Will the current regulations on the employment of foreigners expire on 1 December 2025?
The beginning of December marks the end of the six-month period for replacing the executive acts governing the employment of foreigners, which were issued on the basis of the Employment Promotion and Labour Market Institutions Act (this deadline was established in Article 113 of the Conditions for the Admissibility of Entrusting Work to Foreigners on the Territory of the Republic of Poland Act, which came into force on 1 June 2025).
As of 20 November 2025, most of the new regulations had not yet been issued. If they are not issued and do not enter into force before the deadline, the existing regulations will expire on 2 December 2025, resulting in a temporary regulatory gap.
The new executive acts should specify:
- What documents are required to obtain a work permit or to enter a declaration of entrusting work to a foreigner in the register?
- In what specific cases may a foreigner who is entitled to stay in the Republic of Poland work without a work permit or a declaration of entrusting work to a foreigner?
- In what types of activity are seasonal work permits issued?
- Citizens of which countries may be affected by declarations on entrusting work to a foreigner and other solutions concerning seasonal work permits?
- How much do the fees for an application for a work permit or a declaration on entrusting work to a foreigner cost?
- A template of the application form for a foreigner’s temporary residence permit and attachments, together with a description of the submission procedure.
Employers hiring foreign nationals can therefore expect either intensive updates to procedures and changes in the situation of some foreign employees in the coming weeks, or serious doubts arising from potential gaps in the regulations.