Foreigner Residence and Work Legalization in Poland

Legal work requires two documents, not one

The first document answers whether a foreigner may stay in Poland. The second answers whether they may work here. These are two separate matters, handled by different authorities and based on different regulations. A visa allows entry and stay, but does not itself authorize work.

The most common error in companies is checking only one of these documents. The employer sees a residence card and assumes the matter is settled, or sees a registered statement (oświadczenie o powierzeniu pracy) and does not check the basis on which the employee stays in the country. Responsibility for both elements rests with the entity entrusting work.

There is one significant exception to this rule: some residence titles include the right to work. This applies to the temporary residence and work permit (zezwolenie na pobyt czasowy i pracę), CUKR residence card (karta pobytu CUKR), permanent residence permit (zezwolenie na pobyt stały), and EU long-term resident residence permit (zezwolenie na pobyt rezydenta długoterminowego Unii Europejskiej). In these cases, one document closes both issues.

Changes introduced by the Act of 20 March 2025

From 1 June 2025, the Act of 20 March 2025 on conditions for permissibility of entrusting work to foreigners in the territory of the Republic of Poland (Dz.U. 2025 poz. 621) applies. It replaced regulations that for years governed this matter in the Act on Employment Promotion.

The labor market test disappeared, i.e., the county head's information on lack of possibility to satisfy staffing needs. This was one of the longer parts of the procedure and its removal realistically shortened the path to the permit. The paper form also disappeared: applications are submitted exclusively electronically.

Sanctions went in the other direction. Penalties for illegal entrustment of work increased from the range of 1000 to 30 000 PLN to the range of 3000 to 50 000 PLN, and labor inspectors received the ability to impose fines via penalty tickets. For companies employing many foreigners, another change is significant: some penalties are imposed proportionally to the number of persons entrusted with work in violation of regulations.

Permit types A, B, C, D and E no longer exist

This is a change most often omitted, yet it directly affects filling out applications. The division into permit types A, B, C, D and E ceased to apply with the entry into force of the new Act. From 1 January 2026, old applications are no longer available on praca.gov.pl either.

In their place function three types of permits, each with its own application symbol. If in a guide, announcement, or intermediary offer you still see the formulation permit type A, it is a sign that the material has not been updated for over a year.

All three are issued by the voivode (wojewoda) competent due to the seat of the entity entrusting work or the place of delegation.

If an external company conducts the procedure for you, check what application symbol they use. This is the fastest test of whether they work on current regulations.

Work Entitlements: four paths

Choice of path depends on employee citizenship, type of work, and planned employment period. The shortest path leads through the statement-based procedure, but is available only for citizens of four countries.

From 1 December 2025, Georgia fell off the statement list. Its citizens now need a work permit (zezwolenie na pracę), though statements registered before this date retain validity until the end of the period for which they were entered in the register.

A separate category is seasonal work in agriculture, horticulture, and tourism. The seasonal permit is issued by the district labor office (powiatowy urząd pracy), allows work up to 9 months in a calendar year, and has the lowest fee of all paths.

When delegating a foreigner by a foreign entity, the fee is 800 PLN.

Residence Titles: from visa-free travel to permanent residence

Visa-free travel allows entry on a biometric passport and stay up to 90 days within 180 days, with days counted jointly for all Schengen zone countries. From 10 April 2026, border crossings are recorded by the EES system, which instead of a stamp records biometric data and counts used days itself.

The National D Visa is issued by a consul abroad, so it cannot be obtained while already in Poland. If the employee is in the country and wants to stay longer, the proper path is an application to the voivode (wojewoda) for a temporary residence and work permit, in jargon called TRC from the English temporary residence card.

For persons with longer residence status, two target paths open: permanent residence permit (zezwolenie na pobyt stały), in jargon PRC, and EU long-term resident residence permit (zezwolenie na pobyt rezydenta długoterminowego Unii Europejskiej). The first requires meeting one of statutory premises, for example Polish origin, Pole's Card, or marriage to a Polish citizen. The second is based on a time criterion: five years of legal and uninterrupted residence.

Uninterrupted residence has a statutory definition. Breaks cannot exceed a total of six months in a year nor ten months in the entire considered period. This is the most common cause of refusal for applications submitted after years of work in Poland.

Permit is a decision, residence card is a document

This distinction accounts for a large part of misunderstandings during inspections and hiring. The residence permit is an administrative decision of the voivode (wojewoda): it grants the right of residence under specified conditions. The residence card is a document that confirms this right and which the foreigner carries on their person.

For this reason, there are two fees and they are paid separately: stamp duty for granting the permit and fee for issuing the card itself, amounting to 100 PLN. The stamp duty must be paid in advance, under penalty of application return.

The card also has its own validity period, which does not always overlap with the entitlement period. For permanent residence, the permit is indefinite, but the first card is issued for 10 years and after this time it must be exchanged. Card expiration does not remove the right of residence, but without a valid document it is difficult to confirm one's status to an employer or bank.

What happens during proceedings

This question returns in every conversation with an employer: the employee submitted an application, and their current residence title is just ending. The rule is favorable. If the application was submitted during legal residence and contains no formal deficiencies, residence is considered legal from the day of application submission to the day the decision becomes final.

Confirmation is the stamp in the passport, which the voivode (wojewoda) places after personal appearance for fingerprint collection and after supplementing any deficiencies. The stamp itself does not replace the work entitlement: it legalizes residence, not employment. For work, a statement, permit, or other basis is still needed.

If the decision is negative, and the foreigner submits an appeal within the designated time, residence remains legal until the final decision is issued. For this reason, it is worth watching dates: an application submitted even one day after loss of legal residence does not trigger this protection.

Application for temporary residence and work permit is submitted to the voivode (wojewoda), while staying in Poland. National D Visa cannot be obtained in this mode, because it is issued by a consul abroad.

CUKR Residence Card: new path for Ukrainian citizens

The residence card with annotation Formerly holder of temporary protection, in short CUKR card, is a response to the situation of persons who since the beginning of the war have functioned in Poland on PESEL UKR number. It allows transition from temporary protection to a stable residence title.

Applications can be submitted from 4 May 2026 to 4 March 2027, exclusively electronically through the Case Service Module (Moduł Obsługi Spraw), without booking an appointment at the office. The card is issued for 3 years. Costs are 340 PLN stamp duty and 100 PLN for card issuance.

Conditions concern status, not employment. One must have a current PESEL UKR number on the day of application submission, have it current on 4 June 2025, possess UKR status uninterrupted for at least 365 days, and still have it on the day of card issuance by the voivode (wojewoda). The date condition cuts off persons who obtained status later: whoever received PESEL UKR number after 4 June 2025, will not go this path.

For the employer, the most important is the effect: CUKR card holder has full access to the labor market without additional permits and may conduct business activity on the same principles as a Polish citizen. The obligation to submit notifications of entrusting work disappears.

• current PESEL UKR on the day of application submission
• current PESEL UKR on 4 June 2025
• UKR status uninterrupted for at least 365 days
• current PESEL UKR on the day of card issuance by the voivode (wojewoda)

Ukrainian Citizens: validity periods

For persons who do not transition to the CUKR card, periods resulting from the Act of 26 January 2026 on phasing out solutions adopted after the outbreak of war apply. Residence on the basis of PESEL UKR number is legal until 4 March 2027, and work on the basis of notification is possible until 4 March 2029.

The notification itself is submitted by the employer within 7 days from the start of work by the employee. Another notification is required after each change of contract conditions, which companies most often forget about during raises and position changes.

Ukrainian citizens using temporary protection and staying legally in Poland may also perform seasonal work without a permit. This is a separate basis, independent of the notification. However, it is worth remembering the principle from the beginning of this text: exemption concerns the work entitlement, not residence. When the residence basis ends, the exemption from permit alone saves nothing.

Which document for whom

In practice, most matters boil down to several repeatable situations. Below are the most frequent of them, with the proper path.

• Ukrainian citizen with PESEL UKR number, already in Poland: notification, and ultimately CUKR card.
• Citizen of Armenia, Belarus, or Moldova for several months: statement on entrusting work (oświadczenie o powierzeniu pracy).
• Citizen of Georgia: from 1 December 2025 exclusively work permit (zezwolenie na pracę).
• Citizen of a country outside the statement list, just arriving: work permit (zezwolenie na pracę), then National D Visa at the consul.
• Employee already in Poland, employment to last longer: temporary residence and work permit at the voivode (wojewoda).
• Employee with five-year legal residence: EU long-term resident residence permit.

Employer obligations before and during work

Before admitting a foreigner to work, one must check the document confirming their legal residence and keep its copy. Employee statement or photo of document sent via messenger is not enough: verification is done before the first day of work, not after.

During employment, obligations do not disappear. Actual conditions must match what was declared in the application, and changes of position, work time dimension, or remuneration may require a new document or notification. Validity deadlines are monitored separately and extension is initiated in advance.

It is worth separating two roles in the company: who physically checks documents upon hiring and who manages the validity calendar. Inspections most often hit the interface of these two tasks, when everyone assumes someone else did it.

• verification of residence title before admitting to work
• keeping copy of document for the period of work performance
• compliance of employment conditions with application content
• reporting changes of conditions when regulations require it
• calendar of document validity and extensions in advance

Cost of an error

Illegal entrustment of work to a foreigner is threatened with a fine from 3000 to 50 000 PLN. For acts committed intentionally and with calculation, the lower limit rises to 6000 PLN. A labor inspector may impose a fine in penalty ticket proceedings up to 10 000 PLN.

The method of imposing the penalty also matters. Some penalties are imposed proportionally to the number of foreigners entrusted with work in violation of regulations, so with multi-person employment, amounts grow multiple times.

To this add consequences not visible in the tariff: work team suspension, necessity to supplement documents retroactively, and loss of an employee in whose recruitment and arrival the company already invested.

Five most common errors

The order here is not accidental: from most frequent to most costly.

• Work on visa-free travel alone. Entry without visa gives right of residence, not right to work.
• Gap between documents. Several days without valid title is already illegal entrustment of work.
• Change of conditions without notification. Different position or different work time dimension than in application.
• Counting deadline from decision. Real start is decision plus visa, if needed, plus travel.
• Relying on documents from before 1 June 2025, including on type A application templates.

Where and how to submit applications

Employee matters are handled through praca.gov.pl: this applies to statements on entrusting work, work permits, and notifications. Residence matters, including CUKR card, are handled by the Case Service Module (Moduł Obsługi Spraw) run by the Office for Foreigners (Urząd do Spraw Cudzoziemców).

Electronization removed queues, but did not shorten the proceedings itself. Legalization usually takes from 2 to 7 months, depending on path, citizenship, and load of the specific office. To this time one must add the National D Visa, if the employee is just arriving, and the travel itself.

Planning staffing, it is worth counting backwards: from the date the employee is to stand at the position, through travel and visa, to application submission. For seasonal work, this margin decides whether the team will make it for the season start.