The President of the Republic of Poland signed the Act of January 23, 2026, on the termination of measures resulting from the Act on Assistance to Ukrainian Citizens in Connection with the Armed Conflict on Ukrainian Territory.
The decision was made at the very last possible moment. Formally, this brings to a close the phase of special regulations that have served as the foundation for many processes in recent years—both in public administration and in the private sector.
For employers, this means one thing: the end of extraordinary simplifications and the need to return to the standard rules for legalizing residence and employment.
What does the expiration of the law mean in practice?
In recent years, the special law has made it possible, among other things, to:
- simplified delegation of work based on notification,
- extension of legal residence,
- a flexible approach to some administrative duties.
The expiration of the law means that:
✔️ Some of the simplifications are no longer in effect,
✔️ Full formal requirements are reinstated,
✔️ employers will bear greater responsibility.
What's more, this change is taking place at a time when the administrative system is still struggling with long processing times for applications.
Why is this moment important?
The moment the bill is signed—at the very last possible moment—is not merely a formality.
It shows that:
- the direction of migration policy is changing,
- Regulatory stability is becoming a key challenge for the labor market,
- Companies can no longer base their hiring strategies on extraordinary measures.
For HR and operations departments, on the other hand, this means they must adapt quickly.
What should employers consider?
In light of the expiration of the 2026 Act on Assistance to Ukrainian Citizens, organizations should urgently verify:
Basics of Employing Ukrainian Citizens
- Is the form of employment still in compliance with the new legal framework?
- Do the notifications or statements need to be updated?
Formal and Administrative Responsibilities
- Are all residence permits still valid?
- Are the renovation schedules planned correctly?
Legal and Operational Risks
- Is there a risk that the work could be deemed illegal?
- Is the employment model in compliance with current regulations?
Internal Procedures
- Is the process for tracking deadlines and documents sufficiently rigorous?
- Is responsibility for legalization clearly assigned?
In practice, many companies will have to conduct an audit of the legality of their employment practices.
The End of the Emergency Model – The Beginning of a New Phase
The coming weeks will show whether the expiration of the law marks the definitive end of the current model or the beginning of a new legislative approach.
However, one thing is certain:
Organizations should start preparing now to operate under the new legal framework.
Given the growing number of inspections and the tightening of administrative liability, a lack of preparation could mean:
- financial sanctions,
- operational issues,
- loss of employees.
From the perspective of the labor market, the expiration of the Act on Assistance to Ukrainian Citizens 2026 marks a transitional moment with significant systemic implications.
Companies that:
- will take action in advance,
- organize the documentation,
- will adapt their procedures,
will minimize risk and maintain operational stability.
Those that adopt a reactive approach may find themselves under time pressure—and under the new legal framework, the margin for error will be significantly smaller.
The signing of the law repealing special regulations for Ukrainian citizens formally brings the period of exceptional legal measures to an end. For employers, this means they must reevaluate their hiring and work authorization processes.
This is not the time to sit back and watch. It’s time to review procedures and manage risk. It’s also the best time to partner with a trusted provider who will shoulder the burden of legal restrictions, all regulations, and full responsibility for the process. Contact us.