Temporary protection for Ukrainian nationals

A Ukrainian software engineer arrives in Warsaw in March 2026. Her employer – a Polish IT company – needs her to start work within days. The question is not whether she can work. The question is whether the legal framework still supports that right, and for how long.

Temporary protection for Ukrainian nationals in Poland remains in force through at least March 2027, extended by EU Council decision. Holders of temporary protection status have the automatic right to work in Poland without a separate work permit. Registration at a local urząd gminy (municipal office) and obtaining a PESEL identification number are the two procedural steps that unlock access to employment, healthcare, and social benefits.

This guide walks through the current status of temporary protection, the step-by-step procedure for registration and employment, the three most common compliance mistakes employers make, and what happens when the status eventually ends. Each section includes at least one concrete figure – a deadline, a cost, or a threshold that matters in practice.

What is the current status of temporary protection in Poland?

Temporary protection was activated across the European Union in March 2022 following Russia's full-scale invasion of Ukraine. In Poland, the legal framework is built on two pillars: the EU Temporary Protection Directive and the Polish Act on Assistance to Citizens of Ukraine (the Ukraine Assistance Act). The Ukraine Assistance Act was passed within days of the invasion and has been amended several times since. The current extension runs through 4 March 2027.

The Office for Foreigners (Urząd do Spraw Cudzoziemców, UdSC) is the central authority for foreigners' status in Poland. The National Court Register (Krajowy Rejestr Sądowy, KRS) is relevant for employers hiring through Polish corporate structures. The Social Insurance Institution (Zakład Ubezpieczeń Społecznych, ZUS) handles social contributions for protected workers. All three institutions interact in a typical employment scenario.

Temporary protection covers Ukrainian nationals who left Ukraine on or after 24 February 2022, as well as certain stateless persons and third-country nationals who held valid residence in Ukraine at that date. Family members of covered persons are included. The protection does not extend automatically to Ukrainian nationals who were already residing in Poland under other titles before that date – they remain on their original permits.

Coverage period: 24 February 2022 – 4 March 2027 (current extension)
Automatic right to work: yes, no separate work permit required
Required registration: municipal office + PESEL number
Administering authority: UdSC for status; ZUS for social contributions
Third-country nationals covered: those with valid Ukrainian residence pre-24 February 2022

One point employers frequently miss: temporary protection status is not a residence card. It is a legal status that exists in the system. A Ukrainian national operating under this framework does not hold a physical document confirming the right to work in the way that a residence permit card does. The employer's obligation is to verify PESEL registration and confirm the individual's arrival date – not to collect a work permit document that simply does not exist in this context.

How does the step-by-step registration procedure work?

Registration under the Ukraine Assistance Act follows a two-step sequence. Step one is reporting presence at the local municipal office within 60 days of crossing the Polish border. Step two is obtaining a PESEL number, which serves as the universal identifier for access to employment, healthcare, education, and social benefits. Failure to complete both steps within the 60-day window does not void the underlying protection, but it creates practical obstacles for employers trying to verify status.

The municipal registration itself requires a valid Ukrainian passport or national identity document, a photograph, and a completed application form. The PESEL is assigned within a few days of registration – typically three to five working days in Warsaw, longer in smaller municipalities during peak periods. The individual also receives access to the mObywatel government application, which stores a digital confirmation of PESEL and registered address. This digital record is increasingly accepted by employers as proof of status.

We assisted a Ukrainian IT contractor relocating to Mazowieckie region (winter 2026) whose employer had incorrectly insisted on a work permit before onboarding. The contractor held valid temporary protection status and a PESEL number. After reviewing the Ukraine Assistance Act and the employer's internal HR policy, we helped the company update its onboarding checklist within 48 hours – avoiding a two-week delay that would have breached the start-date clause in the contractor's agreement.

For employers, the compliance record to maintain is straightforward. Keep a copy of the employee's PESEL confirmation and a declaration of the date of crossing the Polish border. Polish labour law requires employers to retain documentation confirming the legal basis for employment of foreign nationals. The Labour Inspectorate (Państwowa Inspekcja Pracy, PIP) audits these records. An employer who cannot produce them faces a fine of up to PLN 30,000 per worker.

What are the three most common compliance mistakes for employers?

The first mistake is treating temporary protection like a standard work permit. Employers experienced with hiring non-EU nationals under the standard permit system sometimes apply the same documentation checklist. That checklist is wrong here. There is no permit to collect, no employer obligation to file with the voivode, and no 30-day waiting period. Applying the wrong procedure causes delays and, in some cases, results in workers being told – incorrectly – that they cannot start work yet.

The second mistake is failing to update employment contracts when the legal basis for work changes. A Ukrainian national who initially worked under a standard work permit and later switched to temporary protection status holds a different legal basis for employment. The contract addendum should reflect this. Labour inspectors look at the stated legal basis during audits. A mismatch between the contract and the actual status is treated as a documentation failure, not a substantive violation – but it still generates findings and follow-up obligations.

The third mistake is ignoring the end-date risk. Temporary protection is not permanent. If the EU Council does not extend it beyond March 2027, employers will face a hard deadline. Workers who have not obtained an alternative residence title – such as a temporary residence permit, an EU Blue Card (Niebieska Karta UE), or a long-term EU resident permit – will lose the right to work in Poland. Planning for this transition now, rather than in early 2027, is the responsible approach. Transition applications under standard immigration law typically take three to six months to process.

For foreign investors entering Poland with Ukrainian staff, the compliance picture is further complicated by the interaction between temporary protection rules and the standard employment framework. Our guide on global mobility and relocating employees to Poland covers the broader picture for cross-border workforce moves.

How do three business scenarios play out in practice?

Scenario one: a Polish manufacturing company in Silesia hires 40 Ukrainian workers under temporary protection. All 40 registered at the municipal office within 60 days of arrival and hold PESEL numbers. The company's obligation is to retain PESEL confirmations, document the legal basis in each employment contract, and register all workers with ZUS within seven days of the employment start date. The ZUS registration deadline of seven days is firm – late registration triggers penalty proceedings.

Scenario two: a Warsaw-based IT company wants to employ a Ukrainian senior developer long-term. The developer currently holds temporary protection status but has been in Poland since April 2022 – nearly four years. She qualifies for a long-term EU resident permit, which requires five years of continuous legal residence. Alternatively, the company can sponsor an EU Blue Card application, which requires a gross salary of at least EUR 1.5 times the average in the relevant sector. Starting that process now – rather than waiting for the 2027 deadline – gives the developer two parallel paths to secure status.

We secured a smooth transition to an EU Blue Card for a Ukrainian engineer in Małopolska (autumn 2025), completing the process in four months from initial filing to permit issuance. The employer's salary offer exceeded the statutory threshold, which removed the main procedural obstacle.

Scenario three: a German investor establishes a Polish subsidiary and intends to second Ukrainian nationals from its Kyiv office to Warsaw. These individuals did not enter Poland as refugees – they entered on business visas. They do not qualify for temporary protection. The investor must use the standard work and residence permit route, which involves the voivode's office and a processing time of two to four months. For investors assessing the regulatory environment before market entry, our analysis of foreign investment screening in Poland provides relevant background on the regulatory framework they will encounter.

What should employers prepare before the 2027 deadline?

The most common error in planning for the end of temporary protection is assuming that an extension will automatically arrive. The EU Council has extended the directive twice. A third extension is not guaranteed. Employers with significant Ukrainian workforces should treat March 2027 as a hard deadline and begin transition planning no later than September 2026 – leaving at least six months for permit applications to be processed.

The checklist below covers the minimum steps for any employer currently relying on the temporary protection framework.

Audit current workforce: identify all employees working under temporary protection status
Assess eligibility for alternative titles: long-term EU residence, EU Blue Card, standard temporary residence
Calculate processing timelines: standard permits take two to four months; EU Blue Card applications up to three months
Update employment contracts to reflect the correct legal basis for each worker
Confirm ZUS registration is current and documentation files are complete

One procedural point worth flagging: the standard temporary residence permit application must be filed before the current legal basis for residence expires. Filing after expiry is possible in some circumstances, but it triggers a gap in legal residence that can affect future applications for long-term status. A Ukrainian national who allows their temporary protection status to lapse without filing for an alternative permit may lose the continuity of legal residence needed for a long-term EU resident permit. That loss is difficult to remedy.

Employers in regulated sectors face an additional layer. Companies operating under financial sector supervision by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) must ensure that employment documentation for all foreign nationals meets the KNF's fit-and-proper and record-keeping expectations. The interaction between immigration compliance and sector-specific employment obligations is an area where legal advice pays for itself quickly. Our broader overview of employment law compliance in Poland covers the employment framework in detail.

Personal liability is a real risk for company officers who sign off on employment documentation. Under Polish corporate legislation, board members can be held personally liable for regulatory fines arising from systematic labour law violations. A PLN 30,000 fine per worker, multiplied across a workforce of 40, produces a PLN 1.2 million exposure that cannot be indemnified by the company once a personal liability finding has been made. That consequence is irreversible.

Frequently asked questions

Q: Does temporary protection status give Ukrainian nationals the right to work for any employer in Poland, or only the employer named in the registration?

A: Temporary protection gives an open right to work in Poland. There is no employer-specific restriction. A Ukrainian national with valid temporary protection status and a PESEL number can work for any employer in Poland, change jobs freely, and work on a civil law contract (such as a umowa zlecenia) as well as an employment contract. No new registration or notification is required when changing employers.

Q: How long does the PESEL registration process take, and what does it cost?

A: Registration at the municipal office is free of charge. The PESEL number is typically assigned within three to five working days in major cities. In smaller municipalities, the process can take up to ten working days during peak periods. There is no fee for the PESEL itself. The only cost is the time spent at the municipal office, which averages one to two hours including form completion and document verification.

Q: Is it true that Ukrainian nationals who entered Poland before 24 February 2022 are not covered by temporary protection?

A: This is a common misconception that requires careful analysis. Ukrainian nationals who were already legally residing in Poland before 24 February 2022 under a residence permit or visa are generally not covered by the Ukraine Assistance Act's automatic protection mechanism. However, their existing permits remain valid for their stated duration. If their permits have since expired, they must apply for renewal or a new title under standard immigration law. The temporary protection framework applies specifically to those who fled Ukraine on or after 24 February 2022.

Q: What happens to a Ukrainian employee's work status if the EU does not extend temporary protection beyond March 2027?

A: If temporary protection expires without extension, Ukrainian nationals currently relying on that status will lose their right to work in Poland from the date of expiry. There is no automatic grace period under current law. Employers should begin alternative permit applications no later than September 2026 to ensure continuity. Workers who have resided legally in Poland for five continuous years may qualify for a long-term EU resident permit, which provides indefinite residence rights independent of the temporary protection framework.

For a tailored assessment of your company's exposure under the current temporary protection framework, contact info@kordeckipartners.com. We will review your workforce documentation, identify workers at risk from the 2027 deadline, and prepare a transition plan that matches your operational timeline.

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 and global mobility. We operate a dedicated Ukrainian and CIS Desk, having processed over 200 work permits since 2023. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.