Temporary protection for Ukrainian nationals

A Ukrainian national employed by a Warsaw technology company since 2022 receives a letter from the Urząd do Spraw Cudzoziemców (Office for Foreigners, UdSC) asking her to confirm her status. Her employer's HR team has no idea whether her temporary protection document still covers her right to work – or whether a separate work permit is now required. The question is not academic. Getting it wrong exposes the company to fines and the employee to forced departure.

Temporary protection for Ukrainian nationals in Poland is governed by a dedicated national act implementing the European Union's Temporary Protection Directive. It grants eligible individuals the right to reside and work in Poland without a separate work permit, provided they register with the UdSC and hold a valid Zaświadczenie o korzystaniu z ochrony czasowej (certificate of temporary protection). The current protection period runs to 4 March 2026, with a legislative extension under active discussion in both the European Parliament and the Polish Sejm. Employers must verify the certificate's validity date before onboarding any Ukrainian national under this regime.

This guide walks through the registration procedure, the right-to-work rules, the most common compliance errors, and the practical steps both employees and employers should take before the current deadline expires. Three business scenarios – manufacturing, IT, and a foreign investor subsidiary – illustrate how the rules apply in practice.

What does temporary protection actually cover in Poland?

Temporary protection under Polish law does three things at once. It grants the right to reside in Poland lawfully. It grants the right to work for any employer without a separate work permit. It also entitles holders to access public services, including healthcare and schooling for children. The National Court Register (KRS) allows companies to onboard protected individuals as employees or contractors on the same day the certificate is presented. No additional authorisation from the Powiatowy Urząd Pracy (District Labour Office, PUP) is required.

Eligibility covers Ukrainian nationals who were residing in Ukraine before 24 February 2022, stateless persons and third-country nationals with a valid Ukrainian residence permit, and family members of the above. It does not automatically cover Ukrainian nationals who were already living in another EU member state before that date. The UdSC has issued guidance clarifying that dual nationals – holding both Ukrainian and another country's passport – may be excluded if the second nationality is that of an EU state.

One figure matters above all others for employers right now: 4 March 2026 is the current outer boundary. Any employment contract extending beyond that date must include a contingency clause or a parallel work-permit application, unless the Sejm enacts an extension before then. We secured a favourable PUP decision for a manufacturing client in the Mazowieckie region (autumn 2025) after demonstrating that their Ukrainian employees' certificates remained valid, avoiding a potential mass-permit filing that would have cost the company over PLN 80,000 in administrative fees.

How do Ukrainian nationals register for temporary protection in Poland?

Registration is handled by the UdSC and can be initiated at any border crossing or at a UdSC regional office. The process has three stages: identity verification, biometric data collection, and issuance of the certificate. In Warsaw, the UdSC office at ul. Taborowa handles most applications; in Kraków, the Małopolska provincial office processes them. The entire procedure takes between 30 and 90 days, depending on the applicant's place of registration and current office backlogs.

Documents required at registration:

Ukrainian passport or other identity document
Proof of residence in Ukraine before 24 February 2022 (utility bill, lease, or school record)
Completed registration form (available in Ukrainian and Polish on the UdSC website)
Biometric photograph meeting the UdSC's technical specifications
For family members: proof of family relationship with the primary applicant

There is no registration fee. The certificate itself is issued free of charge. The Polish Financial Supervision Authority (KNF) is not involved in this procedure – it becomes relevant only if the individual intends to provide regulated financial services. Once issued, the certificate serves as a standalone work-authorisation document. Employers should retain a copy in the personnel file alongside the employment contract.

What are the right-to-work rules for employers hiring under temporary protection?

An employer hiring a Ukrainian national under temporary protection must verify three things before the first day of work: the certificate is genuine, its validity date has not passed, and the employee's identity document matches the certificate. The Państwowa Inspekcja Pracy (State Labour Inspectorate, PIP) conducts spot checks and can impose fines of up to PLN 30,000 per infraction for illegal employment. That figure doubles for repeat violations within two years.

The right to work is unconditional with respect to sector and employer. A protected individual can work in manufacturing, IT, hospitality, or any other field. They can change employers freely – no notification to the PUP is required. This is a significant operational advantage over a standard work permit, which is tied to a specific employer and requires a new application for each job change. For IT companies rotating staff across projects, this flexibility is material. (It is also why many employers in the technology sector have been slow to pursue parallel EU Blue Card applications – the temporary protection regime is simply more convenient.)

Self-employment is permitted. A protected individual may establish a sole proprietorship registered in the Centralna Ewidencja i Informacja o Działalności Gospodarczej (Central Register and Information on Business Activity, CEIDG) or become a shareholder in a Polish limited liability company. The same right-to-work freedom applies. However, social security contributions follow standard Polish rules, and the ZUS (Social Insurance Institution) has been auditing registrations of Ukrainian sole traders since mid-2024.

To discuss how the right-to-work rules under temporary protection apply to your workforce, contact info@kordeckipartners.com.

Your company's specific situation may have an irreversible consequence if verification is delayed past the certificate's expiry date: the employee becomes an unauthorised worker overnight, and any employment contract in force at that moment exposes the company to PIP sanctions. Acting before the 4 March 2026 deadline is not optional.

What happens when temporary protection expires – and what are the alternatives?

If temporary protection ends without an extension and no alternative status is in place, the Ukrainian national loses both the right to reside and the right to work in Poland on the day of expiry. This is the irreversible consequence that makes advance planning essential. Employers who wait until the deadline will face a six-to-twelve-month gap, because standard work permit procedures – including the EU Blue Card – take between three and nine months from application to decision.

The main alternative statuses available to Ukrainian nationals in Poland are:

Temporary residence and work permit – tied to a specific employer, valid up to three years, requires a labour market test in most regions
EU Blue Card – for highly qualified workers earning at least 150% of the average gross salary in Poland (currently around PLN 10,500 per month); valid three years, portable across the EU after 18 months
Refugee status or subsidiary protection – available to individuals who face persecution or serious harm if returned to Ukraine; processed by the UdSC, timeline of six to eighteen months
Long-term EU resident status – available after five years of legal residence; grants near-permanent right to remain and work

The decision matrix depends on salary level, employer size, and how quickly the employer needs continuity. For manufacturing companies paying average wages, the standard work permit is the only realistic option. For IT firms with senior engineers earning above PLN 10,500, the EU Blue Card is worth pursuing in parallel now – the 18-month portability window becomes a selling point for international talent. We obtained a residence and work permit for a Ukrainian engineer at a subsidiary in Lower Silesia (spring 2025) within four months by submitting a complete application on the first filing date, avoiding a resubmission that would have added three months to the timeline.

For guidance on structuring the right transition pathway for your Ukrainian employees, reach out to info@kordeckipartners.com.

The specific circumstances of your company's workforce – headcount, salary bands, and contract lengths – determine which route avoids a gap in work authorisation. Waiting until March 2026 to begin this analysis forfeits the lead time needed for a smooth transition.

Three business scenarios: manufacturing, IT, and foreign investor subsidiary

These scenarios illustrate how the rules operate in practice. Each involves a different employer profile and a different compliance challenge. None of them is hypothetical in the sense that the fact patterns recur regularly in our practice.

Manufacturing company, Silesia. A medium-sized manufacturer employs 45 Ukrainian nationals on the shop floor. All hold temporary protection certificates expiring in March 2026. The company cannot afford a six-month staffing gap. The right move is to begin standard work permit applications for all 45 employees by October 2025 at the latest, targeting a decision before March. The labour market test requirement means the company must post each vacancy at the PUP for at least one day before filing – a procedural step that takes seven days in total. Budget: approximately PLN 440 per permit application, plus HR time.

IT company, Warsaw. A software house has twelve Ukrainian developers earning between PLN 12,000 and PLN 18,000 per month. All qualify for EU Blue Cards. The employer should file Blue Card applications now. The advantage: Blue Card holders can change employers after 18 months without a new permit, reducing future administrative burden. The application requires an employment contract for at least one year and proof of relevant qualifications. Timeline: three to five months from submission to decision at the Warsaw voivodeship office. For comparison, compliance considerations for companies operating across borders are addressed in our guide on employment law compliance for Netherlands companies in Poland.

Foreign investor subsidiary, Małopolska. A German-owned subsidiary employs eight Ukrainian managers under temporary protection. The parent company wants to know whether those employees can be posted to Germany after their Polish status expires. The answer involves both Polish temporary residence rules and German immigration law. The EU Blue Card is the right instrument here precisely because of its cross-border portability. Once the individual has held a Blue Card in Poland for 18 months, German law allows a simplified transfer. Employers navigating cross-border posting arrangements will also find our article on posted workers from Luxembourg to Poland and A1 certificates relevant to the A1 documentation required during any transitional period.

Frequently asked questions

Q: Does a Ukrainian national under temporary protection need to notify anyone when changing employers in Poland?

A: No notification to the District Labour Office or the Office for Foreigners is required when a protected individual changes employers. The right to work is not tied to a specific employer under the temporary protection regime. The new employer should verify the certificate's validity date and retain a copy in the personnel file, but no administrative filing is triggered by the job change. This differs entirely from the standard work permit, which requires a new application for each employer.

Q: How much does it cost to apply for a standard work permit once temporary protection expires?

A: The state fee for a standard work permit application is PLN 100 per permit. In practice, total costs including preparation, translation of documents, and any legal assistance typically range from PLN 300 to PLN 800 per employee. Employers with large Ukrainian workforces should also factor in the HR time required for collecting documents and attending the voivodeship office. Applications submitted with incomplete documentation are rejected without refund, so accuracy on the first filing is important.

Q: Is it a common misconception that temporary protection automatically converts into a residence permit?

A: Yes, this is one of the most frequent misunderstandings we encounter. Temporary protection does not automatically convert into any other form of legal status. When the protection period ends, the individual's right to reside and work in Poland ends with it – unless a separate permit application has been filed and decided before expiry. The UdSC does not issue conversion decisions. Each alternative status requires a standalone application, its own documentation set, and its own processing timeline. Employers who assume automatic conversion will find themselves with unauthorised workers on their payroll the day after the deadline.

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, immigration compliance, and workforce planning. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. Our Ukrainian Desk handles temporary protection registrations, work permit applications, EU Blue Card filings, and cross-border mobility matters for Ukrainian and CIS nationals employed in Poland. If you are involved in a commercial dispute arising from employment or immigration issues, our disputes practice is available at kordeckipartners.com/en/practices/disputes/poland/. To discuss your situation, contact info@kordeckipartners.com.