Poland’s amended Act on Employment Promotion, which enters into force on 1 June 2026, gives county (powiat) authorities—and ultimately the central government—a brand-new tool: ad-hoc “lists of occupations” in which no work permits or declarations of entrustment may be issued to foreigners for as long as local labour conditions warrant. According to the Labour and Social Policy Ministry, the mechanism is designed for emergencies such as mass layoffs or sudden sectoral downturns. A county labour office that detects an oversupply of jobseekers will be able to ask the starosta (county governor) to compile a list of surplus occupations. After consultation with the county labour-market council, the list must be endorsed by the wojewoda (provincial governor), who will test it against national security, migration policy and economic needs before publication in an online register.
![Crisis-Response Lists Will Let Polish Counties Ban Foreign Hires in Specific Occupations]()
If your organisation suddenly needs to reroute talent or seek alternative immigration options because a county list shuts the door on non-EU hires, VisaHQ can help. Through its Poland portal (https://www.visahq.com/poland/), the firm provides real-time visa intelligence, document processing and courier services, allowing HR teams to pivot quickly between work-permit categories, Schengen visas and neighbouring jurisdictions without missing project deadlines.
Although no county has announced plans to activate the measure, officials interviewed by Rzeczpospolita note that retail, hospitality and agriculture—sectors with high rotation and large numbers of migrant workers—could be first in line if unemployment spikes. For employers, the impact would be immediate: new foreign hires in listed roles would be impossible, and pending applications could stall for months. Companies would have to pivot to EU talent, automation or offshoring to stay on schedule. Legal advisers stress that the lists are temporary by design and can be lifted as soon as market conditions improve. Nevertheless, multinational HR teams should map critical roles and suppliers across Poland to gauge vulnerability. Businesses active in multiple counties may face a patchwork of rules; a project safe in Warsaw could be blocked 20 kilometres away in Otwock. Practical tips include building “plan B” recruitment pipelines, monitoring county websites daily, and adding force-majeure clauses to vendor contracts that rely on non-EU personnel. The good news is that existing foreign staff keep their permits, but intra-company transfers into restricted counties will be off-limits until the ban is revoked.
If your organisation suddenly needs to reroute talent or seek alternative immigration options because a county list shuts the door on non-EU hires, VisaHQ can help. Through its Poland portal (https://www.visahq.com/poland/), the firm provides real-time visa intelligence, document processing and courier services, allowing HR teams to pivot quickly between work-permit categories, Schengen visas and neighbouring jurisdictions without missing project deadlines.
Although no county has announced plans to activate the measure, officials interviewed by Rzeczpospolita note that retail, hospitality and agriculture—sectors with high rotation and large numbers of migrant workers—could be first in line if unemployment spikes. For employers, the impact would be immediate: new foreign hires in listed roles would be impossible, and pending applications could stall for months. Companies would have to pivot to EU talent, automation or offshoring to stay on schedule. Legal advisers stress that the lists are temporary by design and can be lifted as soon as market conditions improve. Nevertheless, multinational HR teams should map critical roles and suppliers across Poland to gauge vulnerability. Businesses active in multiple counties may face a patchwork of rules; a project safe in Warsaw could be blocked 20 kilometres away in Otwock. Practical tips include building “plan B” recruitment pipelines, monitoring county websites daily, and adding force-majeure clauses to vendor contracts that rely on non-EU personnel. The good news is that existing foreign staff keep their permits, but intra-company transfers into restricted counties will be off-limits until the ban is revoked.
