This article provides an overview of the key changes to Polish immigration regulations that came into force on 1 June 2025. These amendments mark one of the most comprehensive and far-reaching overhauls of Poland’s immigration framework in recent years. The reform package introduces a range of new compliance obligations, modifies existing administrative procedures and significantly redefines the legal landscape for employment-related immigration.

The changes directly affect both employers and foreign nationals working or planning to work in Poland. Employers must now navigate new responsibilities related to hiring and maintaining the lawful employment of foreign workers, while individuals from third countries will face revised application procedures. Both will experience additional reporting requirements.

The overarching goals of the reform include improving transparency, reducing bureaucratic barriers and aligning Polish immigration law more closely with evolving EU directives and best practices. At the same time, some of the measures respond to pressing labour market needs, demographic shifts and current geopolitical realities that have increased the demand for foreign talent in key sectors of the economy.

Overall, the new regulations are expected to reshape the way in which businesses and individuals approach immigration and employment in Poland, requiring careful attention to compliance in order to avoid legal and operational risks.

Elimination of the Labour Market Test – Introduction of “Protected” Job Roles

Under the new regulations, the traditional labour market test – a prerequisite for many job roles – has been abolished. Previously, employers were required to prove that no suitable Polish or EU candidates were available for a given position before hiring a foreign national. This step, often considered time-consuming and bureaucratic, has now been replaced with a more streamlined mechanism.

In its place, regional authorities (mid-level administrative bodies) will be empowered to publish and maintain a list of “protected” job positions. These are roles considered particularly sensitive from a labour market perspective – either due to high local unemployment in that sector or strategic socio-economic priorities.

Mandatory Online Submission of Work Permit Applications

All applications for work permits in Poland must be submitted via an online platform. The new system aims to streamline the application process and reduce administrative backlogs.

Expansion of Mandatory Grounds for Refusing Work permits and Residence Permits

The amended regulations introduce a broader set of mandatory grounds on which authorities must refuse to issue work permits and temporary residence permits for the purpose of work. These changes reflect the government’s intent to increase oversight and prevent abuses of the immigration system, particularly in cases involving intermediary employers.

A work permit application will now be refused if the facts suggest that the foreign national would, in reality, be working for a third party – not for the employer listed in the application. This rule does not apply to employment arranged through temporary work agencies, where working for a third-party client is an accepted and regulated model.

Authorities will be required to refuse such applications if any of the following conditions are met:

  • The employer was created solely for the purpose of facilitating the entry of foreign nationals, without conducting any genuine business activity.
  • The employer fails to meet financial criteria, which includes having outstanding social security or tax liabilities.
  • The employment contract offers less than one-quarter of a full-time position, raising questions about the legitimacy or sustainability of the job offer.

These stricter requirements place greater responsibility on both employers and foreign nationals to ensure that job offers are genuine, lawful and compliant with Polish labour and immigration standards.

Limited Validity of Work Permits in Certain Employment Scenarios

Under the revised regulations, the validity of work permits will be limited to a maximum of one year in specific cases, reflecting the authorities' heightened focus on the credibility and stability of employment arrangements.

A one-year cap will apply in the following situations:

  • Part-time employment: Where the foreign national is expected to work less than half of a full-time position, regardless of the duration specified in the employment contract.

  • Newly established companies: Where the sponsoring employer has been in operation for less than 12 months at the time of submitting the work permit application.

These provisions are intended to mitigate the risk of fictitious employment and ensure that foreign nationals are being hired into stable and verifiable positions. The authorities are likely to treat the situations mentioned above as inherently higher-risk and may subject them to additional scrutiny.

Stricter Rules for Right-to-Work Checks and Visa Compatibility

The new regulations impose heightened obligations on employers to verify the legal basis of a foreign national’s stay in Poland before commencing employment. In particular, the rules clarify a previously ambiguous situation regarding the compatibility of visas and work permits.

It is no longer permissible to work in Poland on the basis of a visa issued by another Schengen country, even if the individual holds a valid Polish work permit. In other words, a Polish work permit must be paired with a legal basis of stay such as:

  • A Polish visa (exceptions may also apply for the purpose of issuing visas).
  • A residence permit issued in Poland or another Schengen country, or
  • A visa-free stay.

This means that a foreign national who enters Poland with, for example, a French or Spanish national visa, even if valid for Schengen travel, may not lawfully take up employment in Poland, even if a Polish work permit has been granted. A failure to conduct proper right-to-work checks under the new regime could lead to serious compliance consequences.

Fines for Illegal Employment will Increase.

The increased penalties reflect a broader compliance-first approach within the new legal framework. They are intended to serve as a deterrent against informal or unauthorised employment practices. The fines for employers will be now range from PLN 3,000 to PLN 50,000, and for foreign nationals from PLN 1,000 to PLN 5,000.

Increased Employer Compliance Obligations

The amended rules introduce new and stricter compliance duties for employers hiring foreign nationals. These obligations aim to ensure greater transparency in employment relationships and to safeguard foreign workers’ rights.

Employers will now be legally required to submit a copy of the employment contract (or a service contract) concluded with a foreign national before the individual begins working. This requirement will be phased in as follows:

  • From 1 July 2025 – mandatory for cases based on declarations of entrusting work to a foreigner (simple work permit),
  • From 1 August 2025 – mandatory for standard work permit applications.

In addition, employers will be obliged to inform every foreign employee in writing – in a language they understand – about their right to join trade unions in Poland.

Stricter notification requirements

As part of the recent immigration reform, effective 1 June 2025, employers are now subject to stricter notification requirements. To ensure compliance and avoid penalties, it is crucial for employers to closely monitor all reporting obligations and implement internal procedures to meet the required timelines.

New notification deadlines for work permits – employers will be required to inform the authorities within seven days in the following cases: a foreign national has not started employment within two months from the initial validity date of the work permit; a foreign national has stopped working for a period exceeding two months; or a foreign national has terminated their employment more than two months before the expiry date of their work permit.

New notification deadlines for declarations of entrusting work to a foreign national – employers will be required to inform the authorities that a foreign national has started work within seven days from the commencement date indicated on the declaration, as well as if a foreign national has failed to start work within 14 days from the commencement date indicated on the document.

Employers of a foreign national working under a residence permit for the purpose of work are required to inform the Immigration Office within 15 working days in several cases: a change in the name of the job position without a change in the scope of duties (the same obligation applies in the case of a work permit, but within seven days) and termination of work by the foreign national.

Remote Work from Poland – Scope of Permitted Activities Without a Work Permit

Under the updated immigration rules, occasional and incidental remote work performed for a foreign (non-Polish) entity, where the work has no connection to the Polish labour market or economy, will be permitted without the need for a Polish work permit.

This exception is particularly relevant for:

  • Foreign nationals staying in Poland temporarily (e.g. on a visa or under visa-free travel),
  • Digital nomads or business travellers engaging in short-term assignments that are entirely disconnected from Polish employers or clients.

However, it is important to note that this exemption applies only to irregular, non-systematic remote work and does not cover typical full-time remote work performed from Poland, even if the employer is located abroad. In other words, if a foreign national resides in Poland and regularly performs remote work for a foreign company (e.g. on a full-time basis), this falls outside of the exception.

Stricter Conditions for Work Permits in the Case of Postings

The new immigration regulations introduce stricter requirements for obtaining work permits for foreign nationals posted to Poland, particularly in the context of intra-company transfers and service provision arrangements.

Before a posting to Poland can commence, the foreign national must be employed by the posting entity and have actually performed work. Intra-group postings will also require the existence of vertical capital ties between the posting entity and the Polish receiving entity. In the case of a posting for the purpose of providing services, there must be a direct service agreement entered into by the foreigner’s employer.

Key Changes for Blue Card Holders – Greater Flexibility and Expanded Rights

The recent reform introduces several important improvements for holders of the EU Blue Card in Poland, aimed at increasing the scheme’s attractiveness for highly skilled foreign professionals.

Highlights of the changes include:

  • Shorter Required Contract Duration: The minimum length of the employment contract required to apply for a Blue Card has been reduced from 12 months to 6 months, making the process more accessible and adaptable to dynamic job markets.
  • Relaxed Experience Requirements in Tech: For selected IT and New Technology roles, the required work experience threshold has been lowered from five years to three years.
  • Easier Employer Transitions: Blue Card holders now benefit from increased flexibility when changing employers. The process involves fewer formalities and a simple notification to the authorities may suffice in many cases.
  • Right to Start a Business: One of the most notable updates is that Blue Card holders are now explicitly permitted to establish and run their own business in Poland.

These changes reflect a broader trend toward modernising the Blue Card system and encouraging long-term residence of high-skilled professionals in Poland’s economy.

Important Changes to Temporary Residence Permits for the Purpose of Work

The new regulations bring significant restrictions on eligibility for applying for a temporary residence permit (TRP) for the purpose of work in Poland.

Key changes include:

  • Limited Visa Eligibility: Certain categories of Polish national visas will no longer allow their holders to apply for a temporary residence permit for the purpose of work.
  • Schengen Visa and Permit Holders Excluded: Foreigners who hold Schengen visas or residence permits issued by other EU/Schengen countries will, as a rule, no longer be eligible to apply for a work-based residence permit in Poland.

An exception applies to Blue Card candidates who meet the Blue Card criteria. These individuals may still initiate the Blue Card application process, even if they hold a residence permit from another EU country.

These changes are intended to strengthen control over migration flows and ensure that only those with a clear legal basis tied to employment in Poland can transition to long-term residence. Employers and individuals should carefully assess the type of visa or permit held prior to starting the TRP application process.