End of the Ukrainian Special Act in Poland – what it means for employers

On 19 February 2026, the President signed an act phasing out the extraordinary solutions introduced under the so-called Ukrainian Special Act. The new rules are expected to apply from 5 March 2026, marking a shift from emergency measures in force since 2022 to system-based regulations for foreigners benefiting from temporary protection in Poland.

For employers, the key point is that the change is designed to organise the legal basis for residence and work without creating a gap that could lead to interruptions in employment. The days ahead should be used to review documentation and adjust HR and payroll processes to the new framework.

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Why this matters for employers in Poland

Over the last few years, many organisations relied on the Ukrainian Special Act when hiring Ukrainian nationals — often using simplified administrative duties.

The phase-out does not necessarily mean employers must replace employment bases overnight. However, it increases the importance of:

• maintaining consistent records of residence statuses and work entitlements,
• tracking deadlines and notification obligations,
• assessing risk in non-standard cases (changes in employment conditions, postings/assignments, longer travel outside Poland).

In practice, the biggest risk is rarely the wording of the rules themselves, but the lack of a repeatable, auditable system that allows a company to demonstrate compliance during inspections.

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What changes from 5 March 2026 – key issues for companies

1) Moving to system-based rules for temporary protection

The new act is intended to move away from a separate legal regime dedicated only to Ukrainian nationals and to anchor the core mechanisms in system legislation on temporary protection in Poland. For HR teams, this means stronger reliance on verifying residence status and the right to work, similar to processes applied to other foreign nationals.

2) Employment continuity and protection of prior actions

From the employer perspective, it is crucial that the regulations are expected to preserve the effects of actions taken before 5 March 2026 (including notifications already submitted). This reduces the risk of sudden employment breaks—while still requiring companies to tidy up data and documentation.

3) “Notification of entrusting work” – administrative duty and penalties

The act is expected to keep the notification of entrusting work mechanism as a simplified access route to the Polish labour market for Ukrainian nationals under temporary protection. In the transition period, this notification route is also expected to apply to assigning work to Ukrainian citizens who are legally staying in Poland.

Failure to submit the notification is not meant to automatically determine that the work assignment is illegal, but it may be punishable by a fine of PLN 1,000 to PLN 3,000. For companies, the practical risk shifts toward administrative compliance and process quality (timeliness, data completeness, alignment between the notification, the contract, and actual working conditions).

4) Postings and longer business travel – a key risk for temporary protection beneficiaries

A major operational risk concerns travel outside Poland. The legislation provides that temporary protection may expire if a beneficiary leaves Poland for more than 30 days. In practice, posting an employee under temporary protection (or longer work outside Poland at a client site) should be assessed in advance — otherwise the person may lose status and require a different residence route.

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What remains in place and how to plan for 2026–2027

Temporary protection – the planning horizon

The act assumes temporary protection will be maintained until 4 March 2027. For employers, this is an important operational horizon: it creates time to plan longer-term residence solutions for selected employees (for example, moving toward standard residence permits), without urgent, last-minute action.

PESEL UKR and status verification – implications for HR processes

In day-to-day HR practice, employers should continue to rely on robust verification of residence grounds and documents confirming temporary protection. The legal framework also clarifies formal requirements in selected situations, including cases requiring additional identity confirmation at the municipal office (urząd gminy). As a result, onboarding and ongoing employment procedures should be updated to keep documentation consistent and reduce employer-side risk.

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Common organisational gaps employers face during regulatory change

When regulations change, the same issues typically surface:

• no central register of residence statuses and document expiry dates,
• inconsistencies between HR, line managers, and HR/payroll data (role, work location, working time, contract type),
• no clear standard for assessing whether a change in working conditions triggers additional steps for work/residence legality,
• postings and business travel managed without checking the impact on temporary protection status,
• ad hoc employee communication without clearly assigned roles and responsibilities.

The consequences are not only penalties, but also operational risks: employment disruptions, team tension, higher turnover, and the cost of corrective actions.

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How to prepare your organisation before 5 March 2026

1) Review residence statuses and work entitlements

• identify employees under temporary protection and those using other residence titles,
• check documents in personnel files and data consistency in HR/payroll systems,
• flag higher-risk groups (postings, unclear status, gaps in documentation continuity).

2) Standardise notifications and employment-change workflows

• assign clear roles: who files notifications and who verifies them,
• define a consistent data standard (aligned job title/working conditions),
• implement a process for handling changes in working conditions to avoid legalisation risks.

3) Business travel/posting policy for temporary protection beneficiaries

• require pre-checks for every posting/trip with a risk of exceeding 30 days outside Poland,
• where necessary, plan an alternative residence/work basis in advance.

4) Internal communication to reduce turnover

• provide a short briefing for managers and employees: what changes, how the company will operate, where to report travel and changes,
• appoint a stable internal contact point responsible for communication consistency.

If your company employs foreign nationals and wants to put employer-side processes in order, getsix® can support you with legalisation of residence and work and ongoing HR and payroll administration in Poland.

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The end of the Ukrainian Special Act in Poland does not have to destabilise employment — but it does require process readiness. Employers should focus on practical actions: reviewing statuses, improving notification quality, controlling postings/travel, and ensuring HR and payroll data consistency. This approach reduces the risk of fines, employment gaps, and issues during inspections.

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Legal basis

• Act of 23 January 2026 on phasing out solutions resulting from the act on assistance to Ukrainian citizens in connection with the armed conflict on the territory of that state, and amending certain other acts.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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