From 1st June 2025, Poland implemented immigration changes aimed at tightening compliance, modernising the work permit system, and aligning immigration controls with labour market needs. The new law was signed by the President in April and formally published in May.

While some changes will simplify application processes, the legislation introduces significant new obligations for employers hiring foreign nationals.

Labour market test removed

From 1st June 2025, employers have no longer been required to conduct a labour market test before applying for a work permit. This removed the need to advertise vacancies and demonstrate the absence of suitable Polish candidates.

Instead, employers are now restricted from hiring foreign nationals into roles listed under a forthcoming “protected professions” list. Work permits will not be issued for these roles, except in limited circumstances (for example, Turkish nationals who have been legally employed in Poland for at least four years).

Employment contracts must be submitted before work begins

Employers are now required to submit signed employment contracts before a foreign worker begins employment under a work permit or special permission work permit.

For seasonal workers, this contract must be submitted within seven days of starting work. This replaced more flexible arrangements previously in place and introduced potential penalties for non-compliance, including work permit revocation or fines.

Notification requirements for employers

Employers and foreign workers must now notify authorities of a broader set of changes, including updates to place of residence, working hours, or employment termination. These changes were not previously subject to mandatory reporting. Failure to comply with these new obligations may result in administrative sanctions or fines.

New data retention obligations

Employers must now retain the employment and personal data of foreign workers for at least two years after the end of employment. This introduced a formal recordkeeping requirement that was previously absent and may necessitate updates to internal compliance processes.

Fast-track processing for employers

Certain employers now benefit from accelerated work permit processing. This applies to:

• Employers deemed important to the Polish economy
• Repeat applications for the same foreign employee
• Applications for roles in recognised shortage occupations

This route is designed to reduce wait times for strategic sectors and trusted employers.

Restrictions on work under certain visas

Since 1st June 2025, foreign nationals in Poland under the following visa types are no longer permitted to work:

• Family visit visas
• Non-degree study visas
• Medical treatment visas
• Visa-free entry
  
  

Digitalised work permit system

All work permit applications must now be submitted through a new online platform. This is intended to streamline the process and improve transparency for both applicants and authorities.

New employers operating in Poland for less than one year are limited to one-year work permits for their foreign staff.

Refusal grounds and increased enforcement

Authorities now have wider discretion to refuse work permits based on:

• Unpaid social security contributions
• Applications deemed to have no genuine employment purpose
  
  

Enforcement has also been stepped up, with unannounced joint inspections by the National Labour Inspectorate and Border Guard.

Employers found to be non-compliant may face fines ranging from PLN 3,000 to PLN 50,000. Foreign nationals working without authorisation may be fined between PLN 1,000 and PLN 5,000.

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Should you have any queries regarding the above information or if you require assistance with your corporate, employment or immigration matter, please get in touch with a legal professional at Hudson McKenzie via email at londoninfo@hudsonmckenzie.com or by telephone +44(0) 20 3318 5794.

The information provided does not amount to legal advice.

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