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On June 1, 2025, some of the most significant changes in Polish immigration law in recent years came into force. The new regulations aim not only to streamline procedures related to the employment and legalization of foreigners’ stay in Poland but also to align Polish national laws with EU standards. Their implementation is a response to the growing needs of the Polish labor market, changing demographic conditions, and the increasing number of foreigners settling and working in Poland. The reforms also include enhanced protection of workers’ rights and new powers for the Polish Border Guard and the National Labour Inspectorate.
The changes in Polish immigration law were introduced through a package of four Polish acts:
Under the new Polish rules, all applications related to the legalization of employment of foreigners — including applications for work permits and declarations of employment — must be submitted exclusively in electronic form via a dedicated ICT system. Applications submitted in any other form will be left unprocessed (Article 8(2)–(5) of the Polish Act on the conditions for the admissibility of employing foreigners).
The system also handles the submission of explanations, appeals, the transmission of documentation, and the delivery of decisions and correspondence — all via an individual user account (Article 72 of the Act). The purpose of these changes is to simplify procedures, reduce waiting times for decisions, and limit bureaucracy.
Employers in Poland will be required to submit a copy of the signed employment contract with the foreigner before the work begins — this applies both in cases where a work permit is required and when a declaration of employment has been registered. The new obligations also apply to foreign companies posting workers to Poland.
If the foreigner does not take up employment or terminates it before the declared date, the employer must notify the relevant Polish authority. Consequently, the authority will invalidate the declaration or revoke the issued work permit.
Digitization will also extend — at a later stage — to procedures for legalizing residence in Poland. Public institutions have two years to implement these solutions. Until then, residence proceedings will continue under the current Polish rules.
The new Polish regulations concerning the legalization of employment for foreigners simplify the previously existing procedures. One major change is the removal of the obligation to examine the local labor market and to obtain the so-called starosta’s opinion prior to issuing a work permit. This requirement has been replaced with lists of shortage occupations, determined at the county (powiat) level based on factors such as unemployment rates and the number of mass layoffs.
For these listed occupations, the employment of foreigners will be restricted. The aim is to better protect Polish workers and adapt more dynamically to labor market changes. These measures come as a response to the growing number of mass layoffs in Poland — more than 37,000 were reported in 2024, and the beginning of 2025 suggests that this trend is continuing. Nevertheless, the new regulations do not provide additional protection for foreigners, who may also be subject to dismissal.
As of June 1, 2025, significant changes in Polish immigration law include reforms to the EU Blue Card scheme in Poland. The amendment to the Polish Act on Foreigners introduces solutions intended to increase the flexibility and attractiveness of this residence and work permit for highly qualified non-EU professionals.
Key modifications include:
Below is a comparative summary of the legal framework before and after the reform:
| Requirements | Before June 1st of 2025 | After June 1st of 2025 |
| Minimum contract period | Min. 12 months | Min. 6 months |
| Intra-EU mobility | Not available | Possibility to work in another EU country for up to 90 days within 180 days without additional permits (short-term mobility); long-term mobility requires a permit |
| Conducting business | Prohibited | Allowed within the scope of the Blue Card held (issued before and after 1.06.2025) |
| Form of the decision | Includes details of the employer and the position | No indication of the employer or the position |
| Change of employer/position (holders <2 years) | Requires change of decision | Possible without change of permit (as long as work still in skilled occupation and with adequate remuneration) |
| Minimum salary (for applications in 2025) | No uniform threshold specified | Not less than PLN 12,272.58 gross/month |
| Information obligations to the Governor s | Change of working conditions/employer or loss of job – within 15 working days | Obligation to report: loss of job, change of employing entity, loss of qualifications or start of long-term mobility |
| Protection period after job loss | 90 days | 6 months (for Blue Card holders for at least 2 years); before 2 years – no change |
| Paper submission mode | Paper | Electronic only – remote submission and insight into case status |
These changes in Polish immigration law represent a significant step toward increasing the accessibility and functionality of the EU Blue Card in Poland, supporting mobility, entrepreneurship, and the influx of qualified professionals into the Polish labor market.
The new Polish regulations significantly increase penalties for the illegal employment of foreigners. The basic fine for employers now ranges from PLN 3,000 to PLN 50,000 per illegally employed foreign national (Article 84(1) and (13) of the Polish Act on the Conditions for the Admissibility of Employing Foreigners in the Territory of the Republic of Poland). This means that penalties will be imposed proportionally to the number of violations identified, rather than – as was previously the case – as a single lump sum regardless of the scale of the breach.
For comparison: the previous maximum fine was PLN 30,000, regardless of how many foreigners were employed illegally.
Example: In the case of 10 illegally employed foreigners, the minimum fine would amount to PLN 30,000, while the maximum could reach PLN 500,000.
Additional penalties – of up to PLN 6,000 per person – are foreseen in more serious cases, such as misleading a foreigner, demanding financial gain in exchange for assistance with legalization procedures, or submitting false declarations.
The law also introduces penalties for the foreigner – no less than PLN 1,000 – for taking up work without the required permits.
Employers in Poland should pay particular attention to employment documentation, including the validity and authenticity of foreign workers’ documents. In case of doubt, they are advised to consult the public PRADO register (Public Register of Authentic Identity and Travel Documents Online), the Polish Border Guard, or a legal employment specialist.
At the same time, the powers of the National Labour Inspectorate and the Polish Border Guard have been expanded. As of June, inspections can be carried out without prior notice, increasing the likelihood of detecting illegal employment. Inspectors have also gained the authority to impose administrative fines of up to PLN 10,000 without court involvement, particularly for violations specified in Article 84 of the Act.
These changes are aimed not only at increasing the effectiveness of inspections but also at encouraging employers to properly prepare, manage, and store documentation related to the employment of foreigners. A failure to exercise due diligence may result in serious legal and financial consequences, including the loss of the right to continue employing foreign nationals in Poland.
The changes in Polish immigration law introduce introduce digitization and simplification of procedures — applications and documents are now submitted online, and the labor market test has been abolished. This demonstrates a gradual evolution of the Polish system. At the same time, new obligations, harsh penalties, and more grounds for permit refusal mark a truly revolutionary shift. Whether the process becomes easier or more difficult remains to be seen in practice.
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