5 March 2026]()
Equally important is identity verification. HR teams must confirm that each PESEL-UKR record matches a valid biometric passport; mismatches will trigger an automatic MOS 2.0 alert that can void the employee’s right to work. For Ukrainians arriving after 5 March 2026 the clock is even tighter: they have just 30 days to obtain a PESEL-UKR, without which employers cannot file the mandatory notification.
Grant Thornton’s global-mobility practice warns that companies with large Ukrainian workforces should conduct a “March Audit”—cross-checking PESEL numbers, contract amendments and MOS log-ins—before the end-of-quarter payroll run. Failure to do so could expose firms to retroactive fines and, in extreme cases, criminal liability for facilitating illegal employment.
While the reform raises the administrative bar, it also delivers predictability. The dreaded labour-market test (informacja starosty) remains abolished, and digital processing promises faster decisions once the initial learning curve is behind employers.
The headline change is speed. Notifications to hire Ukrainians—once valid indefinitely—now expire after three years and must be filed within seven days of any material change in contract terms. The Ministry of Labour’s online notice form has been simplified, but stiff penalties of up to PLN 3,000 apply for late or inaccurate filings.
Employers and individuals who need assistance navigating Poland’s evolving immigration landscape can streamline the process through VisaHQ. The platform’s Poland desk (https://www.visahq.com/poland/) offers step-by-step support for residence cards, work permits and PESEL registrations, giving both HR departments and Ukrainian nationals a single online interface for document checklists, application tracking and expert advice.
Equally important is identity verification. HR teams must confirm that each PESEL-UKR record matches a valid biometric passport; mismatches will trigger an automatic MOS 2.0 alert that can void the employee’s right to work. For Ukrainians arriving after 5 March 2026 the clock is even tighter: they have just 30 days to obtain a PESEL-UKR, without which employers cannot file the mandatory notification.
Grant Thornton’s global-mobility practice warns that companies with large Ukrainian workforces should conduct a “March Audit”—cross-checking PESEL numbers, contract amendments and MOS log-ins—before the end-of-quarter payroll run. Failure to do so could expose firms to retroactive fines and, in extreme cases, criminal liability for facilitating illegal employment.
While the reform raises the administrative bar, it also delivers predictability. The dreaded labour-market test (informacja starosty) remains abolished, and digital processing promises faster decisions once the initial learning curve is behind employers.
