Temporary protection for Ukrainian nationals

A Ukrainian national employed by a Warsaw technology company has worked under temporary protection since March 2022. Her employer now faces a compliance review. The protection status is due for renewal, the work authorisation documentation is incomplete, and the human resources team cannot confirm whether the current framework still permits automatic employment without a separate work permit. The gap between what the law says and what the company has actually done is widening by the day.

Temporary protection for Ukrainian nationals in Poland is governed by the Act on Assistance to Ukrainian Citizens (Ustawa o pomocy obywatelom Ukrainy, the Ukraine Aid Act), which grants eligible persons the right to reside and work in Poland without a separate work permit. The protection period has been extended multiple times and currently runs through at least the first quarter of 2026. Employers who fail to verify the legal basis for employment – or who allow the protection period to lapse without transitioning to an alternative status – face administrative sanctions and, in serious cases, personal liability of management board members.

This service page explains the current regulatory framework, identifies the most common compliance failures, and sets out practical steps for employers and Ukrainian nationals who need to act before the next statutory deadline. We cover the employment authorisation rules, transition pathways to standard work permits or the EU Blue Card, and the specific risks that arise in cross-border and multi-jurisdiction structures.

What does temporary protection status currently allow in Poland?

Temporary protection under the Ukraine Aid Act gives eligible Ukrainian nationals the right to both reside and work in Poland without a separate work permit. That is the single most important feature of the regime. The employer need not obtain a work permit Poland-style before hiring – the protection status itself serves as the authorisation. The protection period has been extended by the Polish government in coordination with European Union Council decisions, and the current deadline extends to at least March 2026.

The National Court Register (Krajowy Rejestr Sądowy, KRS) and the Office for Foreigners (Urząd do Spraw Cudzoziemców, UdSC) are the two principal administrative bodies that interact with employers and employees in this context. The Social Insurance Institution (Zakład Ubezpieczeń Społecznych, ZUS) processes registration of Ukrainian workers and issues confirmation of social insurance coverage. Employers must notify the relevant district labour office (Powiatowy Urząd Pracy) within 14 days of hiring a person under temporary protection – a step that many businesses missed in the early, high-volume months of 2022 and have never corrected.

The protection covers nationals who entered Poland on or after 24 February 2022 and registered with the relevant municipal authority (urząd gminy) within the statutory period. Stateless persons habitually resident in Ukraine and certain third-country nationals who held valid Ukrainian residence permits at the date of displacement also qualify, subject to documentary verification. Employers should not assume that a Ukrainian passport alone confirms eligibility.

Right to reside and work without a separate work permit
Access to the public health system and education
Entitlement to social benefits under Polish law
PESEL number registration enabling banking and tax compliance
14-day employer notification obligation to the district labour office

One practical complication concerns persons who arrived before 24 February 2022. They do not qualify for temporary protection and require a standard work authorisation pathway. An employment lawyer Warsaw-based teams consult frequently will confirm that this distinction – arrival date relative to the invasion – is the single most common source of misclassification in employment files.

What are the main compliance risks for employers?

The most immediate risk is employing a person whose temporary protection has lapsed or who was never properly registered in the first place. Under Polish labour law and the Act on the Promotion of Employment and Labour Market Institutions (Ustawa o promocji zatrudnienia i instytucjach rynku pracy), employing a foreigner without valid authorisation carries fines of up to PLN 30,000 per individual. Repeated violations can trigger criminal liability for the person responsible within the company's management structure.

We secured a reversal of an administrative fine exceeding PLN 80,000 for a manufacturing client in the Mazowieckie region (autumn 2025). The company had hired six Ukrainian workers under temporary protection but failed to file the mandatory notifications with the district labour office within the 14-day window. The authority issued fines and initiated a follow-on inspection of the entire workforce. We challenged the procedural basis of the notifications and obtained a full reversal on appeal.

A second category of risk involves the PESEL number. Ukrainian nationals under temporary protection are entitled to a PESEL number, which is required for tax registration, social insurance contributions, and payroll processing. Employers who process payroll without a PESEL – relying instead on a passport number – create discrepancies in ZUS records that can take months to untangle. The financial exposure includes unpaid social insurance contributions plus statutory interest, currently running at 8 percent per annum.

Documentation failures are the third major risk area. The protection status is linked to a specific UdSC registration record. If the worker's UdSC record shows an expired or cancelled status, the employment is unauthorised from the date of lapse – regardless of what the employment contract says. Employers who do not run periodic checks on the UdSC database are effectively operating blind.

Whistleblower Poland obligations add a further layer. Since the transposition of the EU Whistleblowing Directive into Polish law in 2024, companies employing more than 50 workers must maintain a reporting channel. Ukrainian employees who report compliance failures – including failures in their own documentation – are protected from retaliation. Employers who dismiss or demote a whistleblower face reversal of the termination and damages.

For a tailored assessment of your employment compliance exposure, reach out to info@kordeckipartners.com.

How does the transition to standard work authorisation work?

Temporary protection is not permanent. When the protection period ends – or if an individual's status lapses before the statutory deadline – the Ukrainian national must either leave Poland or hold an alternative authorisation. The two main pathways are the standard work permit (zezwolenie na pracę, Type A) and the EU Blue Card (Niebieska Karta UE), which applies to highly qualified workers earning at least 150 percent of the average gross salary in Poland (currently approximately PLN 10,500 per month).

The Type A work permit is employer-specific. It is issued by the relevant voivode (Wojewoda) and tied to a specific employer and position. The process takes between 30 and 90 days depending on the voivodeship. Warsaw-based employers using the Mazowieckie voivodeship office should budget for the upper end of that range. The permit must be obtained before the employment begins – or, in a transition scenario, before the temporary protection lapses.

The EU Blue Card offers a more flexible status. It is valid for up to three years, allows the holder to change employers after two years, and creates a pathway to long-term EU residence. For Ukrainian nationals who hold university degrees and are employed in professional or managerial roles, the EU Blue Card is often the better long-term instrument. However, the salary threshold is a genuine barrier for workers in lower-wage sectors.

A third option is the temporary residence and work permit (zezwolenie na pobyt czasowy i pracę), which combines residence and work authorisation in a single document. It is issued by the voivode and is valid for up to three years. Processing times currently run to six months or more in Warsaw and Krakow. Employers who plan transitions should initiate applications at least eight months before the protection period ends to avoid a gap in authorisation.

We obtained a set of five EU Blue Card approvals for an IT services firm in Wielkopolska (spring 2025), enabling the company to retain its Ukrainian development team without interruption following the expiry of their temporary protection registrations. The transition was structured over a 14-week period with no employment gap.

To discuss the transition pathway that fits your workforce structure, contact info@kordeckipartners.com.

What cross-border issues arise for posted workers and multi-jurisdiction employers?

Ukrainian nationals working in Poland are sometimes part of cross-border employment arrangements. A German parent company may have seconded an employee to its Polish subsidiary. A Swiss-based logistics firm may rotate workers between its Polish and Swiss operations. In both cases, the temporary protection regime interacts with EU and bilateral rules on social security, tax residency, and work authorisation in ways that require careful sequencing.

Social security coordination is the first pressure point. Poland and Ukraine do not have a bilateral social security agreement equivalent to the EU coordination rules. For Ukrainian workers employed in Poland, ZUS contributions are mandatory unless a specific exemption applies. When a worker is simultaneously posted to another EU member state, the A1 certificate mechanism applies to determine which member state's social security system covers the worker. For postings from Switzerland to Poland, the rules differ from standard EU arrangements – as discussed in our analysis of posted workers from Switzerland to Poland and A1 certificates. Similarly, the framework for posted workers from the United Kingdom to Poland and A1 certificates introduces distinct rules that do not follow the EU model.

Tax residency is the second issue. A Ukrainian national who has lived in Poland for more than 183 days in a calendar year becomes a Polish tax resident. This means worldwide income is taxable in Poland, including any income received from a Ukrainian or foreign employer. Employers who fail to advise their workers on this point – or who do not adjust their payroll structures accordingly – create tax liabilities that can surface during a Polish Tax Administration (Krajowa Administracja Skarbowa, KAS) audit years later.

Ownership structures involving Ukrainian assets also require attention. A Ukrainian national who holds shares in a Polish company, or whose Polish employer has Ukrainian subsidiaries, may need to consider restructuring options. Our analysis of family foundation versus holding company structures is relevant for clients who are weighing asset protection and succession planning alongside their employment status.

For employers operating across multiple jurisdictions, the checklist below identifies the key items to verify before a compliance audit or status transition.

What should employers and Ukrainian nationals prepare before the next deadline?

The approaching end of the current temporary protection period – and the administrative backlog in voivodeship offices processing standard work permits – means that preparation must begin well in advance. Six months is the minimum lead time for a clean transition. Eight months is safer. Employers who wait until the statutory deadline passes will find their workers in an unauthorised status, with all the consequences that follow.

The following checklist covers the core items for employers and HR teams managing Ukrainian nationals under temporary protection.

Verify UdSC registration status for each Ukrainian employee and confirm no lapse or cancellation
Confirm PESEL numbers are registered and match ZUS records for all workers
Check district labour office notification files – confirm 14-day notifications were filed and retained
Identify workers approaching the end of temporary protection and select the correct transition pathway (Type A, EU Blue Card, or combined permit)
Initiate voivodeship permit applications at least six months before the protection period ends

Employers in the manufacturing, logistics, and IT sectors face the highest exposure. Manufacturing and logistics companies often employ large numbers of Ukrainian workers in lower-skilled roles, where the Type A permit is the standard pathway but processing backlogs create gaps. IT companies frequently employ highly qualified workers who qualify for the EU Blue Card but have not initiated applications because the temporary protection has, until now, made the process feel unnecessary.

One scenario that arises repeatedly involves a worker who has changed employers during the protection period. Temporary protection is personal – it is not tied to an employer. But the 14-day notification obligation applies to each new employer. A worker who has held three jobs in three years may have three separate notification gaps, each of which represents a potential fine for each former employer.

A business scenario from the services sector illustrates the stakes. A Krakow-based customer support firm employing 120 Ukrainian nationals discovered during an internal audit in winter 2026 that 34 of those employees had PESEL numbers registered under different spelling variants of their names, creating ZUS mismatches. Correcting the records required coordinated submissions to ZUS, the relevant municipal offices, and the UdSC, taking approximately 11 weeks to resolve. The cost in management time and external legal fees exceeded PLN 150,000.

Frequently asked questions

Q: If a Ukrainian national's temporary protection status has already lapsed, can the employer continue the employment while a new permit is being processed?

A: No. Once the temporary protection status lapses, the legal basis for employment without a separate work permit ceases to exist. Continuing the employment during the processing period constitutes unauthorised employment under Polish law and exposes the employer to fines of up to PLN 30,000 per worker. The correct approach is to suspend the employment contract – with the worker's agreement – until the new authorisation is issued, or to apply for an interim administrative decision from the voivode confirming that the application is pending. The interim decision does not authorise employment but may reduce the severity of any subsequent administrative sanction.

Q: How long does it take to obtain an EU Blue Card for a Ukrainian national in Warsaw, and what does it cost?

A: Processing times at the Mazowieckie voivodeship office currently range from four to seven months. The statutory fee is PLN 440 for the permit itself. However, the total cost including document preparation, translation, legalisation, and legal advisory typically ranges from PLN 3,000 to PLN 8,000 per application depending on complexity. Employers who sponsor multiple applications simultaneously can often achieve efficiencies in document preparation. The salary threshold – currently approximately PLN 10,500 gross per month – must be maintained throughout the permit's validity period, not merely at the time of application.

Q: Is it true that Ukrainian nationals under temporary protection automatically have the right to work for any employer in Poland without any formalities?

A: This is a common misconception. The right to work without a separate work permit is correct, but it is not free of formalities. The employer must file a notification with the district labour office within 14 days of the start of employment. The worker must have a valid PESEL number. The employment contract must be in writing, and the worker must be registered with ZUS within seven days of the start of employment. Failure to meet any of these obligations – even where the underlying right to work is valid – exposes the employer to administrative sanctions. The "automatic" characterisation that circulated in 2022 was an oversimplification that has caused persistent compliance failures.

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, work permit Poland procedures, and cross-border workforce compliance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams managing Ukrainian and CIS national employees. To discuss your situation, contact info@kordeckipartners.com.