Immigration

Poland | Major regulatory changes effective 1 June 2025

Summary

Significant changes to Poland’s immigration framework will come into force on 1 June 2025, following the publication of four key legislative acts. The new rules aim to simplify procedures, strengthen compliance, and align immigration policy with labour market needs. However, they also introduce new employer obligations, tighter controls, and operational challenges that require companies to prepare accordingly.

The detail

Poland has officially published new immigration legislation that will come into force on 1 June 2025. The new legal framework represents a significant overhaul of the rules governing the employment, stay, and entry of foreigners in Poland. These changes will affect both employers and foreign nationals across multiple stages of the immigration process.

Below is a summary of the three key legislative acts and the main updates they introduce:

1. Act on the conditions for employing foreigners in Poland

This new standalone act replaces existing provisions on work permits and introduces a number of structural changes. These changes will likely simplify processes and improve efficiency, but some of them may also create additional administrative burdens for employers. Overall, the reforms strike a mixed balance between facilitation and tighter control, depending on the employer’s sector and workforce profile. The changes are as follows:

• Digitalisation of work permit procedures – key procedures will be moved online, with communication taking place through electronic platforms.
• Removal of the labour market test – this long-criticised requirement will be eliminated to streamline access to the labour market.
• List of excluded occupations – a new list of job types that are ineligible for work permits will be introduced.
• Mandatory submission of signed employment contracts – employers will be required to upload employment contracts before work begins.
• Shorter deadline for reporting failure to start work – the notification period is reduced to 2 months.
• Expanded list of residence documents not permitting work – includes limitations for nationals of visa-free countries and Schengen visas.
• No extensions of existing work permits – employers must apply for new permits instead of extending old ones.
• Remote work limitations – only incidental remote work will be permitted without a specific work permit.
• Priority processing for strategic sectors – work permit applications for selected industries/professions will be fast-tracked.
• Redefined corporate links for posted workers – clarifies what constitutes a valid capital link for secondments.
• Higher penalties for non-compliance – fines for illegal employment may reach up to PLN 50 000. 

2. Amendments to the act on foreigners and related legislation

This package introduces long-awaited changes to the residence permit process, with a focus on efficiency and simplification. This includes modification of the EU Blue Card system to bring it in line with the objectives of the ‘recast’ EU Blue Card Directive (please find our alert here) through the following changes:

• Minimum employment contract: 6 months.
• Decisions will not include employer’s name or job title, therefore Blue Card holders granted under the new regulations will gain an open access to the labor market in Poland.
• Elimination of the amendment procedure for residence decisions.
• Only 3 years of experience is required (down from 5) for selected professions.
• No need to report position changes with the same employer for Blue Card holders granted under the new regulations.
• 3 to 6 months of protection after job loss.
• New opportunities for long and short term mobility.

3. Amendments related to visa system oversight

 The goal of this act is to enhance integrity and reduce abuse in the visa and student migration systems. The measures outlined in the new legislation are:

• Immediate notification obligation for removed students – schools must report individuals struck from student lists without delay with a consequence of cancelling the residence permit.
• Visa-based stay limitations – certain visas will no longer qualify for residence permits based on employment.
• New language proficiency rules – post-secondary diplomas will no longer prove Polish language ability for a long term residence or citizenship. Minimum B2 level required in the language of instruction for student permits.

What it means

These reforms reflect the direction laid out in Poland’s 2025-2030 Migration Strategy we discussed in our previous alert available here, aiming to modernise processes, ensure better oversight, and improve integration. However, the new laws also raise significant questions – especially around how new systems will function in practice, what constitutes acceptable documentation, and how quickly the administration will adapt.

There is particular uncertainty around the updated system for electronic residence permit applications (MOS 2.0), including its accessibility, user experience, and the role of legal representatives. An amendment in this respect is planned in the upcoming months and will have a key impact on the process and technical aspects of the procedure.

For employers, the new law provisions mean:

• Increased need for early planning and documentation.
• Stricter reporting obligations and compliance checks.
• Need to understand the upcoming new digital procedures and system usage.
• Opportunity for faster processing in selected cases – but also risk of delays during the transition.

How we can help

With the new regulations taking effect on 1 June 2025, employers may need to adapt processes and reassess risks quickly. Vialto Partners can support you with:

• Compliance audits and risk reviews
• Training sessions for HR and mobility teams
• Workshops on the new obligations and procedures
• Immigration compliance
• Strategic advisory on work permit planning and staffing models
• Individual employee consultations

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Jadwiga Chorązka
Partner

Emilia Piechota
Managing Director

Jakub Skrzypek
Manager

Want to know when a Regional Alert is posted?

Simply follow our Vialto Alerts page on LinkedIn and posts will be displayed on your feed. To ensure you don’t miss one, once you’re on our LinkedIn page, click on the bell icon under the banner image to manage your notifications.

Further information on Vialto Partners can be found here: www.vialtopartners.com

Vialto Partners (“Vialto”) refers to wholly owned subsidiaries of CD&R Galaxy UK OpCo Limited as well as the other members of the Vialto Partners global network. The information contained in this document is for general guidance on matters of interest only. Vialto is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will Vialto, its related entities, or the agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

© 2025 Vialto Partners. All rights reserved.