🚨 On March 5, 2026, key changes to the regulations governing the employment of foreign nationals will take effect.
For many companies, this poses a real risk: a flood of inspections, heavy fines, and the loss of the ability to continue hiring foreign workers.
In the new reality a single procedural error can cost as much as 50,000 PLN — and that’s for just one foreign national.
Why is the risk rising so sharply?
The scale of the challenge facing employers is unprecedented.
In Poland:
- There are approximately 988,000–993,000 Ukrainian citizens under temporary protection,
- approx. About 670,000 of them are economically active,
- The average waiting time for a residence permit decision is about 300 days,
and in extreme cases can be as long as 500 days.
Under such circumstances, even minor procedural errors can result in the work being deemed illegal.
In practice, the problem is not a lack of goodwill on the part of employers, but rather:
- time pressure,
- ambiguous regulations,
- Failure to update documents when employment conditions change.
One mistake—serious consequences
For illegally employing a foreign national is punishable by:
- fines ranging from 3,000 to 50,000 PLN per person,
- Each violation is treated separately,
- two penalties within two years may mean:
- a ban on hiring foreign nationals,
- a real threat to the company's business continuity.
The most common mistakes are:
- starting work before obtaining the required permit,
- performing work that is inconsistent with the documents,
- continuing work after the decision has expired,
- Documents are not updated when the following changes are made:
- positions,
- salaries,
- number of full-time equivalents.
It's worth noting that even a delay of just a few days can result in the employer being held fully liable.
No More Simplifications and New Responsibilities
The changes to the regulations represent a significant tightening of the rules.
What will change starting in 2026?
✔️ Introduction A 3-year transition period for Ukrainian citizens residing in Poland under other residence statuses
✔️ a gradual transition to a system of work assignment declarations
✔️ repeal of Article 42a, which allowed for the issuance of temporary residence permits even if not all statutory requirements were met
In practice, this means:
- an end to exceptions and the “lenient approach” of government agencies,
- the need for full compliance of the documentation,
- greater responsibility on the part of the employer.
Foreign Delegations – Hidden Risks
Another area of risk is business trips.
Ukrainian citizens benefiting from temporary protection:
- They may not stay outside Poland for more than 30 days,
- Exceeding this limit may result in the loss of legal residence status.
Each delegation requires:
- individual analysis,
- to assess the impact on residence and employment status.
Conversely, the absence of such an analysis may result in the legality of the employment being called into question.
In-demand professions—an opportunity, but not for everyone
Another aspect of the changes is a draft regulation published January 30, 2026,, which introduces a list of 329 shortage occupations.
Foreigners employed in these occupations can expect:
- priority processing of applications,
- faster procedures (so-called "fast track").
However, it’s important to note:
➡️ The fast track is only available if the documents are fully compliant with the regulations.
Formal errors preclude the possibility of using the fast-track process.
The NJOB Perspective – Legalization as Risk Management
From the NJOB's perspective, starting in 2026:
- Work authorization is no longer just a formality,
- becomes part of operational risk management.
Companies that:
- do not update their procedures,
- will not review the documents,
- if they don't prepare for the inspections,
They must expect to suffer real financial and personnel losses.
If you find yourself thinking:
“Maybe there’s something wrong here, too?”
that’s the best time to check it out—before the inspectors do.
Changes to the employment of foreign nationals effective March 5, 2026, mean:
- more oversight,
- higher penalties,
- a smaller margin of error.
For employers, now is the last chance to streamline procedures and minimize the risk of costly mistakes—and to partner with a trusted provider like the NJOB Group. Contact us.
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Source: here.