I describe the legal status current as of November 20, 2025, taking into account new regulations in force from June 1, 2025, and the extension of special rules for employing Ukrainian citizens until March 4, 2026. I also indicate where you can check current interpretations on Polish government websites.
What are the basic principles of legally employing a foreigner in Poland in 2026?
Legal employment of a foreigner in Poland is based on a simple equation: legal stay + right to work + consistent contract. When any element is incorrect, you risk a high penalty for illegal entrustment of work.
Three pillars of legal work for a foreigner
Before signing a contract with a foreigner, always verify three areas. This limits the risk of inspections and costly corrections.
- Legal stay – valid visa, residence card, visa-free travel, or special regulations, e.g., for citizens of Ukraine.
- Right to work – work permit, temporary residence and work permit, declaration, seasonal permit, or exemption from the permit requirement.
- Contract and conditions – written contract consistent with the document, appropriate remuneration, and registration with ZUS and offices.
Basic assessment scheme for employment legality
The table below shows a simple scheme I use for the initial assessment of the legality of employing a foreigner. You can treat it as a checklist for the HR department or a small business owner.
| Element | What do you ask about? | Typical documents |
|---|---|---|
| Stay | Is the stay legal and does it allow work? | National visa, Schengen visa PL, residence card, special act UA |
| Right to work | Does the foreigner have access to the labour market? | Work permit, residence and work permit, declaration, seasonal permit, UA notification, exemption from permit requirement |
| Contract | Does the contract reflect the conditions from the document? | Employment contract, mandate contract, B2B along with translation for the foreigner |
| Working conditions | Do remuneration and full-time equivalent meet statutory requirements? | Rate at least as in the document and not lower than the Polish minimum |
| Notifications | Have all notifications to offices been made? | ZUS, tax office, notifications to the labour office / voivode |
At Progress Holding, we conduct such an audit even before signing the first contract with a foreigner. Thanks to this, your company starts cooperation from a safe level, rather than correcting mistakes after the first inspection.
What documents entitle a foreigner to work in Poland in 2026?
In 2026, a foreigner can work in Poland based on several types of documents or an exemption from the obligation to have a permit. The specific document depends on citizenship, residence status, and the type of work performed.
Citizens of the EU, EEA, and Switzerland
Citizens of EU, EEA countries, and Switzerland can generally work in Poland without a work permit. However, they must ensure legal stay, and for longer stays, residence registration and a residence document.
Citizens of Ukraine – special act and notification of entrusting work
Citizens of Ukraine who are legally staying in Poland in connection with the war can work without a standard permit. The condition is the submission of an electronic notification of entrusting work by the employer within 7 days of its commencement.
New regulations extend the recognition of the stay of many Ukrainian citizens as legal until March 4, 2026. The employment model based on notification, submitted via the praca.gov.pl system without additional fees, has also been maintained.
Citizens of Armenia, Belarus, Georgia, Moldova, and Armenia – declaration
For citizens of five countries: Ukraine, Belarus, Georgia, Moldova, and Armenia, simplified access to the labour market is provided. You can entrust work based on a declaration on entrusting work to a foreigner entered into the register of declarations.
For several years, the declaration can cover a work period of up to 24 months, and work must start no later than 6 months from submitting the declaration. From 2025, additional obligations also apply, including sending a copy of the contract to the labour office before starting work.
Other third-country nationals – work and residence permits
Most citizens of countries outside the EU, EEA, and Switzerland need a document allowing access to the Polish labour market. Most often, this will be a work permit, a temporary residence and work permit, or a seasonal work permit.
| Document | For whom | Who issues it | Maximum period |
|---|---|---|---|
| Work permit (type A) | Work for a Polish employer in Poland | Voivode | Usually up to 3 years, depending on the contract |
| Temporary residence and work permit | Stay and work for a designated employer | Voivode | Up to 3 years |
| Seasonal work permit | Seasonal work in specific industries | Staroste | Up to 9 months in a calendar year |
| Declaration on entrusting work | Citizens of UA, BY, GE, MD, AM | Staroste / labour office | Up to 24 months |
| Exemption from permit obligation | Including graduates of Polish schools, Pole’s Card holders | Not applicable | Depending on stay and contract |
If you are unsure which document will be appropriate for a specific employee, you can commission us to analyze the situation. At Progress Holding, we prepare a short legal and tax note for clients, describing the optimal employment path for a given foreigner.
How to employ a foreigner step by step in 2026?
The procedure for employing a foreigner in 2026 is fully digital and multi-stage. You must plan the sequence of actions because the wrong order can invalidate documents or delay the start of work.
Step 1: Check citizenship and residence status
At the beginning, you check which country the candidate comes from and on what basis they are staying in Poland. This determines whether you need a permit, a declaration at all, or if a notification alone is sufficient, as with many Ukrainian citizens.
- For EU/EEA/Swiss citizens, legal stay is key, not a work permit.
- For Ukrainian citizens covered by the special act, you check if they fall within the extended protection period until March 4, 2026.
- For other foreigners, you choose the appropriate type of permit or declaration.
Step 2: Choose the right document allowing access to the labour market
The next step is choosing the path: declaration, notification, work permit, or residence and work permit. In 2026, all these procedures are conducted electronically via the praca.gov.pl portal or appropriate e-systems of offices.
- For simple jobs not requiring high qualifications, a declaration or seasonal permit is often sufficient.
- For specialists and management staff, a work permit or a single residence and work permit is typical.
- For longer cooperation, it pays to plan the path immediately: visa – permit – residence card.
Step 3: Prepare an offer and contract meeting statutory requirements
In the job offer and contract, you must ensure remuneration at least at the level of the Polish minimum. For many permits, the remuneration cannot be lower than the salary of employees in similar positions.
The contract must be concluded in writing, and the foreigner should receive a translation into a language they understand. From 2025, you have an additional obligation to send a copy of the contract to the office that issued the permit or registered the declaration, even before admitting the foreigner to work.
Step 4: Submit applications electronically and complete notifications
From June 1, 2025, applications for work permits and declarations are submitted exclusively electronically. You use a qualified signature, trusted profile, or e-ID for this.
- In the praca.gov.pl system, you set up an employer or proxy account.
- You attach the draft contract, foreigner’s data, information about the position and remuneration to the application.
- After starting work, you register the foreigner with ZUS within 7 days, and for Ukrainian citizens, you additionally submit a notification if required.
If you want to relieve your HR department, you can hand these steps over to Progress Holding. We prepare applications, handle correspondence with offices, and watch deadlines, and you get a clear status of the case in Polish or English.
How does employing EU citizens, Ukrainians, and other third-country nationals differ?
In 2026, the method of employing a foreigner depends heavily on their citizenship. Different rules apply to a citizen of France, different to a citizen of Ukraine, and still others to a citizen of e.g., India or the Philippines.
EU/EEA/Swiss citizens – simplified model
With EU/EEA/Swiss citizens, you focus on standard labour law and tax rules. You do not need a work permit, but for a stay longer than 3 months, the employee should complete residence formalities.
Ukrainian citizens – special rules until March 4, 2026
For Ukrainian citizens, a special regime related to the special act still applies. The legal stay of many people is extended by law, and access to the labour market takes place based on a simple notification submitted by the employer.
This path is much faster than standard work permits but requires meeting deadlines and accurately filling out the electronic form. At Progress Holding, we most often combine notification with a parallel path to obtain a residence permit to secure longer cooperation.
Other third-country nationals – standard and seasonal permits
For other foreigners, you most often need a work permit or a temporary residence and work permit. In seasonal sectors, such as agriculture or tourism, seasonal work permits are used for a period of up to 9 months a year.
What obligations does the employer have towards offices when employing a foreigner?
From 2025, your obligations as an employer towards institutions have significantly expanded. This concerns both the preparation of documents and what you do after the foreigner starts work.
Obligations before admitting a foreigner to work
Before the foreigner starts work, you must verify their residence document and right to work. From June 2025, you must also send a copy of the contract to the authority that issued the permit or registered the declaration.
- You check the visa, residence card, or other residence document and make a copy for the files.
- You verify if the document allowing access to the labour market covers your company, position, place of work, and full-time equivalent.
- Before work starts, you send a scan of the contract via praca.gov.pl to the appropriate labour office or voivode.
Obligations after starting work
After starting work, you have the obligation to register the foreigner with ZUS and, in many cases, inform the office about taking up work. regarding the notification of a Ukrainian citizen, the deadline is 7 days, counted from the day work is entrusted.
- You register the foreigner for insurance within 7 days from the day work starts.
- You inform the labour office or voivode about taking up, ending, or not taking up work, in accordance with the decision or declaration entry.
- You keep documents regarding the foreigner’s employment to be able to show them to PIP (National Labour Inspectorate), Border Guard, or tax office.
In practice, these obligations are a heavy administrative burden for many small companies. That is why at Progress Holding, we increasingly take over the role of an external HR department that watches notification deadlines and prepares appropriate corrections.
What are the penalties for illegal employment of a foreigner in Poland?
From June 1, 2025, penalties for illegal employment of foreigners are significantly higher. An employer who illegally entrusts work to a foreigner must expect a fine from 3,000 to 50,000 PLN for each case.
How to understand “illegal entrustment of work”?
Illegal entrustment of work is not just the lack of a work permit. It is also employing a foreigner who does not have legal stay or entrusting work on conditions other than those indicated in the permit, declaration, or notification.
The new act on the conditions of admissibility of entrusting work to foreigners and amended penal regulations provide for high penalties for such violations. The minimum fine is 3,000 PLN for one foreigner, and the maximum can reach 50,000 PLN.
Consequences for the foreigner
A foreigner who illegally performs work also bears responsibility. Regulations provide for a fine of at least 1,000 PLN, and in extreme cases, problems with extending the stay.
Therefore, during inspections by PIP or the Border Guard, both parties should be able to show a complete set of documents. At Progress Holding, we prepare “inspection folders” for clients with organized copies of documents in case of an inspection visit.
How does it look in practice? Progress Holding experience
In working with Progress Holding clients, I see that employing foreigners in Poland is often the first serious contact with Polish migration law. A well-planned process gives the company certainty and stability, while a poorly planned one generates stress and costs already at the first inspection.
Most common models of cooperation with foreigners
In practice, I encounter three most common models of cooperation with foreigners. Each of them requires a different arrangement of documents, but the logic is similar.
- “Fast start” model – declaration or UA notification, and parallel residence and work card path.
- “IT specialist” model – temporary residence and work permit with remuneration clearly above the minimum and a stable contract.
- “Seasonal” model – seasonal work permit, often with the option of multi-seasonal entry for the same employees.
Most common mistakes I see in employer documents
- Contract concluded on conditions other than in the declaration or permit (different rate, different place of work).
- Failure to send a copy of the contract to the office after changes from 2025.
- Incorrect residence title – e.g., work on a tourist visa or visa of another Schengen state.
- Exceeding the scope of work entered in the document without changing the decision or a new application.
How specifically does Progress Holding help?
At Progress Holding, we can plan the entire employment path of a specific foreigner with you. This includes selecting the document, preparing applications and contracts, as well as ongoing HR, payroll, and tax services for your company.
For foreign clients and Polish entrepreneurs employing foreigners, we provide service in Polish and English. If you plan a larger international team, we can also help with company registration, obtaining PESEL or NIP numbers for key people, and organizing the settlement structure.
Frequently asked questions about employing foreigners in Poland in 2026?
Below you will find answers to questions I most often hear from clients planning to employ foreigners. You can use this section as a quick cheat sheet for yourself or your HR department.
Do I always need a work permit for a foreigner?
Not always. EU/EEA/Swiss citizens, some graduates of Polish universities, people with the Pole’s Card, or many Ukrainian citizens can work without a permit. However, you must always check if the specific foreigner falls within the catalog of exemptions and if their stay is legal.
Can I employ a foreigner on a mandate contract or B2B?
Yes, the law allows employing a foreigner on a mandate contract or B2B cooperation, provided the document allowing access to the labour market covers this. However, you must remember the minimum hourly rate and not to replace an employment contract with a civil law contract when an employment relationship actually exists.
Can a foreigner start work while waiting for a permit decision?
In some cases yes, e.g., with seasonal work or extending a valid permit. However, detailed conditions from the act and implementing regulations must be met, including submitting an application without defects and working on existing work right conditions.
Can I employ a foreigner who has a visa from another Schengen state?
From 2025, foreigners with visas from other Schengen states generally cannot legally work in Poland on this basis. In such a situation, you need to plan obtaining the appropriate visa or residence card related to work in Poland.
How quickly will the office issue a work permit or residence and work permit?
The duration of the proceedings depends on the voivodeship and the workload of the office. In practice, standard cases take from several weeks to several months, so it is worth starting the procedure in advance and preparing a complete set of documents immediately.
Can Progress Holding handle correspondence with ZUS and labour offices for me?
Yes. As part of HR and payroll services and consulting for foreigners, we can become your proxy. This includes submitting applications, receiving correspondence, and explaining official letters so that you can focus on running your business.
If you plan to employ a foreigner or an entire international team in Poland in 2026, a well-prepared procedure will save you stress, time, and money. Proper selection of documents, contracts, and notifications secures your company against high penalties and allows you to develop your business peacefully. Do you need professional support? Contact us at Progress Holding at +48 603 232 418 or via email office@progressholding.pl.
