Work permit in Poland – the employer’s guide

What changed on 1 June 2025

The rules on employing foreign nationals used to sit inside the employment-promotion act. On 1 June 2025 they moved into a statute of their own, and the move was not a tidying exercise. Almost every operational assumption an HR team had built up over a decade stopped being true on the same day.

There is one point of continuity worth holding onto: legal residence and legal work remain two separate questions. A foreign national needs a title that permits them to be in Poland and a basis on which to work. Getting one right and the other wrong is still the most expensive mistake in this area, and the 2025 act did nothing to soften it.

Does your hire need a work permit at all?

A surprising share of the work permits employers ask us to obtain are not needed. Before anything is filed, the question is which of four positions the candidate is in.

The exemption list is long, technical and has just been rewritten, so it is worth checking rather than assuming. A Polish graduate, a doctoral candidate and a Karta Polaka holder all work without a permit, and employers routinely apply for one anyway – paying 400 zł and waiting months for a document with no legal effect.

The three work permits that replaced types A to E

The letters are gone. In their place are three permits named after the arrangement they cover, plus the seasonal permit, which sits on its own track. If you are translating from the old system, this is the map.

Practically, the renaming matters for one reason above all: the old application forms no longer exist. Since 1 January 2026 the portal offers only the three new forms, so a template, a checklist or an internal instruction that still says “apply for a type A permit” cannot be executed at all. If your onboarding pack mentions letters, it needs rewriting before your next hire, not after.

Two further points of substance survive the renaming. The permit is granted by the voivode, and it is always specific: it names the employer, the position or type of work, the minimum remuneration, the working time and the type of contract. Work performed on terms other than those stated is not a technical breach – it is illegal entrusting of work, with the consequences set out further down this page.

The declaration route – and who quietly lost it

For nationals of a short list of countries, an employer can skip the permit and register a declaration on entrusting work with the district labour office instead. It is faster and simpler, and it is the backbone of hiring in several sectors.

Everything else about the declaration route tightened in line with permits: it is filed electronically, a written contract must exist before work starts, and the terms actually applied must match what was registered.

Filing: one portal, and not the one you have been reading about

Since 1 June 2025, applications for work permits and declarations – together with supplementary documents, appeals and complaints – go exclusively through praca.gov.pl, from an individual account, signed with a qualified electronic signature, a trusted profile or a personal signature.

The voivodeship offices put the consequence in plain terms: an application submitted any other way – by post, through a document-exchange system, over the counter – will be left without consideration. Not rejected on the merits. Not returned for correction. Simply not examined, with the filing date lost.

One practical consequence of the move to a single portal is that the account matters. The individual account is tied to a signature, and whoever holds it is, in practice, the person who can file, answer a request for documents and lodge an appeal within the deadline. Concentrating that in one HR inbox is a single point of failure worth planning around – particularly in August and around year end.

Conditions: pay, hours and the quarter-time floor

For the ordinary permit – a Polish company employing the foreigner directly – three conditions do most of the work, and one of them is new enough to catch people out.

The quarter-time floor deserves a moment because it is structural rather than procedural. It rules out the marginal part-time arrangements that some employers used for students, for people combining two jobs, and for roles that were genuinely small. If a role is smaller than a quarter of full time, the answer is not a differently worded application – it is a different arrangement or a different legal basis, and that is a conversation to have before an offer goes out.

Where the position is a regulated profession or the activity itself is regulated, the qualifications and authorisations have to be in place as well. Recognition of foreign qualifications runs on its own timetable, generally a slower one than the permit, so it belongs at the start of the project rather than in the middle.

How long a work permit lasts

The general rule is up to three years. Two situations cut it to one.

The one-year cap on new employers is the one that shapes projects. A group setting up a Polish subsidiary and staffing it with foreign nationals in the first year will be renewing every permit at the twelve-month mark, all at once. That is predictable, and it is much cheaper to plan for in month two than to discover in month eleven.

What the employer must do, and by when

The permit is the easy part. The duties that attach to it run for the whole engagement and beyond it, and most of what a labour inspector looks at is here rather than in the application file.

Before the first day

• Check the residence document and take a copy. Not a glance – a copy, kept for the whole period of work and for two years after it ends. Employers who hold nothing have no defence at all on an inspection, however genuine the document was.
• Conclude the contract in writing, before work begins. The contract has to be presented to the foreigner in a language they understand, which in practice means a translation. Starting someone on a handshake and papering it the following week is illegal entrusting of work in its own right, even if the permit is flawless.
• Make the terms match the permit. Position or type of work, working time, minimum remuneration, type of contract. A promotion, a shift pattern change or a move from a civil-law contract to employment can all take the arrangement outside the permit.

During and after

Not every change requires a new permit – the act lists changes that can be handled by notification instead, and using the right one saves months. Knowing which column a given change falls into is most of the value of having this run properly: employers tend to over-apply, which is slow, or under-notify, which is expensive.

Posting workers to Poland

Where the worker stays employed by a foreign entity and is sent to Poland, the old types C, D and E have become three sub-cases of a single posting permit:

• posting to a branch, subsidiary or affiliated entity of the foreign employer – the old type C;
• posting to provide a temporary and occasional service by a foreign employer with no ongoing activity in Poland – the old type D;
• posting for any other purpose – the old type E.

Jurisdiction follows the arrangement: for a posting to a related entity, the voivode for that entity’s seat; for a service or other posting, the voivode for the recipient’s seat or the place where the work is mainly done; and where neither can be established, the Mazowieckie voivode. A posting permit cannot be used for seasonal work or for board and proxy functions – those belong to the other two permits, and applying under the wrong head means starting again.

Posting from inside the EU is a different question. A worker employed by an undertaking established in an EU or EEA state, in accordance with that state’s law and normally working there, may be posted to provide services in Poland for a short period without a Polish work permit; beyond that, the posting permit is engaged. Where the line falls in a given assignment is worth checking rather than assuming, because the consequence of getting it wrong falls on the Polish recipient as much as on the sender. We cover this in more detail on our page for EU service providers.

Whatever the answer on the permit, the posting-of-workers rules apply in parallel: notification to the labour inspectorate, Polish minimum terms and conditions, documentation kept in Poland. Those obligations are untouched by the 2025 act and are enforced separately. Clearing the immigration question does not clear the labour-law one.

Ukrainian nationals and temporary protection

The special regime for people who came from Ukraine after February 2022 has been progressively folded into the ordinary law. Since 5 March 2026 the arrangement sits inside the work act itself.

The notification is easy to file and easy to forget, and missing it is a separate offence with its own fine band. For an employer with dozens of Ukrainian staff, the practical answer is not vigilance but process: tie the notification to the same trigger that creates the ZUS registration, so it cannot be skipped by someone starting a week early.

Residence titles that do not allow work – where good files go wrong

A work permit says the employer may entrust the work. It says nothing about whether the person may be in Poland, and it does not cure a residence title that excludes work. Three changes since June 2025 have made this trap materially worse, and none of them is in the English-language guides.

The pattern in all three is the same and worth stating to anyone in your business who makes offers: the permit and the residence title are checked separately, and the weaker one governs. An employer holding a valid work permit whose employee is working on the wrong visa is entrusting work illegally, and the fine lands on the employer.

Refusal grounds – now mostly about you, not about your hire

This is the deepest change in the 2025 act and the one in-house counsel should read first. The refusal grounds are mandatory: where one applies, the authority must refuse. There is no weighing, no explanation of circumstances, no discretion to be persuaded out of. And most of them look at the employer.

There is a second head of refusal aimed at employers who failed to perform their duties in connection with earlier permits – the notifications and contract obligations set out above. The compliance record and the ability to hire are now formally joined: a missed notification last year is not merely a past irregularity, it is an obstacle to this year’s recruitment.

There are of course grounds relating to the foreigner as well – qualifications for a regulated profession, convictions, entries in the register of undesirable foreigners or a Schengen alert – and the possibility that the occupation appears on a district list. But the centre of gravity has moved. For most employers the sensible preparation before a hiring programme is a clean check of contributions, tax position and prior notifications, done before the first application rather than after the first refusal.

Penalties, and what inspectors can now do without a court

The sanctions were raised on 1 June 2025 and, more importantly, made far easier to impose.

What counts as illegal entrusting is broader than most employers assume. It covers working without the required permit or declaration, working on a residence title that does not permit work, working in a different position or on different terms than the permit states, and – on its own – having no written contract. The last two do not feel like immigration breaches at all, which is exactly why they are the ones we see.

Fees

All four amounts below rose on 1 December 2025, in most cases fourfold. Any page still quoting 50, 100 or 200 zł is describing the position before that date.

For a company hiring at volume the increase is not trivial: fifty declarations that cost 5,000 zł in November 2025 cost 20,000 zł in December. It is also a reason to be sure a permit is needed before paying for one – see whether your hire needs a permit at all.

How long it takes

We do not publish an average, and we would be sceptical of anyone who does. The 2025 act sets no special deadline for deciding a work permit, so the general administrative time limits apply, and actual waiting times differ sharply between voivodeship offices and between quarters.

What the act does introduce is an order of priority among pending applications – undertakings of strategic or essential importance first, then renewals, then shortage occupations, then everything else. Whether a given employer or role falls into a priority band is a question worth asking at the planning stage, because it affects sequencing more than anything you can do once the file is lodged.

The single biggest variable you control remains completeness on the day of filing. An electronic file missing an attachment does not fail fast; it waits in the queue and then generates a request for documents, which starts the wait again.

Work permit, single permit, Blue Card or ICT?

A work permit is one of several ways to make an engagement lawful, and often not the best one. The right question is not “how do we get a work permit” but “what does this person’s next five years look like”.

The choice has consequences long after onboarding. Years spent on a work permit with an ordinary residence permit count towards EU long-term residence and eventually citizenship; years on an ICT transfer count towards neither. For a person the business intends to keep, choosing the quick route at the start can cost them five years at the end.

What guidance on the Polish work permit still gets wrong

Each item below is something we have read this year, in guidance an employer could reasonably have relied on – including from Polish law firms and, in several cases, from Polish government pages that were never updated.

One consequence is worth stating for anyone maintaining an internal handbook: the useful test is no longer whether a source looks authoritative, but when it was last revised. Several Polish government pages currently carry pre-June-2025 content with no date on the page at all.

How we work with employers

We act for the company. In most of this area the employer is the applicant, the party and the one the penalties land on, so that is where our instructions and our power of attorney sit – and it means we can take the filings off your HR team rather than supervising them through the portal.

Work permits in Poland – frequently asked questions