Ukrainians and other foreign nationals in Poland after 5 March 2026: residence, business, employment

• FORTUNKA
• Foreign nationals
• September 10, 2026

On 5 March 2026 the act phasing out the arrangements of the special act on assistance to Ukrainian citizens came into force (Dz.U. 2026 poz. 203). It did not close the chapter in one move: temporary protection runs until 4 March 2028 (Council Implementing Decision (EU) 2026/1912), some provisions were moved into the act on granting protection to foreign nationals, and since 2025 employers' duties have been governed by a separate act on the conditions for permitting work to be entrusted to foreign nationals. Below we gather in one place what an employer, a business owner and the foreign national themselves need to know after 5 March 2026 — with references to the provisions.

What changed on 5 March 2026

The act of 23 January 2026 phases out the arrangements of the 2022 special act gradually. Some entitlements moved into the act of 13 June 2003 on granting protection to foreign nationals: the stay of beneficiaries of temporary protection is legal for as long as the Council of the EU decision remains in force (art. 106 sec. 1 of that act) — after Council Implementing Decision (EU) 2026/1912, until 4 March 2028 — and their right to work without a permit and to run a business depends on it as well. The date of 4 March 2027 remains, among other things, for the application for the CUKR residence card (art. 42x of the special act). Some provisions only come into force on 1 January, 5 March and 1 September 2027, and some on the date given in an announcement. So it is not true that “the special act was repealed” — it is being phased out in stages.

Residence: legal for as long as the Council of the EU decision is in force

The stay of people covered by temporary protection (a PESEL with UKR status) who entered Poland legally during the period specified in the Council of the EU decision and in order to use temporary protection is recognised as legal under art. 106 sec. 1 of the act on granting protection to foreign nationals for as long as that decision remains in force — after Council Implementing Decision (EU) 2026/1912, until 4 March 2028. Until 4 March 2027, residence documents, visas and temporary residence permits of Ukrainian citizens that expired earlier remain valid by operation of law. A person who is only now arriving in Poland and wants to use temporary protection applies for a PESEL UKR within 30 days of crossing the border — in person, on a paper application, at any municipal office, with a valid travel document. After that deadline, protection is not available.

The CUKR residence card — applications from 4 May 2026

For people who want to stay in Poland longer than temporary protection lasts, there is the CUKR residence card. Applications can be filed from 4 May 2026 until 4 March 2027, only electronically through the Case Handling Module (MOS). The card is issued for 3 years and processing can take up to 180 days. The conditions: a stay recognised as legal under art. 106 of the act on granting protection to foreign nationals and, cumulatively — UKR status on 4 June 2025, UKR status on the day the application is filed and uninterrupted UKR status for at least 365 days. The CUKR card gives full access to the labour market without a work permit and the right to run a business on the same terms as Polish citizens.

Business activity (JDG) after 5 March 2026

Since 5 March 2026, a new sole proprietorship (JDG) can be registered on the same terms as by Polish citizens by a Ukrainian citizen covered by temporary protection (PESEL UKR — for the whole period of temporary protection, after Council Implementing Decision (EU) 2026/1912, until 4 March 2028) and by people with a permanent residence permit, an EU long-term resident's residence permit, a Karta Polaka or another residence title that grants such a right. A temporary residence permit on its own is not enough — its type is what counts. Anyone who does not fall within this list can run a business only as a limited partnership, a limited joint-stock partnership, a limited liability company (z o.o.), a simple joint-stock company or a joint-stock company (art. 4 sec. 3 of the act of 6 March 2018). A Ukrainian citizen who registered a business in CEIDG before 5 March 2026 under art. 23 sec. 1 of the special act (legal stay and a PESEL number) continues to run it on the existing terms for the whole period of stay recognised as legal. When residence stops being legal, the CEIDG entry is subject to removal (by decision of the minister responsible for economic affairs) — so with every change of status it is worth checking straight away what happens to the business.

Employment: notify the PUP within 7 days

An employer hiring a Ukrainian citizen notifies the district labour office (PUP) within 7 days of the day work starts, through praca.gov.pl. Notifications filed before 5 March 2026 remain valid — they do not have to be repeated. A new notification is needed when the type of contract, the position or the type of work changes, or when working time or the rate of pay is reduced. Since 5 March 2026 this duty follows from the act of 20 March 2025 on the conditions for permitting work to be entrusted to foreign nationals, not from the special act.

Three years of the transitional provision

Ukrainian citizens staying in Poland legally but without temporary protection (for example on a temporary residence permit) may work on the basis of the PUP notification alone for another 3 years from the day the act came into force, that is from 5 March 2026 (Article 41 of the phase-out act; official sources give the end of this period as either 4 March or 5 March 2029). After that period a work permit or another title will be needed, as for other foreign nationals.

Penalties for the employer

Illegally entrusting work to a foreign national carries a fine of 3,000–50,000 PLN, and no less than 3,000 PLN for each foreign national; in aggravated cases (for example exploitation) the lower limit rises to 6,000 PLN. Failing to file the notification on time is a separate offence and is not treated as illegal employment: failing to notify the district labour office (PUP) of entrusting work to a person covered by temporary protection is punishable by a fine of 1,000–3,000 PLN, failing to notify the starost of the start or non-start of work on the basis of a declaration — 500–5,000 PLN, and failing to notify the authority that issued the work permit — a fine of no less than 500 PLN. A PIP (National Labour Inspectorate) inspection checks both.

What this means for your business

If you employ Ukrainian citizens: check that every employee has an active PESEL UKR or another residence title, and note the dates — 4 March 2028 for temporary protection, 4 March 2027 for the CUKR card application, 3 years from 5 March 2026 for the transitional provision. Check that your PUP notifications match the current contracts (position, working time, rate of pay). If you run a JDG as a foreign national: make sure your residence title gives you the right to run a business after temporary protection ends as well (after Council Implementing Decision (EU) 2026/1912 — after 4 March 2028), and apply for the CUKR card if you meet the conditions — by 4 March 2027 (art. 42x of the special act).

What we do for clients

As part of our services for foreign nationals we handle the legalisation of residence and employment: we check the employee's residence title, file PUP notifications on time and repeat them when the contract changes, keep the documentation that PIP inspects, and take care of A1 certificates and posting formalities. In payroll and HR we settle the pay and ZUS contributions of employees from abroad in the same way as everyone else's. We do not conduct residence card proceedings on an employee's behalf — we tell you what to file and where.

Frequently asked questions

Does a PUP notification filed before 5 March 2026 have to be filed again?

No — it remains valid, and a new one is only needed when the working conditions change.

Can a Ukrainian citizen with a PESEL UKR set up a JDG today?

Yes — on the same terms as Polish citizens, for as long as they are covered by temporary protection (art. 4 sec. 2 point 2 of the act of 6 March 2018 and art. 116 sec. 2 of the act on granting protection to foreign nationals), i.e. after Council Implementing Decision (EU) 2026/1912, until 4 March 2028; once it ends, another residence title granting this right is needed, such as the CUKR residence card (art. 42w of the special act).

Until when can an application for the CUKR card be filed?

Until 4 March 2027, only through MOS; one of the conditions is UKR status held for at least 365 days.

Sources

• Ustawa z dnia 23 stycznia 2026 r. o wygaszeniu rozwiązań wynikających z ustawy o pomocy obywatelom Ukrainy… (Dz.U. 2026 poz. 203)
• Ustawa z dnia 20 marca 2025 r. o warunkach dopuszczalności powierzania pracy cudzoziemcom (Dz.U. 2025 poz. 621)
• Zielona Linia — Pobyt i praca obywateli Ukrainy po 4 marca 2026 r.
• Zielona Linia — Zatrudnianie obywateli Ukrainy: przepis przejściowy
• Zielona Linia — Karta pobytu CUKR: można już składać wnioski
• biznes.gov.pl — Działalność gospodarcza obywateli Ukrainy
• Państwowa Inspekcja Pracy — Cudzoziemcy: ułatwienia w zatrudnieniu, wyższe sankcje
• Okręgowy Inspektorat Pracy w Gdańsku — Zatrudnienie obywateli Ukrainy: zmiany od 5 marca 2026 r.
• Straż Graniczna — Status UKR: zasady ochrony