• Insights

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

December 12, 2025

insight-news-default

Country / Territory

  • PolandPoland

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • Poland has announced extensive immigration reforms, including:
    • Introducing a “digital-only” rule for submission of residence permit applications, expected from January 2026;
    • Removing Georgian nationals’ eligibility for “Special Permission” status;  
    • Restricting university student work permit exemptions; and  
    • Increasing application fees and introducing new documentary requirements.  
  • The digitization efforts are part of broader attempts to accelerate processing times, with case delays increasing steadily since 2017.  
  • The effective legal date for the digital portal reforms currently remains uncertain, though is expected at some point in early 2026. However, even if formally implemented in early 2026, practical implementation is expected to take longer – including stretching into 2027. 

The situation 

Poland has introduced extensive immigration reforms, including introducing a “digital-only” rule for submission of residence permit applications (expected from January 2026); removing Georgian nationals’ eligibility for “Special Permission” status; and restricting university student work permit exemptions.

A closer look 

DETAILS 

IMPACT  

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. 

Other changes include:  

  • Fees. The fee landscape is shifting as follows:
    • Effective December 1, 2025, application fees changed as follows:  
      • Locally hired employees. PLN 400, up from PLN 100 – a 300% increase. 
      • Posted employees. PLN 800, up from PLN 100 – a 700% increase.
    • Effective January 1, 2026, consular fees for visa applications will increase, including:
      • National visa (type D). Increase to EUR 200, up from EUR 135.  
      • Schengen visa (type C). Increase to EUR 90, up from EUR 80. 
  • New forms for Residence Permit applications. Effective December 1, 2025, residence permit applicants must use new templates, and employers must provide a new attachment with the updated forms. Use of outdated forms may result in application refusals.  
  • Work permit applications. Effective December 1, 2025, in addition to pre-existing rules, work permit applicants must now submit copies of all completed pages of a foreign national’s passport and additional statements confirming compliance with the law. Additionally, authorities now have the power to request further documents or evidence to confirm circumstances relevant to the case; whereas previously they did not.  

Background 

The digitization efforts are part of broader attempts to accelerate processing times, with case delays increasing steadily since 2017. According to the government, the solutions should allow for faster processing.  

Looking ahead 

The effective legal date for the digital portal reforms currently remains uncertain, though is expected at some point in early 2026. However, even if formally implemented in early 2026, practical implementation is expected to take longer – including stretching into 2027. 

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen. 

Country / Territory

  • PolandPoland

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

UK Immigration Reforms and Their Impact on the Engineering Talent Pipeline

In this blog, Fragomen’s Nadine Barnole, Jonathan Hill, Anastasia Vasiljeva and Nicole Williams examine how higher Skilled Worker salary thresholds, rising sponsorship costs and proposed Graduate Route changes are making it harder for employers to attract and retain international engineering talent.

Learn more

Media mentions

Irish Examiner: Updates to Non-EU Work Permits Will Help Firms Fill Critical Roles

Practice Leader Colm Collins explains how Ireland's employment permit updates can help employers address workforce shortages while strengthening the country's ability to attract global talent.

Learn more

Blog post

Understanding EU-Turkey Association Rights for Workers and Families in Germany

Senior Associate Arta Djahanschiri and Associate Iris Barthel discuss how EU-Turkey Association Law, including Association Council Decision No. 1/80, can provide Turkish employees and their family members in Germany with residence and labor market rights that may extend beyond protections available under the German Residence Act.

Learn more

Media mentions

Konfederacja Lewiatan: Ekspertyza przedstawiająca skutki zmian legislacyjnych oraz ich praktyczne konsekwencje dla osób objętych ochroną czasową

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain Polish legislative changes affecting residence rights, employment authorization and long-term immigration pathways.

Learn more
Generic Insights

Media mentions

Deutscher AnwaltSpiegel: Internationale Rekrutierung ist eine Compliancefrage

Partner Marius Tollenaere and Associate Jamela Sharrock examine how employers in Germany can strengthen immigration compliance by embedding it into every stage of the employment lifecycle.

Learn more

Podcast

EB5: What Prospective Applicants Need to Know NOW!

In this episode of The Immigration Conversation, Partner Chad Blocker, Senior Counsel Mitchell Wexler and Associate Alex Kim discuss what prospective EB-5 applicants should know now, including source-of-funds documentation, project selection, concurrent filing, retrogression and upcoming program deadlines.

Learn more

Blog post

New EU Social Security Coordination Rules: What Employers Need to Know

In this blog, Partner Jo Antoons and Senior Manager Marina Ocariz discuss the EU’s provisional agreement on revised social security coordination rules and what employers should know about the expected changes to A1 certificate requirements, posted worker rules and short-term cross-border work compliance.

Learn more

Blog post

Approaching EB-5 Grandfathering Deadline: What Investors Need to Know Before September 30, 2026

In this blog, Partner Rahul Soni explains the EB-5 grandfathering provisions under the EB-5 Reform and Integrity Act of 2022 and why prospective investors should consider filing before the September 30, 2026 deadline to help preserve statutory protections and reduce exposure to future program uncertainty.

Learn more

Video

Do You Need a Visa for Thailand? Tourist Visa Rules Explained

In this video, Practice Leader Kate Praphakornphiphat explains the key requirements, documents, fees and processing time for a Thailand tourist visa, as well as stay duration and extension options for short-term travel. 

Learn more

Fragomen news

Fragomen and Talent Beyond Boundaries Named Co-Chairs of Global Task Force on Refugee Labour Mobility

Fragomen and Talent Beyond Boundaries announce that they will jointly serve as co-chairs of the Global Task Force on Refugee Labour Mobility for a two-year term beginning in June 2026.

Learn more

Blog post

From Barnsley to the North: AI Growth and the UK's Immigration Challenge

In this blog, Manager Gillian Gibbons and Immigration Consultants Gemma Oliver and Larna Kate Hadfield examine how Barnsley’s designation as the UK’s first government-backed Tech Town reflects wider AI and digital growth across the North of England, and why immigration strategy will be critical for employers seeking to access the global talent needed to support regional innovation.

Learn more

Media mentions

Hong Kong Business Magazine: Employers Seek Broader Immigration Reforms

In this Hong Kong Business article, Managing Director Magdalene Tennant discusses Hong Kong’s recent decision to allow employment and dependent visa renewal applications to be filed up to three months before expiry, a change intended to reduce the risk of work disruptions and provide employers with greater flexibility in managing foreign talent.

Learn more

Blog post

UK Immigration Reforms and Their Impact on the Engineering Talent Pipeline

In this blog, Fragomen’s Nadine Barnole, Jonathan Hill, Anastasia Vasiljeva and Nicole Williams examine how higher Skilled Worker salary thresholds, rising sponsorship costs and proposed Graduate Route changes are making it harder for employers to attract and retain international engineering talent.

Learn more

Media mentions

Irish Examiner: Updates to Non-EU Work Permits Will Help Firms Fill Critical Roles

Practice Leader Colm Collins explains how Ireland's employment permit updates can help employers address workforce shortages while strengthening the country's ability to attract global talent.

Learn more

Blog post

Understanding EU-Turkey Association Rights for Workers and Families in Germany

Senior Associate Arta Djahanschiri and Associate Iris Barthel discuss how EU-Turkey Association Law, including Association Council Decision No. 1/80, can provide Turkish employees and their family members in Germany with residence and labor market rights that may extend beyond protections available under the German Residence Act.

Learn more

Media mentions

Konfederacja Lewiatan: Ekspertyza przedstawiająca skutki zmian legislacyjnych oraz ich praktyczne konsekwencje dla osób objętych ochroną czasową

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain Polish legislative changes affecting residence rights, employment authorization and long-term immigration pathways.

Learn more
Generic Insights

Media mentions

Deutscher AnwaltSpiegel: Internationale Rekrutierung ist eine Compliancefrage

Partner Marius Tollenaere and Associate Jamela Sharrock examine how employers in Germany can strengthen immigration compliance by embedding it into every stage of the employment lifecycle.

Learn more

Podcast

EB5: What Prospective Applicants Need to Know NOW!

In this episode of The Immigration Conversation, Partner Chad Blocker, Senior Counsel Mitchell Wexler and Associate Alex Kim discuss what prospective EB-5 applicants should know now, including source-of-funds documentation, project selection, concurrent filing, retrogression and upcoming program deadlines.

Learn more

Blog post

New EU Social Security Coordination Rules: What Employers Need to Know

In this blog, Partner Jo Antoons and Senior Manager Marina Ocariz discuss the EU’s provisional agreement on revised social security coordination rules and what employers should know about the expected changes to A1 certificate requirements, posted worker rules and short-term cross-border work compliance.

Learn more

Blog post

Approaching EB-5 Grandfathering Deadline: What Investors Need to Know Before September 30, 2026

In this blog, Partner Rahul Soni explains the EB-5 grandfathering provisions under the EB-5 Reform and Integrity Act of 2022 and why prospective investors should consider filing before the September 30, 2026 deadline to help preserve statutory protections and reduce exposure to future program uncertainty.

Learn more

Video

Do You Need a Visa for Thailand? Tourist Visa Rules Explained

In this video, Practice Leader Kate Praphakornphiphat explains the key requirements, documents, fees and processing time for a Thailand tourist visa, as well as stay duration and extension options for short-term travel. 

Learn more

Fragomen news

Fragomen and Talent Beyond Boundaries Named Co-Chairs of Global Task Force on Refugee Labour Mobility

Fragomen and Talent Beyond Boundaries announce that they will jointly serve as co-chairs of the Global Task Force on Refugee Labour Mobility for a two-year term beginning in June 2026.

Learn more

Blog post

From Barnsley to the North: AI Growth and the UK's Immigration Challenge

In this blog, Manager Gillian Gibbons and Immigration Consultants Gemma Oliver and Larna Kate Hadfield examine how Barnsley’s designation as the UK’s first government-backed Tech Town reflects wider AI and digital growth across the North of England, and why immigration strategy will be critical for employers seeking to access the global talent needed to support regional innovation.

Learn more

Media mentions

Hong Kong Business Magazine: Employers Seek Broader Immigration Reforms

In this Hong Kong Business article, Managing Director Magdalene Tennant discusses Hong Kong’s recent decision to allow employment and dependent visa renewal applications to be filed up to three months before expiry, a change intended to reduce the risk of work disruptions and provide employers with greater flexibility in managing foreign talent.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
June 30, 2026 | United StatesUnited States: Supreme Court Strikes Down Effort to Limit Birthright Citizenship
June 30, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
June 30, 2026 | New ZealandNew Zealand: In-Person English Language Testing Requirement Implemented
June 30, 2026 | New ZealandNew Zealand: Major Changes Announced for Skilled Migrant Category Resident Visa
June 30, 2026 | United Arab EmiratesUnited Arab Emirates: Multiple Changes to Visa-on-Arrival Program Affecting Several Nationalities
June 30, 2026 | United StatesUnited States: Supreme Court Strikes Down Effort to Limit Birthright Citizenship
June 30, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
June 30, 2026 | New ZealandNew Zealand: In-Person English Language Testing Requirement Implemented
June 30, 2026 | New ZealandNew Zealand: Major Changes Announced for Skilled Migrant Category Resident Visa
June 30, 2026 | United Arab EmiratesUnited Arab Emirates: Multiple Changes to Visa-on-Arrival Program Affecting Several Nationalities
June 30, 2026 | United StatesUnited States: Supreme Court Strikes Down Effort to Limit Birthright Citizenship
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.