Poland has reshaped its foreign worker compliance regime for 2026, combining full digitalisation of residence permit applications with sharply higher penalties for employers who get it wrong.
What Has Changed
All residence permit applications — temporary, permanent, and long-term EU resident — must now be submitted exclusively online through the new MOS II platform, ending paper-based filing entirely.
Employers face a new pre-employment reporting duty: work contracts for foreign employees must be reported before the employee starts, with a PLN 3,000 penalty per unreported case. Separately, fines for employing a foreigner without valid work authorisation have tripled, from PLN 10,000 to PLN 30,000.
The shortage occupations list has been expanded, letting employers hire into those roles under a simplified procedure that skips the labour market test — a meaningful speed advantage for qualifying positions. From 1 July 2026, employers must also obtain work permits for students from universities not on the ministerial exemption list, closing a gap that previously let some student hires bypass permits entirely.
Any change to a foreign employee's position, working hours, or remuneration now requires either a permit update or formal notification to the authorities. Separately, legal stay for Ukrainian citizens under UKR protection status, and those on visas or visa-free travel, has been extended to 4 March 2027.
What This Means for HR and Mobility Teams
The compliance bar has risen sharply. Missing the pre-start reporting deadline or letting a role change go unreported now carries real financial exposure at a per-case level, not a one-time risk.
Employers with student hires need to check the exemption list before assuming no permit is required — the July 2026 change closes a route many used previously without issue.
Action Steps
- Move all Polish residence permit filings to MOS II now — paper submissions are no longer accepted.
- Build pre-start contract reporting into onboarding checklists for every foreign hire, with the PLN 3,000-per-case penalty as the compliance trigger.
- Re-verify student hires against the current university exemption list before the July 2026 requirement catches an unpermitted hire.
- Flag any role, hours, or pay change for a foreign employee for immediate permit review, not end-of-year cleanup.
xpath.global's immigration and tax advisory team tracks Poland's MOS II rollout and reporting obligations directly, helping employers file correctly the first time and avoid the tripled penalty exposure introduced in 2026. [Speak to our team.](https://xpath.global)
"Sources: Grant Thornton Poland — 2026; Newland Chase — 2026."
