Declarations regarding the employment of foreign nationals in 2025 are undergoing another significant change. Pursuant to the regulation of the Minister of Family, Labor, and Social Policy dated November 21, 2025, as of December 1, 2025, Georgian citizens will be removed from the list of countries whose nationals are eligible to work under a declaration.
This decision has been in the works for months, but its publication in the Journal of Laws settles the matter—Polish employers must update their recruitment processes and workforce planning.
At the same time, a second, related regulation dated November 20, 2025, was published, which expands the list of situations in which a foreign national may work without a permit and without a declaration.
In this article, we explain what these two changes mean for the labor market, employers, and agencies—and how to prepare your company for the new rules.
Georgia is dropping out of the declaration system—as of December 1, 2025, only four countries will remain
The declaration system is the fastest way to legalize employment for foreign nationals—which is particularly important for industries with high turnover and seasonality. Until now, it has covered citizens of six countries, but as of December 1, the list will be reduced to four.
The statements are available only to citizens:
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Armenia
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Belarusians
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Moldova
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Ukraine
Georgian citizens who have so far been able to work under a simplified procedure will have to go through the standard legalization process—that is, obtain a Type A work permit and, in the case of certain industries, also a residence and work permit.
This change was introduced by the regulation of November 21, 2025, and directly modifies the previous rules regarding the employment of foreign nationals.
Why Was Georgia Removed? Regulatory Context
Over the past two years, the administration has pointed to growing problems:
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a high level of fraud involving statements issued to Georgian citizens,
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failure to actually begin work after the declaration was filed,
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cases in which the procedure is used as a “backdoor for immigration.”
As a result, the government decided to tighten up the system—just as it had done previously in the case of Russia.
From the NJOB’s perspective, this decision is part of a trend toward tighter labor market controls and confirms that the administration is focusing on the reality of employment rather than the mass production of documents.
The second key regulation—when can a foreign national work without a permit?
The new regulation of November 20, 2025, specifies the circumstances under which foreign nationals may work legally without a permit or declaration.
This applies, among other things, to:
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certain professions and activities of a public or social nature,
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educational and research activities,
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selected forms of artistic activity,
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jobs of particular economic or social importance (e.g., work in the field of humanitarian aid, specific publicly funded projects).
The regulation also expands the list of exceptions, bringing it in line with labor market realities and the needs of the administration.
This is good news for companies operating in sectors where foreign nationals perform short-term, project-based, or highly specialized tasks.
What do these changes mean for employers?
Higher risk of staff turnover
Companies that employ Georgian citizens must switch to a permit process—one that is significantly more time-consuming and demanding.
Priority for Ukraine, Belarus, Moldova, and Armenia
The labor market will continue to “tighten” for workers from these four countries, which may increase competition for candidates.
The Need for Thorough Investigation of Cases of Unauthorized Work
The new exceptions offer more possibilities, but using them incorrectly still carries the risk of inspections and penalties.
Process outsourcing is even more important than ever
The system’s security ensures that makeshift employment models are eliminated.
What matters is the legality, quality, and transparency of processes—the foundation of NJOB’s process outsourcing.
What do we recommend to companies?
✔ Immediate audit of Georgian citizens’ employment —will their documents remain valid after December 1?
✔ Review of recruitment plans for 2025/2026—particularly in the manufacturing and warehousing sectors.
✔ Adapting processes to the November 20 regulation —the possibility of working without a permit may ease the burden on some teams.
✔ Avoiding fictitious arrangements —inspections by the National Labor Inspectorate (PIP) and the Regional Labor Inspectorate (DUW) will be even more rigorous.
✔ Collaborating with partners that use legal process outsourcing —we eliminate the risks associated with outsourcing work to unauthorized entities.
The changes resulting from the two new regulations signal that the system for legalizing employment in Poland is becoming more selective, more closely monitored, and more based on actual verification.
Declarations are limited to four countries.
Foreign nationals from Georgia are subject to the full permit procedure.
An expanded list of exceptions will allow some specialists to work without a permit.
Companies must respond immediately—especially those that employ unskilled workers.
At NJOB, we monitor changes as they happen and help companies navigate the new regulations safely—so that legal employment is not just an obligation, but a tangible support for their operations. Contact us.