The draft bill on phasing out aid to Ukrainians could become one of the most landmark legislative issues of early 2026. On December 29, 2025, a government draft bill (UD345) was published on the website of the Government Legislation Center; its purpose is to phase out selected provisions resulting from the special act on aid to Ukrainian citizens.
Although the changes are presented as a streamlining of regulations and a “wrap-up” of temporary measures, business representatives point out that this could significantly affect the legality and smooth operation of foreign workers’ employment. Importantly, the Lewiatan Confederation also draws attention to the legislative process itself—highlighting the lack of public consultation on regulations that affect businesses and thousands of workers in Poland.
Bill UD345 Without Public Consultation—Why Is This Important?
According to the Lewiatan Confederation, the failure to conduct public consultations violates the principles of social dialogue and best practices in lawmaking. At the same time, the changes proposed in the draft concern fundamental issues, such as the simplified legalization of employment for Ukrainian citizens and administrative procedures related to the residence of foreign nationals.
In practice, this means that companies may find themselves in a situation where they have to adapt their HR processes “on the fly,” while at the same time facing a higher risk of procedural errors.
1) Restrictions on the notification procedure—a real risk of chaos in companies
One of the key changes is the restriction of the ability to assign work based on a notification solely to individuals covered by temporary protection.
According to the Lewiatan Confederation, this solution:
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will lead to organizational chaos on the employers' side,
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will require verification of the employee's immigration status on a case-by-case basis,
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will increase the risk of errors in the legalization of employment.
Why is this important for the labor market?
In recent years, the notification procedure has been one of the fastest and most practical tools for legalizing the employment of Ukrainian citizens—especially in industries where labor shortages are a constant problem (logistics, manufacturing, warehousing, and services). Therefore, restricting it could mean:
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lengthening of the hiring process,
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greater pressure on HR departments,
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an increase in the costs of legalization and administrative services.
And importantly—in light of the 2025 immigration reforms—standard procedures are already taking much longer than employers would expect in many cases.
2) Suspension of deadlines in cases involving foreign nationals until March 4, 2027.
The bill calls for extending the suspension of deadlines in cases involving foreign nationals until March 4, 2027. This means that this measure would be in effect for the fifth consecutive year.
Leviathan emphasizes that:
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this does not improve the administration's operations,
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paralyzes proceedings,
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deprives foreign nationals of effective legal protection,
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increases the risk of companies illegally outsourcing work.
Consequences for Companies and Employees
From the perspective of the labor market, the problem is not only the length of the proceedings, but also the uncertainty. If residence permit proceedings take more than a year on average, every company that employs foreign nationals must constantly operate “on the edge” of administrative deadlines while ensuring compliance with the law. As a result, the risk increases:
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gaps in the documentation,
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unintentional violation of the regulations,
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inspection authorities (PIP, Border Guard, ZUS).
The Lewiatan Confederation’s Position—What Does the Business Community Propose?
The Lewiatan Confederation calls for:
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a decision to discontinue the suspension of administrative proceedings,
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maintaining the possibility of hiring Ukrainian citizens under the notification procedure, regardless of the basis for their stay,
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If the restrictions remain in place, they should be postponed until at least March 2027, and clear transitional provisions should be introduced.
From a business perspective, this is a rational approach—because the market needs not only new regulations, but above all predictability and time to implement the changes.
How might the bill to phase out aid to Ukrainians affect the labor market?
From NJOB’s perspective, the key point is that Ukrainian workers have been an important part of the Polish labor market for years—especially in sectors facing labor shortages. Therefore, any change regarding the simplified employment authorization process will have an immediate effect.
Possible implications for the industry:
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greater emphasis on verifying residency status,
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more procedural errors on the part of companies, resulting from ambiguities in the regulations,
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lengthening of the hiring process,
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greater pressure on HR departments,
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the growing importance of specialized support in the legalization process (not just “on paper,” but in terms of the actual process).
What should employers do right now?
Although we’re talking about a project, it’s a good idea to prepare in advance—especially if hiring foreign nationals is a significant part of the operation.
We recommend:
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audit of the employment of Ukrainian citizens and the grounds for their stay,
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organizing documentation related to the legality of employment,
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developing scenarios to streamline the notification procedure,
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implementation of a system for monitoring the duration and status of stays,
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ongoing monitoring of changes to UD345 (including transitional provisions).
The draft bill on phasing out aid for Ukrainians may introduce changes that, for many companies, will mean not only new obligations but, above all, an increase in organizational and procedural risks. If the notification procedure is limited exclusively to beneficiaries of temporary protection, and the suspension of deadlines is extended until 2027, employers will have to act even more cautiously and in a more process-oriented manner.
At the same time, the business community is making it clear that in an area as sensitive as the legalization of foreign workers, the following are essential: consultations, clear transitional rules, and a predictable implementation schedule.