A Kyiv-based technology company decides to transfer five engineers to its Warsaw subsidiary. The HR team assumes the process mirrors a standard EU posting. Within weeks, they discover that Ukrainian nationals require work authorisation, that temporary protection status changes the permit pathway, and that payroll registration deadlines are measured in days – not months.

Relocating Ukrainian employees to Poland involves three parallel tracks: immigration status under temporary protection or a standard work permit, employment contract adaptation under Polish labour law, and social insurance registration with the Social Insurance Institution (Zakład Ubezpieczeń Społecznych, ZUS). Each track carries its own deadline. Missing any one of them triggers personal liability for the employer and may preclude the employee from lawful residence. The employer must act before the employee crosses the border – not after.

This alert covers what changed in 2025, who is affected, and the immediate steps your organisation must take. It addresses temporary protection holders, employees seeking EU Blue Card status, and Ukrainian nationals arriving outside the special-protection framework. Compliance failures are not administrative footnotes – they expose directors to personal liability and forfeits the employee's right to continued stay.

What changed in 2025 and who is affected?

Poland extended temporary protection for Ukrainian nationals through at least mid-2026. That extension matters because it determines which permit pathway applies. Employees who arrived in Poland after 24 February 2022 and registered under the special act (ustawa o pomocy obywatelom Ukrainy, the Ukraine Aid Act) may work without a separate work permit – but only if the employer notifies the District Labour Office (Powiatowy Urząd Pracy, PUP) within 14 days of commencing employment. That 14-day window is a hard deadline. Missing it removes the notification exemption entirely.

For employees who do not qualify under temporary protection – or whose status has lapsed – the standard permit regime applies. A Type A work permit requires the employer to obtain a labour market test from the Voivodeship Labour Office (Wojewódzki Urząd Pracy, WUP), unless the role falls within a shortage-occupation list. Processing times currently run 30 to 60 days. Starting work before the permit is issued is an administrative offence carrying a fine of up to PLN 30,000.

The EU Blue Card is available for high-skilled roles where the gross monthly salary exceeds the threshold set annually by the minister responsible for labour (currently approximately PLN 9,000 per month). Blue Card holders gain more favourable family reunification rights and a shorter path to long-term EU residence. The application is filed with the Voivode (Wojewoda) – the regional state administration authority – and takes 60 to 90 days on average.

  • Temporary protection holders: notify PUP within 14 days of employment start
  • Standard permit applicants: begin WUP labour market test at least 60 days before planned start date
  • EU Blue Card candidates: file with the Voivode at least 90 days before planned start date
  • All employees: register with ZUS within 7 days of employment commencement

We secured regularisation of employment status for a group of six Ukrainian IT specialists for a Warsaw-based software house (spring 2025, Mazowieckie region) – avoiding fines that would have exceeded PLN 150,000 had the notifications remained outstanding.

What are the compliance obligations for Polish employers?

The employer's obligations do not end at immigration. Polish labour law – the Kodeks pracy (Labour Code, KC) – requires that every employment contract be issued in writing before the employee starts work. For Ukrainian nationals, the contract must specify the type of permit or legal basis for work. Omitting that reference creates an ambiguity that the National Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) treats as a documentation failure during audits.

Salary levels matter too. The minimum wage in Poland from January 2025 is PLN 4,666 gross per month. Any employment contract offering less – regardless of what the Ukrainian entity pays – violates Polish law. For Blue Card holders, the salary floor is higher still. Employers who structure compensation partly through the Ukrainian parent company to reduce Polish payroll costs face reclassification risk. ZUS inspectors have increased scrutiny of split-payroll arrangements in 2025.

Remote work adds another layer. If the relocated employee works partly from home in Poland, the employer must comply with the remote work framework under Polish labour law – including a written remote work agreement and health-and-safety obligations at the home workstation. For a detailed breakdown of those requirements, see our analysis of the remote work framework under Polish labour law.

Whistleblower protection is also relevant. Poland implemented the EU Whistleblowing Directive in 2024. Employers with 50 or more employees – including those who have recently expanded headcount through Ukrainian relocations – must maintain an internal reporting channel. Failure to do so carries fines of up to PLN 50,000. The threshold is counted against the Polish entity's total headcount, not just permanent staff.

Our team obtained a successful outcome in a PIP audit for a logistics operator in Lower Silesia (autumn 2025), where documentation gaps for 11 Ukrainian employees were remediated before formal proceedings were initiated – protecting the employer from fines that could have reached PLN 330,000.

What immediate actions must employers take?

Speed determines outcome here. The compliance window for most permit and notification obligations is measured in days, not weeks. An employer who waits until the employee has already started work has already missed the most important deadline. The action list below applies to any organisation relocating Ukrainian nationals to Poland in 2026.

First, audit current headcount. Identify every Ukrainian national on the Polish payroll and confirm their legal basis for work. Temporary protection status must be verified against the PESEL register – the national identification number system administered by the Ministry of Interior. A status that lapsed without renewal means the employee is working without authorisation. That is an irreversible compliance failure if discovered during a PIP inspection.

For employees whose compliance programme design involves a Polish subsidiary, the structural questions – entity type, liability ring-fencing, and internal governance – are addressed in our guide on compliance programme design for Ukraine subsidiaries in Poland. For employers managing posted workers alongside relocated staff, the A1 certificate requirements differ materially – see our note on posted workers and A1 certificates for the procedural comparison.

  • Verify PESEL registration and temporary protection status for each Ukrainian employee
  • Confirm PUP notification was filed within 14 days of employment start
  • Review employment contracts for written form, salary floor, and permit reference
  • Register all employees with ZUS and confirm contribution base is correct
  • Assess whether internal whistleblower channel is required given current headcount

The complexity of managing global mobility across three regulatory tracks – immigration, labour, and social insurance – means that a single missed step can trigger cascading consequences. Personal liability for directors, fines up to PLN 30,000 per employee, and the employee's loss of lawful residence are all live risks. Acting within the correct windows is the only way to keep those risks manageable.

Your company's specific situation requires an immediate assessment. Delay forfeits the notification exemption and may preclude regularisation entirely.

To receive an expert assessment of your Ukrainian employee relocation compliance, contact info@kordeckipartners.com. We will audit your current permit status, file outstanding notifications, and structure employment contracts to meet Polish labour law requirements.

Frequently asked questions

Q: Can a Ukrainian employee start work in Poland before the work permit is issued?

A: Only if the employee holds valid temporary protection status under the Ukraine Aid Act and the employer files a PUP notification within 14 days of the employment start date. Outside that exemption, commencing work before a permit is issued is an administrative offence. The employer faces a fine of up to PLN 30,000 per employee, and the employee's right to continued stay may be jeopardised.

Q: How long does a standard Type A work permit take, and what does it cost?

A: Processing currently takes 30 to 60 days at the Voivode's office, depending on the region. The state fee is PLN 100 per permit. However, the labour market test at the WUP must be completed first, which adds 14 to 21 days to the timeline. Employers should budget at least 60 days from start to finish and begin the process well before the planned employment date.

Q: Does the whistleblower channel requirement apply to companies that recently expanded headcount through Ukrainian relocations?

A: Yes. The 50-employee threshold under Poland's whistleblower legislation is calculated against the total headcount of the Polish employing entity, including all workers regardless of nationality or permit type. A company that crossed the 50-employee threshold after relocating Ukrainian staff must implement an internal reporting channel without delay. The obligation is not linked to the type of employment contract or the employee's immigration status.

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 Ukrainian and CIS desk matters. 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.