The year 2026 is shaping up to be a period of putting in order the rules for employing Ukrainian citizens and further tightening the conditions for legalizing the work of foreigners in Poland. Although Ukrainians remain the largest group of foreign workers and a pillar of many industries, their employment is increasingly moving from an extraordinary mode to a systemic one, with significant consequences for employers. As experts from Job Impulse, a company specializing in employing and legalizing the work of foreigners, indicate, companies are entering a period in which not only the availability of workers is key, but also the cost, stability, and formal correctness of the entire process.

Phasing out the special act, but not phasing out employment

The adoption by the Council of Ministers of a draft act phasing out the solutions of the special act regulating the stay and work of Ukrainian citizens formalizes a process that until now had functioned mainly in announcements. The draft act provides for maintaining temporary protection—in line with decisions at the EU level—until March 2027, which sets a real time horizon for employment planning.

At the same time, some of the solutions known from the special act are to be transferred to the Act on Employing Foreigners, amended in 2025. This concerns, among other things, notifications of entrusting work to Ukrainian citizens. According to the draft act phasing out the solutions of the special act, this mechanism is to be maintained during the transitional period—at least for the next three years—as one of the bases for the legal employment of Ukrainian citizens.

- From the labor market perspective, we are not dealing with a sudden “door closing.” Rather, with a process of organizing solutions that functioned in an exceptional mode for several years. This changes the way companies think—from reactive to more planning-oriented. This is a moment of transition from flexible, intervention-based solutions to a more formalized model. Companies must take into account that legalizing work—also in the case of Ukrainian citizens—will require greater organizational attention and involve greater responsibility on the employers’ side – emphasizes Łukasz Koszczoł, President of Job Impulse.

Rising costs of work legalization

Changes concerning Ukrainian citizens coincide with a significant increase in the costs of legalizing foreigners’ work, effective from December 1. The increases cover most of the employment modes most commonly used by employers:

·        declaration of entrusting work – fee increase from PLN 100 to PLN 400,

·        work permit up to 3 months – from PLN 50 to PLN 200,

·        work permit over 3 months – from PLN 100 to PLN 400,

·        permit for posting – from PLN 200 to PLN 800.

Importantly, these fees are non-refundable, which means that every formal mistake, change in recruitment plans, or candidate withdrawal generates real financial losses on the employer’s side.

- In practice, we observe that work legalization is ceasing to be a marginal cost and solely an administrative obligation. For companies employing larger numbers of foreigners, this is now an item that must be included in budgets and operational plans. At the same time, tolerance for formal errors is decreasing significantly – notes Łukasz Koszczoł.

New residence statuses and their significance for employment

The changes also concern the way the legality of residence of Ukrainian citizens is confirmed. Unofficial information is emerging about the possible phasing out of PESEL UKR as the key residence identifier and strengthening the role of the DIIA PL application as a tool confirming residence status. At the current stage, however, there are no clear, binding decisions in this regard. For employers, this means the need for ongoing verification of employees’ statuses, as well as exercising particular caution in managing HR documentation.

An important element of the new order is also to be the CUKR residence card, which is intended to provide Ukrainian citizens with a more stable, temporary residence status. According to announcements, the card is to be issued for a period of three years, and obtaining it will be linked to the cancellation of UKR status.

At the same time, it should be emphasized that the legal situation remains dynamic, and the final wording of the regulations may still change in the course of further legislative work. According to current announcements, however, it may be possible to maintain a simplified path for employing Ukrainian citizens—based on the notification mechanism—within the transitional period. In practice, this solution may limit the scale of organizational changes on the employers’ side, although it will require ongoing monitoring of regulations and adjusting procedures to their final shape.

Ukraine compared to other recruitment directions

It is worth emphasizing that changes concerning Ukrainians are taking place at a time when recruiting workers from other non-EU countries is becoming increasingly difficult. Complicated visa procedures or limited availability of appointment slots make obtaining workers from distant markets increasingly difficult.

- The year 2026 will not be a revolution, but a test of companies’ maturity in their approach to employing foreigners. Ukrainians will remain one of the key pillars of the Polish labor market, but they will operate in an increasingly formalized legal environment. In these conditions, the advantage will be gained by organizations that already today take legislative changes, costs, and risks into account in their HR strategies – comments Łukasz Koszczoł, President of Job Impulse.

Source: Job Impulse