As of June 1, 2025, the new Law on the Conditions of Permissibility of Entrusting Work to Foreigners on the Territory of the Republic of Poland has come into force, replacing previous provisions under the Law on Employment Promotion and Labor Market Institutions. This legislation introduces significant changes affecting how companies hire and manage foreign employees in Poland.

This article summarizes the most important updates and their current impact on employment policies, particularly concerning non-EU workers currently employed or newly hired.

New Employer Obligations

Since June 1, 2025, employers entrusting work to foreigners must comply with several new obligations:

  • Written employment contracts: All employment contracts with foreign workers must be concluded in writing. Verbal agreements are no longer sufficient, ensuring clear terms and legal certainty.
  • Submission of employment contracts to authorities: Employers are required to submit signed employment contracts to the relevant state administration authority, prior to employing a foreigner in Poland. This formal step is essential for legalizing foreign employment and must be completed promptly.
  • Sworn translation of employment contracts: If the contract is in a language other than Polish, a sworn Polish translation must be kept on file. This ensures authorities can verify contract terms accurately.
  • Collection of employee identification documents: Employers must obtain and retain copies of the foreign employee’s passport and PESEL number certificate. These documents are critical for administrative, tax, and social security purposes.
  • Notification of employment status changes: Employers are obligated to inform the provincial governor without delay if a foreign employee does not start or stops working. This ongoing notification duty helps authorities monitor foreign employment status.
  • Retention of employee personal data: Employee personal data must be securely retained for two years following employment termination to comply with record-keeping regulations.

Changes in the employment of graduates from Polish universities

A key positive development is that graduates of Polish universities can now work without a work permit, regardless of the study mode (full-time, part-time, or distance learning). This facilitates smoother recruitment and retention of locally educated talent.

Employers should update hiring policies to reflect this exemption and promote opportunities for Polish-educated graduates.

Changes in the restrictions on employment based on residence permits

The law now imposes new restrictions on employment eligibility based on certain visa or residence permit types. Foreigners holding specific visas may be prohibited or limited in their ability to work.

Employers must verify visa and permit conditions before assigning work to avoid legal violations and penalties.

Changes to work permits and declarations

Significant procedural reforms include:

  • Introduction of a new classification system for work permits
  • Full digitization of work permit and declaration processes
  • Removal of the labor market test requirement
  • Elimination of the “fast-track” priority system for work permit processing

Employers must adapt to the new electronic application system and updated permit categories to maintain compliance.

Changes regarding visas and temporary residence permits

The law establishes priority processing (fast-track) for visa and for specific applications for the issuance of work permits concerning companies of strategic importance, continuation of employment with the same employer, and shortage occupations, improving onboarding efficiency for eligible foreigners.

HR and mobility managers should leverage these provisions while carefully monitoring eligibility criteria.

Strengthened inspection powers and penalties

The State Labor Inspectorate and Border Guard have been granted expanded authority to inspect and enforce compliance with foreign employment laws. Fines for violations have increased substantially.

Employers must ensure strict adherence to the new legal requirements, maintain thorough documentation, and prepare for potential audits.

Practical implications for employers

  • Review and update employment contracts and policies to comply with written contract and submission requirements.
  • Implement secure document management systems for storing contracts, translations, passports, and PESEL certificates.
  • Monitor foreign employees’ visa and residence statuses regularly to confirm ongoing work eligibility.
  • Train HR and mobility staff on the new procedures, electronic systems, and inspection protocols.
  • Capitalize on work permit exemptions for Polish university graduates to streamline hiring.
  • Collaborate with legal and immigration experts to navigate complex compliance issues.

Moving Forward with Compliance and Confidence

With the new law fully in effect, employers in Poland must prioritize compliance to avoid penalties and operational disruptions. Understanding the detailed obligations and integrating them into daily HR and mobility operations will help organizations build a compliant, efficient, and resilient foreign workforce.

At Expatax, our team supports companies with every aspect of employing foreign nationals in Poland, from residence and work permit applications to ongoing tax and legal compliance.

If you would like guidance on how these changes may affect your organization or assistance adapting your policies, please contact our team to discuss your specific needs.

Published 25 NOVEMBER 2025

Author: ExpaTax