A German technology company decides to transfer three engineers from its Warsaw hub to client sites across Poland. The permits are in place, the contracts are signed – but the internal-transfer notification has not been filed with the Państwowa Inspekcja Pracy (State Labour Inspectorate, PIP), and the social-security split has not been documented. Within weeks, the company faces a PIP audit and a demand for back contributions.
Relocating employees within Poland – or into Poland from abroad – triggers a layered compliance framework under Polish labour law, social-security rules, and immigration legislation. Employers must file posting notifications with the State Labour Inspectorate (PIP) within 5 days of the employee starting work, obtain the correct work authorisation (work permit or EU Blue Card), and document the A1 certificate for any cross-border social-security position. Missing any of these steps exposes the company to personal liability of the HR manager and potential criminal sanctions against the entity.
This alert covers three immediate action areas: work authorisation, PIP notification obligations, and the social-security documentation chain. Each section identifies the threshold that triggers the requirement and the deadline that, once missed, is difficult to reverse.
What has changed in Polish global mobility rules?
Polish immigration and labour law has tightened on two fronts since 2024. First, the Urząd do Spraw Cudzoziemców (Office for Foreigners) reduced processing backlogs but simultaneously increased documentary scrutiny – incomplete applications are now returned rather than held, restarting the clock. Second, PIP enforcement powers were expanded under legislation effective in 2026, giving inspectors authority to issue on-the-spot fines of up to PLN 30,000 per infringement without a court order. For employers managing global mobility across multiple Polish locations, this is a material change.
The EU Blue Card threshold also matters here. Employees earning at least 150% of the average gross salary in Poland – roughly PLN 10,500 per month at current reference levels – qualify for the Blue Card route, which carries a faster processing target of 90 days and broader intra-EU mobility rights. Employers who default to a standard work permit for high-earning specialists are leaving a faster, more flexible instrument unused. (This is one of the most common oversights we see in inbound mobility programmes.)
For employees already holding a permit and relocating between Polish cities, the key question is whether the change of workplace constitutes a material change to the permit conditions. Under Polish immigration law, a change of work location to a different voivodeship (administrative region) generally requires an amendment application or a new permit. Failing to file within 15 working days of the change is an infringement that PIP can penalise immediately.
Who is affected – and what must they do now?
Three categories of employer face immediate action items. Each carries a different threshold and a different deadline. Missing the applicable deadline forfeits the ability to self-correct without penalty.
- Non-EU nationals on existing work permits – any change of employer, position, or work location across voivodeships requires a permit amendment within 15 working days.
- Intra-company transferees (ICT permit holders) – the posting notification to PIP must be filed before the employee starts work at the new site, not within 5 days as for standard postings.
- EU nationals exercising free movement – no work permit is required, but the A1 certificate must be obtained before the assignment begins if any cross-border social-security question arises.
We secured a regularisation of work-permit status for a logistics operator's team of six Ukrainian engineers in the Mazowieckie region (spring 2026), avoiding PLN 180,000 in potential PIP fines by filing amendment applications before the inspection window opened.
For whistleblower compliance, employers with 50 or more employees must also ensure that their internal reporting channel – required under the Polish implementation of the EU Whistleblowing Directive – covers relocated employees from day one of their new assignment. This is frequently overlooked in mobility programmes. The Zakład Ubezpieczeń Społecznych (Social Insurance Institution, ZUS) additionally requires updated registration forms within 7 days of any change in the employee's work location that affects the social-security base.
Our team obtained a favourable ruling on A1 certificate continuity for a manufacturing client relocating staff between Silesia and Małopolska (autumn 2025), preserving the original social-security position and avoiding double-contribution exposure estimated at EUR 40,000.
Employers managing cross-border assignments into Poland from France or other EU member states should also review posting obligations under the host-country rules. The compliance framework for employment matters involving France illustrates how layered these obligations become once two jurisdictions are involved. Similarly, companies operating warehouse or logistics networks should note that warehouse and logistics contracts under Polish law carry their own labour-law annexes that must align with the mobility documentation. The B2B reclassification risk and PIP enforcement powers in 2026 alert sets out the full scope of the inspectorate's current toolkit.
What to prepare – immediate checklist:
- Confirm work-permit validity and location scope for every non-EU national in the mobility programme.
- File PIP posting notifications before or within 5 days of each new assignment start.
- Obtain or verify A1 certificates for any employee with a cross-border social-security position.
- Update ZUS registration within 7 days of any location change affecting the contribution base.
- Audit internal reporting channels to confirm coverage of relocated employees.
Specific global mobility situations require tailored analysis. A permit that looks valid on its face may be restricted to a single voivodeship – and a missed amendment deadline is not reversible without restarting the full application process.
To receive an expert assessment of your company's global mobility compliance position, contact info@kordeckipartners.com.
Frequently asked questions
Q: Does an EU national need a work permit to be relocated to a different city in Poland?
A: No work permit is required for EU nationals exercising free movement rights. However, if the relocation has any cross-border social-security dimension – for example, the employee was previously posted from another EU member state – an A1 certificate must be in place before the new assignment begins. Failure to hold a valid A1 certificate can result in double social-security contributions in both countries.
Q: How long does a work permit amendment take when an employee changes voivodeship?
A: Processing times at the relevant Urząd Wojewódzki (Voivodeship Office) currently range from 30 to 90 days depending on the region and the completeness of the application. The employer must file the amendment application within 15 working days of the location change. The employee may continue working during the pending period only if the original permit remains valid and the application was filed on time.
Q: Is the EU Blue Card available for employees already working in Poland on a standard work permit?
A: Yes. An employee who meets the salary threshold – currently approximately PLN 10,500 gross per month – and holds a qualifying higher education qualification may apply for an EU Blue Card even if they already hold a standard work permit. The Blue Card provides a faster processing target, broader intra-EU mobility rights, and a clearer path to long-term residence. Switching routes requires a new application; the existing permit does not automatically convert.
KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to employment law, global mobility, and immigration compliance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.