The act phasing out the provisions of the so-called Special Act on Ukrainian citizens came into force
What changes can we expect due to the regulations changes?
1. Extension of legal stay until 4th of March 2027.
2. Ukrainian citizens legally residing in Poland but not covered by temporary protection will be allowed to be employed on the basis of notifications to the Labour Office (PUP) for another three years (transitional period)
3. In the event of leaving Poland for a period exceeding 30 days, Ukrainian citizens will automatically lose temporary protection.
4. By 26th of August 2026, Ukrainian citizens whose PESEL number was assigned based on a declaration must confirm their identity. Failure to do so will result in the loss of temporary protection.
5. Extension of the suspension of time limits in residence proceedings until 4th of March 2027.
6. A 30-day deadline from the date of arrival in Poland to submit an application for a PESEL number with UKR status. Failure to submit the application will result in the lack of temporary protection.
We would like to inform you that certain provisions of the new Act remain ambiguous, which may result in the need for clarification through amendments in the near future.
For example, Article 40 of the Act provides that if an employer submitted a notification on entrusting work to a Ukrainian citizen before the Act entered into force, the Ukrainian citizen will be able to continue working on the basis of that notification also after 5th of March 2026. At the same time, Article 41 stipulates that for a period of 3 years from the date the Act enters into force, Ukrainian citizens legally residing in the territory of the Republic of Poland who do not benefit from temporary protection will be allowed to work on the basis of notifications on entrusting work.
When analyzed together, the above provisions may raise interpretative doubts as to their scope and the relationship between the respective regulations. Therefore, it should be expected that these provisions may be clarified or amended in the near future.
We recommend monitoring the situation on an ongoing basis and consulting with our law firm in this regard. We will be pleased to support you in ensuring the lawful employment of Ukrainian citizens in compliance with applicable regulations.
Please contact our immigration expert for futher support:
Adrianna Bober
adrianna.bober@tias.pl
71 737 29 00
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