(POLAND) Poland’s draft Post-March Worker Visa Holders in 2025″>2026 Rules replace the easy, notification-only hiring system for many Ukrainians with a formal system built around Full Work Permits or a new residence path called the CUKR regime. For Ukrainian workers and Polish employers, the change is practical and immediate: jobs that stayed legal with a quick online notice will need a permit-backed plan, tracked end dates, and more paperwork.
The shift lands while the wider EU protection picture stays in place. The European Union has extended the Temporary Protection Directive through March 4, 2027, but Poland is moving from wartime emergency measures to a more standard residence-and-work model.
That means you can still be under EU Temporary Protection, yet your right to work in Poland will increasingly depend on Polish documents and Polish compliance steps.
From emergency hiring to structured authorization after March 5, 2026
Under the wartime “Special Act” approach, many employers hired Ukrainian citizens by filing an electronic employment notification, rather than obtaining a classic work permit. That model scaled fast and helped people enter jobs quickly, but it also relied on simplified checks and short HR workflows.
The draft law under parliamentary review as of late January 2026 pivots away from that approach. Starting March 5, 2026, Ukrainian nationals will generally need formal work authorization for employment in Poland.
In practice, that authorization sits in one of two lanes:
- A standard work permit tied to a job and employer, issued under Poland’s work authorization system.
- A CUKR residence card that combines legal stay with built-in work authorization for eligible Ukrainians.
This is not only a paperwork change. It resets how employers prove compliance during audits, how workers show work eligibility to new employers, and how families keep benefits linked to insured work.
The CUKR regime: what the residence card does, and who it targets
The centerpiece of the draft is the CUKR residence card, designed for Ukrainians who have held PESEL UKR status. Think of it as a bridge from emergency registration to a regularized temporary residence status that also covers work.
CUKR differs from EU Temporary Protection in a simple way: EU Temporary Protection is a broad shield recognized across the EU framework, while CUKR is a Polish residence document with Polish work rights attached. CUKR also differs from a standard work permit because the work right is “embedded.” You do not rely only on an employer-specific permit to prove you can work.
In daily life, embedded work authorization matters in places where people get stuck. A worker changing jobs often needs to show work eligibility fast, not weeks later. A residence card that carries work authorization can reduce gaps, as long as the person stays within the rules and keeps the document valid.
Applicants should still expect the usual building blocks of a residence process. The filing package typically centers on:
- Proof of identity.
- Proof that you are already recorded in the system under the protection and registration framework.
- Proof of address in Poland and contact details that match what offices have on file.
- Biometrics, which often means an in-person appointment and waiting for a card production step.
Incomplete filings are where timelines slip. Mismatched spellings, old addresses, or missing status confirmations lead to follow-up letters and delays.
Many families also forget to align everyone’s paperwork at the same time, which later complicates benefits and insurance records. VisaVerge.com reports that the policy logic behind CUKR is to move from broad emergency access toward a stable, trackable status that employers, benefits agencies, and border systems can verify in a standard way.
Transition timetable: how to stay legal at work through the end of 2026
For workers already employed under the notification model, the transition rule is blunt and date-driven. Employment notifications filed before the new law takes effect remain valid only until their stated end date or December 31, 2026, whichever comes first.
After that, the notification alone will not carry the job. That creates a two-track task list: employers must inventory what they have, and workers must confirm which route they qualify for.
The goal is to avoid a late-2026 scramble where thousands of employment relationships hit the same cutoff. A workable compliance journey usually looks like this:
- Map current status and documents (now through early March 2026). HR should list every Ukrainian employee, their PESEL UKR details, notification dates, and job roles. Workers should keep copies of notifications and proof of ongoing employment.
- Choose the authorization lane (from early March 2026 onward). If the worker fits CUKR eligibility, plan around the residence filing path. If not, plan around a standard work permit tied to the job and employer.
- Prepare MOS-portal readiness and internal controls (spring and summer 2026). The draft framework expects employers to transition staff to formal permits via the MOS-portal workflow, with tracking for end dates and card issuance steps.
- File before the notification expires (through late 2026). The safe approach is to file well before the earlier of the notification end date or December 31, 2026, so payroll and insurance do not break.
- Keep proof and audit files (ongoing). Store confirmations, printouts, and ZUS evidence in the employee’s file, because inspections focus on whether work and insurance were continuous.
“Phasing out” sounds soft, but operationally it means HR teams must stop treating notifications as a long-term solution and start treating them as a short runway. Workers should also expect employers to ask for updates more often, because end dates now carry higher stakes.
Benefits, healthcare, and why ZUS-linked work will matter more
Poland’s draft approach also tightens the link between benefits and insured work. Eligibility for the “800+” child allowance and other social benefits is being tied more strictly to formal employment and payment of ZUS (social insurance) contributions.
For families, this is where an employment document becomes more than a work issue. If employment or insurance coverage breaks, the effects can show up in healthcare access and family support, not only in payroll.
The draft framework also changes employer burden in ways that workers will feel. Employers that could previously hire with a quick electronic step must now plan for:
- Longer lead times that include document checks and, for residence-based routes, biometrics.
- A higher administrative load, including compliance tracking and document management.
- Higher costs than simplified registration, including government fees and internal HR time.
The source figures illustrate the direction clearly. Standard residence permit fees range from PLN 400 to PLN 800, described as roughly four times the previous cost of simplified registration.
Even when workers pay the fee themselves, employers often absorb indirect costs through lost work time, extra HR staffing, and professional support. Uninsured adults face the sharpest pressure points.
The draft framework anticipates narrowed access to healthcare and family benefits starting in mid-2026 for people not in formal employment and not paying into ZUS. That creates a real-world incentive: fix authorization and insurance early, because catching up later can involve gaps that are hard to explain to agencies.
U.S. updates: important context, but they do not authorize work in Poland
Many Ukrainian families in Poland also have U.S. options in mind, through relatives, sponsors, or later moves. Those pathways matter, but they do not change Polish work authorization rules.
In the United States 🇺🇸, USCIS announced on July 7, 2025 an automatic extension tied to Ukraine TPS employment authorization documents. The agency said: “USCIS has automatically extended through April 19, 2026, the validity of employment authorization documents (EADs) issued under the TPS designation of Ukraine with an original expiration date of April 19, 2025, or Oct. 19, 2023.”
That extension helps eligible people keep working in the United States 🇺🇸, but it has no legal effect on work eligibility in Poland. U.S. agencies also announced an employment-related change that sometimes gets mixed into Ukraine conversations.
On January 30, 2026, DHS and the Department of Labor announced a temporary final rule increasing the H-2B visa cap by 64,716 for Fiscal Year 2026. H-2B is a U.S. temporary program for certain non-agricultural jobs. It does not create work rights in Poland, and it does not replace Polish permits.
The clean rule is jurisdiction. Poland decides who can work in Poland under Polish and EU law, regardless of U.S. benefits or U.S.-issued documents.
Where to verify rules, dates, and agency instructions without getting misled
These frameworks move fast because drafts, parliamentary review, and agency implementation do not always align on the same day. Readers should rely on official pages for the most current versions, and check “last updated” stamps when available.
Use the EU source for EU Temporary Protection extension context, not for Polish permit mechanics. The EU Council’s public record is available through the European Council Newsroom, including the June 13, 2025 decision referenced in reporting.
Use Poland’s Interior Ministry channels for the national legislative track and implementing guidance. The draft process and updates are typically routed through the Poland Ministry of Interior (MSWiA) portal.
Use ZUS for benefits and insurance rules, especially when agencies ask for insured status proof. The starting point for many Ukrainian-focused explanations is the ZUS guidance page.
For U.S. TPS verification, use the USCIS country page, because it carries the agency’s current language on eligibility and EAD validity. The official reference is USCIS’s Ukraine TPS page.
Across all systems, the best habit is recordkeeping. Save confirmations, download receipts, and keep printed copies of filings and approvals.
When rules change, proof of what you filed and when often decides whether a transition stays smooth or becomes a dispute over gaps in status, work, or insurance coverage.
