ul. Dywizjonu AK "Jeleń" 7B/U4, WarszawaHow it is filed
On paper
the exception to online-only filing
Who applies
Your Polish entity
and it is the only party to the case
Prior group service
12 or 6 months
manager or specialist / trainee
Maximum transfer
3 years / 1 year
manager or specialist / trainee
Where the transferee must be
Outside the EU
when the first application is filed
Stamp duty
PLN 440
plus PLN 100 for the residence card
On this page
What the ICT permit is
The ICT permit – zezwolenie na pobyt czasowy w celu wykonywania pracy w ramach przeniesienia wewnątrz przedsiębiorstwa – implements the EU intra-corporate transfer directive in Poland. It allows a group company established outside the European Union to second an employee to a Polish entity within the same undertaking or group, as a manager, a specialist or a trainee.
It is a single decision covering both residence and work: no separate work permit is needed, because the decision itself fixes the position, the minimum remuneration and the working time. Beyond that, almost everything about it differs from the permits your other foreign hires will be using.
It is a corporate filing
Your Polish entity files it, signs the declarations, receives the requests and holds the appeal right. The transferee is not a party to the proceedings at all. Powers of attorney come from the company, not from the individual.
It is a secondment, not a hire
The transferee stays employed by the parent company outside the EU and must be able to return there at the end. If the plan is for the person to join the Polish payroll permanently, ICT is the wrong instrument from the first day.
It is temporary by design
Three years for a manager or specialist, one for a trainee, and the clock counts the whole transfer including time spent in other Member States. It is built to end, and it does not lead anywhere by itself.
The permit is granted with the annotation “ICT” on the residence card – or “mobile ICT” where the person is here on long-term mobility from another Member State. Those two words on a card tell you which regime you are in, which is worth knowing when an employee arrives with a document issued in Germany or Czechia.
ICT is still filed on paper – and that matters
On 27 April 2026 Poland made electronic filing through the MOS portal compulsory for residence permits. Applications submitted any other way are left without consideration. Almost every page on this site now says so, because for almost every permit it is true.
ICT is one of the few exceptions. The Act expressly carves out the ICT permit and the long-term ICT mobility permit from mandatory electronic filing: the host entity files them in paper form. This is not a transitional indulgence and it is not optional – it is the route the statute prescribes.
The practical hazard runs the other way from what people expect. An ICT application pushed into MOS by a well-meaning HR platform or a global mobility vendor working from a general briefing is not a slightly irregular filing: it is outside the prescribed route, and the paper application that should have been lodged never was.
We flag this because the error is already circulating. Reputable Polish legal press has published the flat statement that from 27 April 2026 there are no exceptions and paper applications will not be examined – while listing ICT among the categories affected. The Office for Foreigners’ own guidance says the opposite and lists ICT and long-term ICT mobility as the first two paper exceptions, as do the voivodeship offices that actually receive the files.
So the ICT file is still what it always was: a physical bundle, with original signatures, certified copies and sworn translations, lodged at the voivodeship office for your entity’s registered seat. The one relief worth knowing is that the document evidencing the transferee’s prior service inside the group is exempt from the sworn-translation requirement – a small saving that is almost never mentioned, and that on a large transfer programme is not small at all.
Your company applies, not the transferee
On every other Polish residence permit the foreigner is the applicant. On ICT it is the host entity – your Polish company – and the statute goes further: in the proceedings to grant the permit, the host entity is the sole party. The transferee has no procedural standing whatever.
| Who does what | Consequence for your process |
|---|---|
| The host entity files | Your Polish company completes the form and signs the declarations, which are made under criminal liability for false statements. Someone authorised to act for the company has to sign – not the transferee, and not an HR contact abroad without authority. |
| The host entity is the only party | Requests for further documents, the decision and the right of appeal all sit with the company. If the transferee calls the office to ask about their case, they have no standing to be told anything. |
| Powers of attorney come from the company | A power of attorney signed by the transferee is worthless for the grant proceedings. This is the single most common structural error we see in files prepared abroad. |
| Withdrawal is different | If the authority later moves to withdraw the permit, both the host entity and the foreigner are parties. The individual acquires standing precisely when the news is bad. |
The renewal follows the same pattern: the host entity files it, and no later than the last day of the transferee’s lawful stay. Diarise that date against the company, not against the employee – it is the company that will miss it.
Who can be transferred: manager, specialist, trainee
The ICT permit is open to three categories of transferee and to nobody else. The category you choose is not a label on a form – it sets the minimum prior service inside the group, the maximum length of the transfer and the documents you have to produce.
Category one
Manager
A person holding a senior position who primarily directs the management of the host entity under the general supervision of its board or shareholders – the European definition, which Polish practice follows.
12 months of uninterrupted prior employment in the group · up to 3 years
Category two
Specialist
A person working within the group of undertakings who holds knowledge that is both key and specific to the areas in which the Polish host entity operates. Seniority alone is not the test; the knowledge has to be tied to what the Polish entity actually does.
12 months of uninterrupted prior employment in the group · up to 3 years
Category three
Trainee
A graduate holding a higher-education diploma, transferred for professional development. A traineeship agreement is required on top of everything else, setting out the programme, its duration and how the trainee will be supervised.
6 months of uninterrupted prior employment in the group · up to 1 year
Poland applies the maximum prior-service periods the EU directive allows. The directive lets Member States require anywhere from three to twelve months for managers and specialists, and three to six for trainees. Poland took twelve and six. If your group briefing sheet says “at least three months”, it is describing the European floor, not Polish law.
The service must be uninterrupted and must fall immediately before the transfer, within the same undertaking or the same group of undertakings. A person recruited externally three months ago and now being sent to Warsaw does not qualify, however senior the role.
One document rule is worth knowing before you budget the file: the evidence of that prior group service is exempt from the sworn-translation requirement that applies to foreign-language documents generally. On a single transfer that is a modest saving. On a programme of thirty, it is not.
The transferee must be outside the EU when you file
This is the gate that most often stops a transfer plan, and it is worth testing before anything else is prepared. At the moment the application is lodged, the transferee must be outside the European Union – not in Poland, and not in another Member State.
| Situation at the moment of filing | Outcome |
|---|---|
| Transferee is in the home country, outside the EU | Correct position. The application can be examined. |
| Transferee is already in Poland on another status | The authority refuses to initiate proceedings. The only exception is a further ICT permit for a transfer already running. |
| Transferee is in Germany, Czechia or any other Member State | The authority refuses to initiate proceedings – with no exception at all. |
| The longest or first part of the EU assignment is in another Member State | Poland is the wrong place to apply. The permit is granted by the Member State of the first or longest stay; Poland is then reached through mobility. |
| Transferee holds or is applying for a student, doctoral or researcher permit | Proceedings are not initiated. The same applies to posted workers of EU-established undertakings, the self-employed, and anyone employed through a temporary-work or placement agency. |
The practical conclusion for HR: an ICT permit cannot be used to convert someone who is already here. If a valued employee is in Poland on a permit for work and the group now wants to reclassify the relationship as a secondment, the honest answer is usually that this is a different permit, not a different form. We would rather tell you that in the first conversation than after a file has been built.
Conditions for the ICT permit
The conditions are cumulative: every one of them has to be satisfied, and the file has to show it. They fall into three groups – the person, the transfer instrument and the money.
The transferee
- Qualifications and experience adequate to the activity of the Polish host entity, for a manager or specialist; a higher-education diploma for a trainee.
- Formal qualifications for a regulated profession, where the position is one. Engineering, medical and several technical roles are caught more often than companies expect, and recognition takes its own time.
- Twelve or six months of uninterrupted prior service inside the undertaking or group, immediately before the transfer.
- Health insurance under the Polish public system, or confirmation that an insurer will cover the cost of treatment in Poland.
- Secured accommodation in Poland. Unlike several other permits, this one does require it – a tenancy, a corporate flat or company-arranged housing.
- The return condition. At the end of the transfer the person must be able to move back to the parent employer or to another undertaking in the same group established outside the European Union. A transfer with no home to return to is not an intra-corporate transfer.
The transfer instrument
Either a written contract or a document issued by the parent employer – an assignment letter is expressly sufficient, which is useful, because that is what most groups already produce. Whichever you use, it must state the period of the transfer, the seat of the host entity, the position, and the remuneration and other working conditions. A letter missing any of those four will come back as a request for documents and cost you weeks.
For a trainee, add the traineeship agreement: the programme, its duration, and the arrangements for supervising the trainee.
Proof that you are one group
Belonging to the same undertaking or group is not written as a separate tick-box, but it runs through the whole permit, and voivodeship offices require it to be documented – that the Polish host entity is a branch, a representative office or a member of the same group as the parent employer abroad. Group charts, registry extracts and shareholding evidence are part of the file, not an afterthought.
Remuneration: three separate floors, all of which apply
The remuneration test is where otherwise well-prepared transfers fail, because the package is usually designed in the home country and only then checked against Polish law. It has to clear all three of the following at once.
1. Above the social-assistance threshold
Higher than the income threshold for social-assistance benefits – and not only for the transferee, but for each dependent family member living with them. A family of four moves this floor considerably.
2. No less than comparable work in Poland
Not lower than the pay of workers in Poland performing comparable work, or holding a comparable position, at the same working time. This is a local-market comparison, not a home-country one.
3. At least 70% of the voivodeship average wage
Not lower than 70% of the average monthly gross wage in the national economy in the voivodeship where the host entity is seated, in the year before the application, as announced by the President of the Central Statistical Office.
The third floor is the one that surprises people, and two things about it are worth saying plainly. It is regional: the same salary can clear the threshold in one voivodeship and fall short in another, so where you seat the host entity is a substantive decision, not an administrative one. And it is not new – it has been in the statute since the ICT regime came into force in 2018. Guidance presenting it as a recent change is simply mistaken.
Because the figure moves every year with the published statistics, we check it against the current announcement at the date of filing rather than quoting a number that will be stale by the time your transfer starts. If you tell us the voivodeship and the proposed package, you will have the answer the same day.
How long an ICT permit lasts
There are two numbers to plan around, and a third that catches people out.
| Maximum length of the transfer | |
|---|---|
| Manager or specialist | 3 years in total. A further permit is refused once that period has elapsed. |
| Trainee | 1 year in total, and the permit itself is granted for up to one year. |
The ceiling is an aggregate for the transfer, not a per-permit allowance. Within it the transfer can be extended by a further permit, but the total cannot be stretched: three years is three years, whether reached in one decision or three.
The number that catches people out: mobility time counts. The validity of the Polish permit has to take account of the periods the transferee plans to spend working in other Member States during the transfer. Six months in the Prague office are six months of the Polish three years, not six months outside them.
So the mobility plan belongs in the application, not in a later conversation. If you tell the office at the outset that the assignment includes stints elsewhere in the EU, the permit is issued to fit; if you do not, you can find the document expiring in the middle of the transfer.
On the question that every global mobility team asks next: Polish law contains no mandatory cooling-off period before the same person can be transferred again. The EU directive permits Member States to impose a break of up to six months, and Poland did not take it up. The real constraint is the aggregate ceiling, and the scrutiny a second transfer of the same person will attract.
The procedure, step by step
What follows is the route for a first ICT permit filed in Poland, from the point at which the group has decided who is moving.
Test the gate
Is the transferee outside the EU? Is Poland the first or longest EU destination? Does the prior service reach twelve or six uninterrupted months inside the group? Is the position a regulated profession? Four questions, answered before anything is drafted.
Check the package against the three pay floors
Including the 70% voivodeship figure for the year before filing. If the package falls short, it is far cheaper to adjust it now than to answer a request for documents in four months.
Get the authority right
The application is signed by a person authorised to act for and on behalf of the host entity, and the declarations are made under criminal liability for false statements. Any power of attorney is granted by the Polish company. A power of attorney from the transferee has no effect here.
Build the paper file
The form, the declarations, a copy of the travel document and a current photograph of the transferee, the transfer instrument, group evidence, insurance, accommodation, regulated-profession recognition where relevant, and sworn translations – except for the prior-service document, which is exempt.
Lodge it with the voivode for your seat
In paper form, at the office for the voivodeship in which the host entity has its registered seat – not where the transferee will live. Pay the stamp duty and keep the confirmation with the file.
Answer the request for documents
Where the office wants more, it sets a deadline of not less than 14 days, and it may combine that request with one to cure formal defects or pay the fee, in which case the longest deadline governs. This is also the moment that starts the decision clock running.
Decision, visa, entry
The decision goes to the host entity. The transferee, who has been outside the EU throughout, then arranges entry on that basis and comes to Poland to complete the residence-card formalities.
Residence card marked “ICT”
The card carries the annotation ICT, or mobile ICT where the person is here on long-term mobility from another Member State. From then on the notification duties in the next section start to bite.
Renewal runs the same way and is filed by the host entity no later than the last day of the transferee’s lawful stay. Diarise that date against the company. The transferee is not a party and will not be reminded.
How long it takes – and why the statutory deadline will not help you
The statutory period for a first-instance decision is 60 days, and 90 days on appeal. For an ICT permit the 60 days do not run from the day you walk into the office: they run from the later of the host entity filing a formally complete application, or the host entity supplying the documents the office asked for – or the deadline for supplying them passing unused.
Two corrections to guidance that is still in circulation.
It is not 90 days. The ICT-specific 90-day deadline was repealed in January 2022 and the provision that carried it was removed from the Act altogether in April 2026. Any page still quoting 90 days for an ICT decision is four years out of date.
And the 60 days are currently suspended. Until 4 March 2027, the running of time limits for deciding temporary-residence cases before a voivode is suspended. In practice this means the 60-day figure is not an enforceable service standard, and the usual complaint about administrative inactivity is neutralised for the duration. Nor does ICT enjoy the priority handling that was introduced in 2026 for researchers and doctoral candidates.
We do not publish an average waiting time for ICT, because no reliable published figure exists and inventing one would be worse than silence. What we can say is that queues differ sharply between voivodeship offices, that the time is measured in months rather than weeks, and that the single biggest variable within your control is whether the file was complete on the day it was lodged.
The planning consequence is straightforward: fix the transfer start date by reference to the office’s actual queue, not to the statutory number, and build the file early enough that a request for documents does not become a second delay on top of the first.
EU mobility: bringing an ICT holder from another Member State
The commercial point of the ICT regime is that a permit issued in one Member State travels. If a transferee already holds a residence document annotated ICT issued elsewhere in the EU, you do not start again in Poland – you use mobility. There are two kinds, and they are not variations on a theme.
| Short-term mobility | Long-term mobility | |
|---|---|---|
| Length of work in Poland | Up to 90 days in any 180-day period | More than 90 days |
| What you do | A notification to the Head of the Office for Foreigners | A full application to the voivode for a long-term mobility permit |
| Who does it | The host entity | The host entity, which is again the sole party |
| What stops it | An objection within 20 days of a complete notification | Refusal on grounds close to those for the ICT permit itself |
| Work permit | Not required once the period passes without objection | Not required – the permit covers work |
| Card annotation | None – the person keeps the other Member State’s document | mobile ICT |
Short-term mobility: the 20 days, and what starts them
The notification goes to the Head of the Office for Foreigners, in Polish, on paper or electronically. It has to identify the transferee, the position and planned period of work in Poland, the Member State that issued the ICT document and its validity, and the host entity and parent employer, and it carries attachments – evidence that the host entity qualifies, proof of formal qualifications for a regulated profession, the contract or transfer document, and a copy of the travel document, with sworn translations of anything in a foreign language.
The 20 days run from a complete notification – all attachments, all translations. An incomplete filing does not start the clock, which is how companies end up believing they are free to start work when they are not.
Within that window the Head of the Office consults the Border Guard, the Police and the internal security agency on the security ground; they have 15 days and silence counts as no objection.
An objection is final. There is no administrative appeal against it – only a complaint to the administrative court. That makes the quality of the notification, first time, unusually important.
Grounds for objection include a host entity that does not meet the statutory conditions, missing qualifications for a regulated profession, pay below that of comparable positions in Poland, an ICT document that expires before the planned work ends, defence or State-security concerns, false data or forged documents, entry in the register of foreigners whose stay is undesirable, and a Schengen alert for refusal of entry and stay.
One more point that English-language guidance regularly gets wrong: the 90 days in any 180 are counted per Member State. Ninety days in Poland do not consume ninety days available in Czechia.
Long-term mobility – and a 14-day trap
Where the work in Poland will exceed 90 days, the host entity applies to the voivode for a long-term mobility permit. The conditions mirror the ICT permit closely: an ICT-annotated document issued by another Member State, qualifications for a regulated profession, health insurance, accommodation in Poland, the same return-outside-the-EU condition, a transfer instrument stating period, seat, position and conditions, and the same three remuneration floors including the 70% voivodeship figure. The permit cannot outlast the other Member State’s ICT document, and for a trainee it cannot exceed one year.
Do not notify short-term mobility and then immediately apply for the long-term permit. An application for long-term mobility filed on the day the short-term notification reached the Head of the Office, or within the following 14 days, is refused at the threshold – the proceedings are not even initiated. Companies hedging between the two routes walk into this regularly. Decide which route you are on before you file anything.
Moving the other way – sending a Polish ICT holder to work in another Member State – is governed by that State’s rules, and Poland requires no separate authorisation for it. What Poland does require is that the periods of planned mobility were taken into account when your Polish permit was issued, and that the change is notified to the voivode under the duties below.
What the host entity has to report, and when
There are two notification duties, at two different stages, with two different deadlines. Almost every English-language summary we have read quotes one of them and omits the other.
| Stage | Deadline | What must be reported |
|---|---|---|
| While the application is pending | Forthwith, in writing | Every change of circumstances affecting the conditions for granting the permit. |
| After the permit is granted | 15 working days, in writing | Every change of circumstances affecting the conditions of the permit already granted, to the voivode who issued it. |
Where the permit was granted on appeal by the Head of the Office for Foreigners, the post-grant notification still goes to the voivode who decided at first instance. The same duties apply to the long-term mobility permit.
In practice the reportable events are the ones your HR system already tracks: a change of position or remuneration, a change in the transfer period, a move of the host entity’s seat, the transferee leaving the group, a restructuring that changes the relationship between the Polish entity and the parent employer, or a planned period of work in another Member State.
The Act attaches no specific fine to the host entity for missing these deadlines, and we would rather say so than manufacture a threat. The real exposure is different, and larger: a missed notification is exactly the kind of “change of circumstances” that surfaces later as a ground for withdrawal of the permit, and withdrawal collapses your transferee’s status overnight.
Refusal and withdrawal
Two features of the refusal grounds are specific to ICT, and both are about the company rather than the individual.
The host entity itself is under examination
A first ICT permit is refused where the host entity was established mainly in order to facilitate the entry of transferred workers – the shell-entity ground. It is also refused where the employer or host entity is managed by a person penalised for offences under the 2025 act on entrusting work to foreigners or convicted of offences against employees’ rights under the Criminal Code; where social-insurance contributions are unpaid; where there are tax arrears, subject to the usual relief, deferral and instalment exceptions; or where the entity does not conduct business activity or has been declared bankrupt. Untrue data, false information or a forged document in the proceedings are separate grounds, as is a threat to public health.
For a newly incorporated Polish subsidiary whose first substantive act is an ICT filing, that first ground is not theoretical. It is met with evidence of real activity – premises, staff, contracts, a business purpose that exists independently of the transfer – assembled before filing rather than in answer to a request.
A further permit has its own grounds
A subsequent permit is refused where the previous one was used for a purpose other than the one for which it was granted, where the three-year or one-year transfer period has already elapsed, or where the application was filed during an unlawful stay. The Act also allows the Minister to cap ICT permits by regulation; we monitor whether any such limit is issued.
Withdrawal
The permit is withdrawn where the circumstances show it is being used for a purpose other than the one for which it was granted, or where the shell-entity, false-information or employer-disqualification grounds arise after the grant. Withdrawal is the one stage at which the transferee becomes a party alongside the company – which means the individual acquires the right to be heard and to appeal precisely when the news is bad. If a withdrawal notice has arrived, the deadlines are short and both parties need to act; that is a conversation to have the same week.
ICT years do not build long-term residence
This is the most commercially consequential thing on the page, and it is the point most often missed in transfer planning.
Time spent in Poland on an ICT permit or a long-term ICT mobility permit is expressly excluded from the five-year period of residence required for an EU long-term resident’s permit. An executive who spends three years in Warsaw on ICT builds no long-term-residence clock at all. Not a reduced one – none.
The permit is designed as a closed loop: it begins outside the EU, it ends with a return outside the EU, and it does not lead anywhere by itself. That is a perfectly sensible instrument for a two-year assignment. It is the wrong instrument for a person the group intends to keep.
So the question to settle at the start is not “which permit is quickest” but “where is this person in five years”. If the answer is that they will still be in Poland, an ordinary residence permit for work or an EU Blue Card – both of which do count towards long-term residence, and the Blue Card also counts periods in other Member States – is very probably the better structure, even if the first filing is a little more work.
When ICT is the wrong tool
We say this to clients more often than we recommend the permit. ICT is an elegant instrument for what it was built for, and a poor fit for almost everything else. Four situations in particular call for a different route.
| If this is your situation | The better route |
|---|---|
| The person is already in Poland on another status | ICT is closed to you. A residence permit for work or an EU Blue Card, depending on qualifications and salary. |
| The group wants the person to stay in Poland long term | A permit whose years count towards EU long-term residence and eventually citizenship. ICT years count for neither. |
| There is no group relationship, or the “parent” is established inside the EU | ICT does not apply. Depending on the arrangement, a work permit and residence permit, or the posting rules for EU service providers. |
| The prior service inside the group is under 12 months (or 6 for a trainee) | Either wait until it is met, or use an ordinary work route now. There is no discretion to shorten it. |
There is also a structural question worth asking out loud: does the transfer need to be a secondment at all? If the Polish entity will direct the work, bear the cost and want the person on its own payroll, the group may be describing a local hire in the language of a transfer – and the permit that fits a local hire is a different one, with a different application, filed by a different person. Sorting that out at the planning stage costs an hour. Sorting it out after a refusal costs a quarter.
Official fees
These are the amounts payable to the State. They are the smallest part of the cost of a transfer, and the part people ask about first.
| Item | Amount |
|---|---|
| Stamp duty – ICT permit | PLN 440 |
| Stamp duty – long-term ICT mobility permit | PLN 440 |
| Issue of the residence card | PLN 100 |
| Power of attorney | PLN 17 each |
The stamp duty is not refunded if the application is refused, which is one more reason to test the gate before building the file. Budget separately for sworn translations, for document legalisation or apostilles in the home country, and for recognition of qualifications where the position is a regulated profession – those are usually the larger numbers.
What corporate guidance gets wrong about the ICT permit
Every item below is something we have seen in writing, in briefings prepared by reputable organisations, in the last year. We set them out because an HR team working from any one of them will make a decision that costs months.
“From 27 April 2026 every residence application must be filed online.”
Not for ICT. The Act expressly carves the ICT permit and the long-term ICT mobility permit out of mandatory electronic filing; the host entity files them on paper. Polish legal press has published the opposite, listing ICT among the categories affected. The Office for Foreigners and the voivodeship offices that receive the files say the opposite of that.
“The transferee applies for the permit.”
No. The host entity applies and is the sole party to the proceedings. The transferee becomes a party only if the permit is later withdrawn. A power of attorney signed by the transferee does nothing.
“The statutory deadline is 90 days.”
Four years out of date. The ICT-specific 90-day rule was repealed in January 2022 and the provision removed entirely in April 2026. It is 60 days, running from the host entity’s complete filing – and suspended until March 2027.
“You can switch to ICT from inside Poland.”
No. Being in Poland, or in another Member State, at the moment of filing is a ground for refusing to initiate proceedings. The single exception is a further permit for a transfer already running.
“Three years on ICT counts towards permanent residence.”
It counts for nothing. ICT and long-term ICT mobility are expressly excluded from the five-year period required for an EU long-term resident’s permit. This is the misconception with the largest price tag attached.
“EU law imposes a six-month break between transfers.”
The directive permits Member States to impose one. Poland did not. The constraint is the three-year or one-year aggregate ceiling, not a cooling-off period.
“Short-term mobility gives 90 days across the EU.”
Per Member State, not in total. Ninety days of work in Poland do not consume the ninety available in another Member State.
“Notify short-term mobility, then apply for the long-term permit.”
An application for long-term mobility filed on the day the notification arrived, or within the following 14 days, is refused at the threshold. The two routes are alternatives, not a sequence.
“An objection to short-term mobility can be appealed.”
The decision is final. The only route is a complaint to the administrative court, which is slower and narrower than an appeal. Get the notification right first time.
“The host entity must notify changes within 15 working days.”
True after the permit is granted. While the application is still pending, the duty is to notify forthwith. Both exist; guidance usually quotes one.
“The ICT permit needs a separate work permit.”
It does not. The decision itself fixes the position, the minimum remuneration and the working time. The same applies once short-term mobility has passed the objection period.
“Every foreign document needs a sworn translation.”
Almost every one does – but the document evidencing the twelve or six months of prior service inside the group is expressly exempt. Nobody mentions it, and on a transfer programme it is a real saving.
The 70% voivodeship wage floor deserves a footnote of its own here: it is sometimes presented as a 2025 or 2026 novelty. It has been in the statute since the ICT regime came into force in 2018. Only the cross-reference to the statistics has changed.
How we work with HR and global mobility teams
We act for the host entity, which on an ICT permit is the client in the legal sense as well as the commercial one. That means our instructions, our power of attorney and our correspondence all run through your Polish company – and it means we can take the whole file off your HR team rather than supervising them through it.
Feasibility first
Before anything is drafted: is the transferee outside the EU, is Poland the first or longest destination, does the prior service qualify, is the position regulated, and does the package clear all three pay floors in your voivodeship. If the answer is no, you hear it in the first conversation.
The paper file, built properly
The application and declarations, the transfer instrument reviewed against the four mandatory elements, group evidence, insurance, accommodation, translations organised (and not paid for where the exemption applies), lodged with the right voivode.
Mobility, in and out
Short-term notifications to the Head of the Office for Foreigners, long-term mobility applications, and the sequencing between them – including keeping you clear of the 14-day bar. Also the planning of outbound moves so the Polish permit is issued long enough to cover them.
Compliance after the grant
A notification calendar your HR system can actually run: what counts as a change of circumstances, which of the two deadlines applies, and who signs. Plus renewals diarised against the company, not the employee.
Refusals, objections and withdrawals
Appeals against refusal, complaints to the administrative court against a final objection to short-term mobility, and defence of withdrawal proceedings – where both your company and the transferee are parties and the deadlines are short.
Programme-level advice
Where a group is moving several people, the questions are structural: which entity, which voivodeship, which permit for whom, and which of these people should not be on ICT at all because the group intends to keep them.
Planning a transfer into Poland?
Tell us the category, the voivodeship, the proposed package and where the person is today. That is enough for us to tell you whether ICT works, what it will take, and whether something else would serve the group better.
Talk to our corporate team → office@krasuski.legalICT permit – frequently asked questions
Who signs the ICT application – the company or the employee?
A person authorised to act for and on behalf of the Polish host entity. The declarations are made under criminal liability for false statements, so the signatory needs real authority, and a power of attorney to advisers must come from the company. The transferee signs nothing and is not a party to the proceedings.
Is the ICT application really still filed on paper?
Yes. Mandatory electronic filing through the MOS portal came in on 27 April 2026 for residence permits generally, but the Act expressly excludes the ICT permit and the long-term ICT mobility permit: those are filed by the host entity in paper form. An ICT application pushed into the portal is outside the prescribed route, and the paper application that should have been lodged never was.
Our candidate is already working in Poland. Can we move them onto ICT?
No. At the moment of filing the transferee must be outside the European Union, and being in Poland is a ground for refusing to initiate proceedings. The only exception is a further permit for a transfer that is already running. This is the gate that ends most conversations about converting an existing hire.
How long must the person have worked for the group?
Twelve uninterrupted months for a manager or specialist, six for a trainee, immediately before the transfer and inside the same undertaking or group. Poland applied the maximum periods the EU directive allows, so briefings quoting three months are describing the European floor rather than Polish law. There is no discretion to shorten it.
What salary do we have to pay?
Enough to clear three floors at once: above the social-assistance income threshold for the transferee and each dependent family member; no less than comparable work or a comparable position in Poland at the same working time; and at least 70% of the average gross wage in the national economy in the voivodeship where the host entity is seated, for the year before filing. The third floor is regional, so the same package can pass in one voivodeship and fail in another.
How long does an ICT permit last, and can it be extended?
Up to three years in total for a manager or specialist and up to one year for a trainee. Within that ceiling the transfer can be extended by a further permit, but the total cannot be. Periods of planned work in other Member States count towards the Polish permit’s validity, so the mobility plan belongs in the original application.
Is there a cooling-off period before the same person can be transferred again?
Not in Poland. The EU directive allows Member States to require a break of up to six months and Poland did not enact one. What binds is the three-year or one-year aggregate ceiling on the transfer itself, and the scrutiny a repeat transfer of the same person attracts.
Does time on an ICT permit count towards permanent residence or citizenship?
No. Stay on an ICT permit or a long-term ICT mobility permit is expressly excluded from the five-year period required for an EU long-term resident’s permit. Three years in Warsaw on ICT build no long-term-residence clock at all. If the group intends to keep the person in Poland, a residence permit for work or an EU Blue Card is very probably the better structure from the outset.
Our transferee holds an ICT card issued in Germany. What do we do in Poland?
Use mobility rather than a fresh permit. For work of up to 90 days in any 180-day period, the host entity notifies the Head of the Office for Foreigners and may proceed if no objection is raised within 20 days of a complete notification – and that objection, if it comes, is final. For longer work, the host entity applies to the voivode for a long-term mobility permit, which cannot outlast the German document. Do not file the long-term application within 14 days of a short-term notification: it will be refused at the threshold.
What do we have to report to the authorities once the permit is granted?
Every change of circumstances affecting the conditions of the permit, in writing, within 15 working days, to the voivode who granted it. While the application is still pending the same duty exists but must be performed forthwith. The Act attaches no specific fine to the host entity, but an unreported change is exactly what later surfaces as a ground for withdrawing the permit.
How long will the decision take?
The statutory period is 60 days from the host entity’s complete filing, but the running of that period is suspended until 4 March 2027, which also removes the usual remedy for administrative delay. We do not publish an average, because no reliable figure for ICT exists and queues differ sharply between voivodeship offices. Plan on months, and on the start date being driven by the office rather than by the statute.
We have just incorporated the Polish entity. Is that a problem?
It is a risk to manage, not a bar. A permit is refused where the host entity was established mainly in order to facilitate the entry of transferred workers, and a new subsidiary whose first substantive act is an ICT filing invites that question. It is answered with evidence of genuine activity – premises, staff, contracts, a business purpose independent of the transfer – assembled before filing rather than in reply to a request for documents.
Your attorney
Konrad Krasuski – Attorney at law
Konrad leads the firm’s corporate immigration practice: ICT transfers and EU mobility, the structuring questions that come before the filing, and the compliance obligations that follow it. If you are deciding whether a transfer should be an intra-corporate transfer at all, that is the conversation to have with him first.
k.krasuski@krasuski.legal
Warsaw: +48 502 115 589 Wrocław: +48 71 719 59 08
Legal status as of September 2026. This article is general information and does not constitute legal advice in an individual case. Whether a particular transfer qualifies as an intra-corporate transfer, and whether your entity, your transferee and your package satisfy the conditions for an ICT permit, depends on the documents and can only be assessed on them.
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