Polish authorities have set three compliance deadlines between June 30 and August 31, 2026 that directly affect employers with foreign national employees in Poland. HR and mobility teams should act now to audit affected populations and prompt employees to take action before each deadline passes.

1. Student work permit exemption: audit before June 30, 2026

Under Polish law, foreign nationals enrolled full-time (stacjonarne) in first-cycle, second-cycle, long-cycle or doctoral studies at a qualifying institution in Poland — one holding ministerial approval — may work without a work permit. Part-time, postgraduate and MBA programmes do not qualify. Students on those programmes need a work permit to work legally.

Introduced alongside Poland's June 2025 employment reforms, a transitional arrangement has allowed students at certain institutions that do not yet hold ministerial approval to continue working without a permit. That window closes on June 30, 2026.

The change does not affect students whose immigration status already reflects a full-time student purpose of residence at an approved institution.

Employers should audit foreign national employees currently working without a work permit on the basis of student status. Where it is unclear whether an employee meets the qualifying criteria, legal advice should be sought before the deadline.

The consequence of inaction: fines, and in repeat cases, loss of eligibility to employ foreign nationals in Poland.

2. Ukrainian nationals: UKR status data update by August 31, 2026

Ukrainian nationals who registered their stay in Poland and obtained PESEL UKR status without presenting a valid biometric passport at registration must confirm their identity in person at their local municipal authority. This requirement follows the end of the Ukrainian Special Act in March 2026. The update cannot be done online or by post.

Employers should notify Ukrainian employees holding UKR status of the obligation and encourage early action, given the volume of affected individuals and likely administrative queues at municipal offices.

Failure to update by August 31, 2026 will trigger an automatic status change from UKR to NUE as of September 1, 2026, with immediate loss of the right to reside and work in Poland. Affected individuals will also lose access to the newly introduced CUKR card (Czasowe Uprawnienie Karty Rezydenta), a three-year residence card offering a longer-term pathway for Ukrainians remaining in Poland after the Special Act framework ended. Timely action preserves both current status and future options.

3. EU residence documents: mass expiry on August 3, 2026

As part of EU-wide harmonisation of residence document security standards, all Polish residence documents issued to EU citizens and their non-EU family members before August 1, 2021 will expire on August 3, 2026, regardless of any longer or indefinite validity printed on the document. This includes permanent residence documents bearing no expiry date.

Employers should identify any employee holding Polish residence documents issued before August 1, 2021 — whether an EU national or a non-EU national family member of an EU citizen whose right to work derives from that document — and advise them to submit a renewal application without delay. Polish voivodeship offices are already reporting processing backlogs, and early filing is strongly recommended.

Missing the deadline requires a full new application with fresh supporting documentation. For non-EU family members of EU citizens, the stakes are higher: failure to renew on time may bar them from re-entering Poland and the Schengen Area until a new document is issued. Employers with internationally mobile employees in this category should treat this as a priority.

What employers should do now

Three audits, three dates. Screen your workforce for students working under the permit exemption before June 30, 2026. Flag Ukrainian employees with UKR status who registered without a biometric passport ahead of August 31, 2026. Check issue dates on EU-related residence documents ahead of August 3, 2026.

Each measure stems from Polish legislation and EU document-security rules; official guidance from the relevant Polish authorities governs individual cases. This article is informational and does not constitute legal advice for individual situations.