New Legal Framework for Employment of Foreigners and Labour Market

On 1 June 2025, Poland rolled out a new legal framework for employing foreigners, and replaced the previous Labour Market and Employment Services Act. The reform promises modernisation, digital processes, and a crackdown on market abuse.

But with change comes uncertainty. While many obligations remain, new rules have sparked questions about their scope, interpretation, and the disconnect between legislative intent and enforcement. A recent letter from the SME Envoy (Rzecznik MŚP) to the Minister of Labour, Family and Social Affairs suggests that what was promised in theory may differ in practice, potentially requiring official clarifications or amendments.

In this evolving landscape, staying compliant means staying alert and proactive. Below is a summary of the key changes to help you navigate the new regulations.

Employment Agencies – Fight Against Malpractice

• Foreign (EU) entrepreneurs that under previous regulations provided job placement and temporary work services in Poland based on an entry in the Register of Foreign (EU) Entities are now required to register with the National Register of Employment Agencies (KRAZ). New registration should be undertaken by September 2025.
• Entities offering only HR consulting and career advice are no longer required to register in KRAZ.
• Stricter requirements for providing services to foreigners apply and agencies can start providing their services to foreigners only two years after registration.
• Most agencies (with the exception of those that solely collect and provide job vacancy and job seeker information via online systems) must ensure direct client contact at their premises and keep documentation on-site.
• Foreign entrepreneurs must designate a representative in Poland.
• Penalties for illegal job placement have been significantly increased (up to PLN 100,000).

New Forms of Employment Support

Entrepreneurs benefit from expanded support: grants and loans for micro family businesses, subsidies for hiring retirees, and broader access to the National Training Fund, now available to all social security contributors including sole proprietors.

For example, new subsidies have been introduced for employing jobseekers who have reached retirement age and were not employed by the company directly before that. The subsidy covers up to 50% of the minimum wage for one month, alternating with a month without subsidy.

Additionally, digital solutions such as the fully online ePraca platform will make job offer submissions and recruitment processes easier both jobseekers and employers.

Employment of Foreigners – Host of New Obligations & Restrictions

• Visas issued for family visits, education purposes (other than studies), medical stays, or from other Schengen countries no longer permit legal employment. This restriction applies also to the employees who obtained a permit prior to the entry into force of the new regulations.
• The entire work permit and employment declaration process will be fully electronic. All e-submitted documents must be signed with one of the following e-signatures: a qualified electronic signature, trusted profile (EPUAP) or a personal e-signature (a type of advanced e-signature; podpis osobisty).
• Repeated applications (same employer, same employee) and certain other applications, in particular for jobs disclosed by the ministry as jobs with labour shortages, will be fast-tracked.
• The labour market test has been abolished – in exchange, local authorities may now publish lists of job types that are ineligible for work permits.
• New obligations of employers include submitting a signed written contract concluded with the foreigner to the authorities before work begins (if applicable, together with a sworn translation) and providing written notice informing employees of their right to join trade unions.
• Revised notification deadlines:
  • Foreign employment declarations – commencement must be reported within 7 days of starting employment, while non-commencement within 14 days of the day reported to the authorities as the planned commencement date;
  • Work permits – non-commencement (within 2 months of planned commencement), long breaks (over 2 months), or early termination (more than 2 months before expiry) must be reported within 7 days.
• Provided they legally reside in Poland, citizens of Ukraine, Belarus, Moldova, Georgia, Armenia, Bangladesh, and Nepal may use a simplified declaration-based employment procedure for up to 24 months.
• Work permits must be refused if the employer has outstanding unpaid taxes or social security contributions – this is now a mandatory condition for rejection.
• Penalties for illegal employment now range from PLN 3,000 to PLN 50,000 per foreign worker. Smaller violations (e.g. missing contract translations) may still incur penalties of PLN 1,000-3,000.
• A 7-days prior notice is no longer required to commence the inspection.
• The National Labour Inspectorate (Państwowa Inspekcja Pracy) and Border Guard Service (Straż Graniczna) can now impose fines up to PLN 10,000.

For detail and more business law, please get in touch with our experts Justyna Jóźwiak and Emilia Łowczyk.