More than 1.15 million foreign nationals working in Poland and an administrative system that has been grappling with lengthy proceedings for years. The scale of foreign worker employment is growing, but the procedures for legalizing the residence and employment of foreigners remain one of the biggest challenges for employers. The Polish HR Forum, with the support of the largest employer organizations, has presented five specific proposals for change. Is this the beginning of a real overhaul of the system?
The issue of legalizing the residence and employment of foreign nationals in Poland is not a new one. Prolonged proceedings, complicated procedures, difficulties in verifying residence status, and the fragmentation of responsibility among various institutions have for years affected the operations of companies that employ foreign nationals.
Today, however, the scale of this challenge is much greater.
According to data from the Central Statistical Office , as of the end of March 2026 , 1.153 million foreign nationals were employed in Poland , an increase of 8% from the previous year. Ukrainian citizens accounted for approximately 68% of this group—nearly 784,000 people. Other well-represented nationalities included citizens of Belarus, India, Georgia, and Colombia.
These are the workers who support the functioning of Polish industry, logistics, manufacturing, trade, and many other sectors of the economy.
However, the growing number of foreign workers also means increasing demands on the administrative bodies responsible for handling their cases.
And this is where the fundamental question arises: Is the system for legalizing residence and employment in Poland prepared to meet the actual scale of the market’s needs?
The legalization of foreign nationals is no longer merely an administrative issue
For an entrepreneur, waiting for a residence permit decision is not merely a formality that can be separated from the day-to-day operations of the business.
This is a factor that affects workforce planning, team stability, shift scheduling, and the fulfillment of obligations to business partners.
Protracted proceedings can hinder personnel decisions, limit employee mobility, and increase the workload on HR departments, which must continuously monitor the status of documents and the deadlines for proceedings.
In some cases, the wait for a decision on a residency application can be as long as a year.
It is worth keeping in mind that legal residence and legal employment are two separate issues. Simply waiting for a residence decision does not automatically grant the right to work, just as holding a document authorizing employment does not always determine the legality of one’s residence.
For companies, this means they must monitor several aspects of an employee’s legal status simultaneously.
The problem, therefore, is not only the length of the procedures, but also the lack of sufficient predictability and easy access to reliable information.
It is precisely these challenges that the position presented by the Polish HR Forum addresses.
The Polish HR Forum is proposing a reform. Employers speak with one voice
The Polish HR Forum presented a comprehensive position on the direction of changes to the system for legalizing the residence and employment of foreign nationals in Poland.
The organizations' proposals received support from the Lewiatan Confederation, the American Chamber of Commerce in Poland (AmCham), the Business Centre Club, the Federation of Polish Entrepreneurs, and the Polish Chamber of Commerce.
This is an important signal.
Issues related to the legalization of foreign nationals’ residence and employment no longer concern only employment agencies or companies specializing in international recruitment.
Manufacturing companies, logistics operators, commercial enterprises, and employers—for whom foreign workers are a permanent part of their workforce—are also feeling the impact.
The proposals presented focus on five areas: decentralization of procedures, digital verification of a foreign national’s status, incentives for responsible employers, simplification of paperwork, and the creation of a controlled path to legal residency.
Each of them addresses a different problem with the current system.
1. Transfer of some responsibilities to county employment offices. Will decentralization speed up procedures?
The first proposal concerns a change in the structure of the administrative body responsible for the legalization of foreign nationals.
The Polish HR Forum proposes transferring some responsibilities to county employment offices, which would relieve the burden on provincial offices and enable more efficient handling of cases at the local level.
Currently, it is the provincial offices that play a key role in procedures related to the issuance of residence permits.
The large number of cases being handled, the complexity of procedures, and limited organizational capacity contribute to administrative backlogs.
Decentralization could mean a more even distribution of responsibilities among institutions.
However, this is not a solution that will automatically reduce wait times.
For the reform to yield the expected results, it would be necessary to ensure adequate staffing, expertise, IT tools, and uniform standards of conduct.
Simply transferring cases from one institution to another will not solve the problem unless it is accompanied by appropriate organizational changes.
For employers, the most important factor would be the result: shorter and more predictable proceedings, regardless of where they conduct their business.
2. Electronic Profile of a Foreign National’s Legality of Stay and Employment. An End to Uncertainty in Document Verification?
One of the most important proposals is to create a government tool that would enable binding verification of a foreign national’s residency status.
The Electronic Profile of a Foreign National’s Legality of Residence and Employment would provide employers with access to reliable information necessary for making hiring decisions.
Why is this so important?
An employer who hires a foreign national must ensure that the conditions for legal employment are met.
In practice, this requires an analysis of residence documents, the basis for the right to work, the validity periods of the documents, and, in some cases, the status of any ongoing administrative proceedings.
It's not always easy.
Particularly in the case of foreign nationals whose legal status has changed over time, an employer may have difficulty determining their current residence status.
The proposed profile would reduce this uncertainty.
Greater government responsibility for data, but not for all employment
A key element of the proposal is the proposed division of responsibility.
The relevant administrative authorities would be responsible for ensuring the accuracy of the information made available in the national system.
The employer, however, would still be responsible for properly carrying out the work authorization procedure and complying with the terms and conditions of employment.
That's an important distinction.
The point is not to exempt businesses from their obligations, but to provide them with a tool whose data they can safely rely on to guide their actions.
From the perspective of companies that employ a larger number of foreign nationals, this could reduce the risk of errors, streamline HR processes, and increase legal certainty.
3. Trusted Employer Status. Should reliability make it easier to hire foreign workers?
Another proposal is to introduce the status of “Trusted Employer.”
According to the proposal of the Polish HR Forum, it should be available to any business owner who meets objective legal compliance criteria, regardless of the size of the company.
This is particularly important from the perspective of small and medium-sized enterprises.
A system that rewards only the largest employers could lead to unequal treatment of companies that comply with the law but do not employ hundreds of workers.
Therefore, the proposed solution is based on the assumption that the primary criterion should be the entrepreneur’s integrity, rather than the scale of the business.
In practice, the status of “Trusted Employer” could serve as the basis for establishing more predictable or simplified procedures for entities that demonstrate a high level of regulatory compliance.
However, the specific rules for granting this status, the scope of potential benefits, and the oversight mechanisms would need to be clarified.
Why is this proposal important for the labor market?
Companies that invest in proper hiring procedures, documentation, and regulatory compliance incur the associated organizational costs.
The opportunity to take advantage of certain administrative simplifications could serve as an additional incentive to maintain high standards.
At the same time, it would be necessary to establish transparent rules for evaluating businesses.
Trust should be based on verifiable compliance with the law, not on a discretionary decision or the size of the workforce.
4. Trusted digital signature when entering into contracts with foreign nationals. Less paperwork, more efficient document workflow
The fourth proposal concerns the possibility of using a trusted digital signature when entering into contracts with foreign nationals.
At first glance, this may seem like a minor change compared to the reform of residency procedures.
From the perspective of the day-to-day work of HR departments, however, it can be very important.
Companies that employ foreign nationals must handle a significant volume of documents, often with employees, candidates, and administrative teams spread out across different locations.
The possibility of making broader use of trusted digital signatures could simplify the process of entering into contracts and reduce the need for traditional document workflows.
However, for such a solution to be effective, the relevant regulations would need to be amended accordingly, and the legal consequences of signing documents in this form would need to be clearly defined.
The mere availability of a digital tool does not mean that it can replace every form of signature required by law.
Digitization should simplify procedures not only from a technical standpoint, but above all from a legal one.
5. Regularizing one’s stay without having to leave Poland. Is this a way to curb the gray market?
The final proposal concerns foreign nationals who have lost their legal residence status but are still residing in Poland.
The Polish HR Forum proposes the creation of a supervised regularization procedure that would allow such individuals to voluntarily disclose their situation and apply to have it regularized without having to leave the country first.
This does not mean automatically legalizing the status of all individuals in an irregular situation.
The proposal calls for individual review and the fulfillment of specific conditions.
Why might regularization be economically significant?
A foreign national who is outside the legal residency system may have limited opportunities for legal employment, and this situation increases the risk of exploitation and involvement in the informal economy.
A controlled procedure for returning to legal status could provide an opportunity to resolve some of these cases.
From the government's perspective, this would mean greater transparency regarding the status of foreign nationals residing in Poland.
From the perspective of the labor market—a potential reduction in informal employment and an increase in the number of people working within the legal framework.
At the same time, the effectiveness of such a mechanism would depend on a precise definition of the conditions for its application, safety controls, and the legal consequences for individual cases.
Regularization should not be confused with a general residence amnesty.
Digitization of the legalization process for foreign nationals. Why isn’t the electronic application system fully functional yet?
In recent years, digitization has become one of the main areas of focus in the modernization of administrative procedures.
The development of the MOS system—that is, the Case Management Module—is a key component of this process.
Electronic application submission can streamline the submission of documents, reduce some administrative tasks, and organize communication with government agencies.
However, this does not automatically mean that the time required to process cases will be reduced.
If the proceedings still require a multi-stage review and the institutions responsible for conducting them have limited resources, simply changing the method of submitting documents will not eliminate all delays.
The issue of access to information is similar.
The ability to submit an application electronically does not guarantee that the employer will receive a binding confirmation of the foreign national’s residence status.
Therefore, the proposal for an Electronic Profile of a Foreign National’s Legality of Stay and Employment represents a distinct and significant direction for change.
A modern legalization system should not only accept documents online, but also enable efficient case processing and provide reliable information to those involved in the process.
What Might the Reform of Foreign National Legalization Mean for Businesses?
From the employers' perspective, all five proposals share a common goal: to make the process of hiring foreign nationals more predictable.
This is particularly important for manufacturing, logistics, and service companies.
In many organizations, hiring foreign workers is no longer a stopgap measure used solely to address seasonal staffing shortages.
It is part of long-term human resources planning.
Therefore, companies need not only access to candidates, but also the ability to conduct the entire hiring process efficiently and in compliance with the law.
The proposed changes could affect several areas of operation:
- Workforce planning —thanks to potentially shorter and more predictable procedures.
- Legal certainty —through access to reliable data on the status of foreign nationals.
- Streamlining HR processes —by simplifying some of the paperwork and digitizing documents.
- Risk management —through a clearer division of responsibilities.
- Employment stability —achieved by creating solutions that help resolve certain residency situations.
However, this does not mean that all of these benefits will materialize automatically if the reform is adopted.
Their actual scope will depend on the specific regulations, the organization of the administration, and how the various mechanisms are implemented.
What should employers be doing right now?
The position of the Polish HR Forum is a proposal for systemic changes, not a new set of binding regulations.
Therefore, companies that employ foreign nationals should not put off their current obligations while waiting for the reform.
It remains essential to properly verify documents, monitor deadlines, ensure that employment terms comply with the required legal framework, and properly document the process of assigning work.
It is also advisable to regularly review the status of employees whose residence permits are subject to ongoing administrative proceedings.
Special attention should be given to cases involving a change of employer, position, terms of employment, or basis for residence.
Well-organized internal procedures remain one of the most important elements in mitigating legal risk.
This applies both to companies that employ foreign nationals directly and to companies that work with employment agencies and outsourcing service providers.
Even the best administrative reform cannot replace proper organization of the hiring process on the employer’s part.
Legalizing the residence and employment of foreign nationals requires predictability, not yet another stopgap measure
The fact that there are more than 1.15 million foreign workers is a clear indication of the important role that foreign labor plays in the Polish economy.
At the same time, the growing scale of this phenomenon requires an administrative system that is sufficiently efficient.
The proposals put forward by the Polish HR Forum show that the discussion on the legalization of foreign nationals need not be limited to yet another round of changes to forms, deadlines, or individual procedures.
The question of the system’s overall structure is becoming increasingly important: the division of responsibilities, access to information, the accountability of the government and employers, and the ability to respond quickly to changing market needs.
Decentralization, the Electronic Legality Profile, Trusted Employer status, the trusted signature, and the regularization procedure are proposals that could serve as a starting point for broader reform.
Not all of them will be equally easy to implement. Each one requires appropriate safeguards and precise legal solutions.
However, the direction of the proposed changes is clear.
A system for regularizing the status of foreign nationals should not only be effective in enforcing the law, but also efficient, transparent, and predictable for individuals and businesses that operate in accordance with the law.
For the Polish labor market, this is no longer merely a matter of streamlining administration.
This is one of the elements involved in creating a stable environment for companies that rely on an international workforce.
At the NJOB Group, we continuously analyze changes in regulations governing the employment of foreign nationals and their practical implications for employers. We assist companies in organizing their hiring processes, ensuring legal employment, and selecting appropriate models of cooperation.
Because as the scale of foreign employment grows, the predictability of procedures ceases to be merely a convenience. It becomes one of the conditions for the smooth functioning of the labor market.
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