Starting June 1, 2025, a comprehensive set of regulations will come into effect, significantly changing the rules for hiring foreigners in Poland. The legislative reform covers both the legalization process for foreigners’ stay and work, as well as new obligations for employers and employment agencies.

What changes from June 1, 2025?

The changes are based on four new laws aiming to: 

• strengthen the system for legalizing the employment of foreigners, 
• reduce malpractice and exploitation within employment agencies,
• digitize administrative procedures, 
• align national regulations more closely with current labor market needs and EU legal standards.

A good starting point is conducting a comprehensive review of employment practices related to foreign workers. Contact us for assistance!

Employer obligations

Legal basis for stay in Poland

As of June 2025, it will no longer be possible to employ foreigners residing in Poland on the basis of a visa issued by another Schengen state or under visa-free travel (for selected nationalities). Employment will only be legal if the foreigner’s stay is based on a Polish residence permit. 

Stricter regulations on contracts with foreigners

Although civil law contracts will not be entirely banned, their use will be significantly restricted. In most cases, employing a foreigner will only be allowed under an employment contract. Flexible forms of employment will be limited mainly to seasonal work. 

Digitization of an employment process

Starting from June 2025, all applications for work permits and related documentation must be submitted exclusively online, through a dedicated IT system. Applications submitted in paper form will not be processed. 

New reporting obligations

Employers will be required to: 

• provide the employee with a copy of the contract in Polish before the employment begins, 
• notify the voivode (provincial governor) of: 
  – failure to start work within 2 months, 
  – a work break longer than 2 months, 
  – termination of employment before the permit expires, 
• notify the local labor office of employment status within specific deadlines: 
  – within 7 days of the foreigner starting work, 
  – within 14 days of them failing to take up the position. 

Restrictions for new companies and part-time employment

According to the new regulations, companies operating for less than 12 months or employing foreigners for fewer than 20 hours per week (i.e., part-time) will only be able to obtain work permits valid for up to one year. Previously, it was possible to receive permits valid for up to three years. The restrictions also apply to permits related to specific job functions and to foreigners posted to Poland. 

Ban on “employee outsourcing”

The new regulations explicitly prohibit so-called employee outsourcing, which previously allowed employers to circumvent labor laws. As of June 1: 

• assigning a foreigner to work by a non-licensed entity (i.e., not a staffing agency) will result in a fine of at least 6 000 zł per worker, 
• delegating a foreigner to work under the supervision of another entity (outside of legal temporary work arrangements) will be subject to a minimum fine of 3 000 zł. 

Additionally, at the beginning of 2025, the PKD code 78.30.Z was removed, eliminating the legal basis for using outsourced workers. Companies must now switch to process outsourcing – delegating an entire business process, not just workers. 

End of “foreign-owned shell companies”

Lawmakers have also ended the common practice of assigning work to foreigners in exchange for non-cash contributions (e.g., shares or stocks) in Polish companies. As of June 1, foreigners will no longer be allowed to conduct business activities in the form of a limited liability company (sp. z o.o.), a simple joint-stock company (P.S.A.), or a joint-stock company (S.A.) if this involves working or providing services in lieu of a monetary contribution. 

Higher penalties for illegal employment of foreigners

The new regulations significantly increase penalties. The minimum fine for illegal employment of a foreigner is 3 000 zł and may reach up to 50 000 zł. Each case is treated individually – the fine is imposed per foreign employee. 

Additional penalties of up to 6 000 zł per person apply for fraud or abuse (e.g., misleading workers, demanding bribes). 

How to prepare for new legal requirements?

To successfully adapt to the upcoming changes in employing foreigners, employers should take specific steps now. Here are three key actions to consider: 

1. Audit your foreign employment processes 

Start by thoroughly analyzing all existing contracts with foreign workers to ensure compliance with the new laws. Review internal HR practices, identify potential legal risks, and determine what changes—both formal and operational—are needed. 

2. Verify cooperation with employment agencies 

Next, carefully assess the employment agencies you work with. Ensure they have a valid entry in the National Register of Employment Agencies (KRAZ). Confirm whether your partners are preparing to meet the new legal standards. If needed, explore alternative recruitment sources to avoid disruptions. 

3. Reevaluate your employment model 

Finally, take a look at your current employment strategy for foreigners. Consider whether direct employment is more cost-effective and legally secure than outsourced models. Assess the risks associated with different forms of employment and adapt your recruitment and operational strategies accordingly. 

If you need additional support in accounting and hr &payroll services contact us!

Text based on: INFORLEX