Poland: Extensive Reforms Include Digital-Only Rule for Residence Permits and Work Permit Exemption Restrictions

Digital portal for residence permits. 

• All residence permit applications will soon need to be filed digitally via the dedicated government system. In-person applications will cease being accepted. The effective legal date for this reform currently remains uncertain, but is expected at some point in early 2026. 

• Applicants will need to create individual accounts, and signing the application will require an electronic signature. Attachments provided by employers will also need to be signed electronically.  

Employers should prepare for a full transition to digital workflows for residence permit applications and ensure both human resources teams and foreign employees are equipped to handle electronic submissions and e-signature requirements. 

Georgia loses “Special Permission” status. 

• Effective December 1, 2025, Georgian nationals must now adhere to the standard work permit application process. Previously they were eligible for so-called “Special Permission” status, a type of work authorization that requires less documentation and is issued significantly quicker than a standard work permit (seven to 14 days as opposed to two to six months).  

• “Special Permission” statuses issued to Georgian nationals prior to December 1, 2025 remain valid.  

• Following this change, “Special Permission” status is now only available to nationals of Armenia, Belarus, Moldova and Ukraine.  

Employers of Georgian nationals should anticipate a longer and more complex procedure for work permit applications. Onboarding schedules may need to be revised.  

Work permit exemptions, 

• Effective December 1, 2025, work permit exemptions now only apply to full-time students of eligible universities – either expressly approved universities or universities exempted from the approval requirement (such as public academic universities).  

• Previously, the work permit exemption applied to full-time students of any Polish university.  

• Transitional provisions allow students currently working under the old rules to continue for up to six months. 

• Previously, employers were only required to verify whether the student had full-time or part-time status. Now, in order to apply the exemption, employers will also need to check the eligibility of the university.  

• Employers should review the status of employees who are currently subject to this work permit exemption, and determine if they will continue to satisfy the new criteria once the transitional provisions expire. Depending on the situation, employers may need to consider obtaining work authorizations for affected employees.