The authorities invoked this regulation to justify their protracted action or inaction. This further prolonged, and in some cases still prolongs, the already considerable waiting time for an administrative decision in some provinces.

The Supreme Administrative Court, in judgements dated 13 June 2025 (II OSK 2939/24 and II OSK 2940/24),  nevertheless took a clear position favourable from the perspective of the foreigners, according to which the limitation of administrative deadlines for the period after 30 June 2024 was no longer justified by the constitutional, treaty and convention rationale of the need to limit the right to court over inaction or protracted proceedings.

Thus, the inaction of authorities or the protraction of cases after 30 June 2024 should be evaluated with consideration events occurring since 1 July 2024, thus creating the possibility for applicants to effectively complain about further tardiness of administrative authorities in their residence cases.

In accordance with the justification of the NSA judgements:

• the limitation of administrative deadlines under the Ukraine special law, in principle, took place with proportionality in view of the emergency situation and the massive influx of people from Ukraine after the war began on 24 February 2022,
   
• solutions of this type, i.e., conditioned by emergency situations, can be considered proportionate as long as these situations persist (at the appropriate level of intensity),
   
• since the massive influx of people to Poland due to the war has indeed slowed (as evidenced by statistical data), and the authorities have had more than two years to adjust their rules for serving the public to be able to implement the principle of speedy administrative proceedings, the extension of art. 100d of the Ukraine special law beyond 30 June 2024 was no longer really justified.