The influx of Ukrainian citizens into Poland, particularly intense after February 24, 2022, has presented new challenges but also created new opportunities for the Polish labor market. To facilitate the rapid integration and employment of people fleeing the war, special legal regulations were introduced. What regulations concerning access to the labor market for Ukrainian citizens are currently in force as of early April 2025?
Note: In this article, we use the common term “refugees from Ukraine” primarily referring to citizens of Ukraine covered by the so-called Special Act, not necessarily persons formally granted refugee status under the Geneva Convention.
The special act – Basis for facilitated access to work
The key legal act here is the Act on assistance to citizens of Ukraine in connection with the armed conflict on the territory of that state (the so-called Special Act or specustawa). Its purpose included, among others, maximally simplifying procedures related to legalizing stay and enabling swift employment for people fleeing the war.
Who is Covered by the Simplifications?
The special, simplified rules for accessing the labor market apply to:
- Citizens of Ukraine who legally entered the territory of Poland in the period from February 24, 2022, in connection with military actions in Ukraine.
- Their spouses (who are not citizens of Ukraine), provided they arrived in Poland directly from the territory of Ukraine in connection with the conflict.
- Persons whose stay in Poland is considered legal under Art. 2(1) of the Special Act (this is often confirmed by having a PESEL number with UKR status or the Diia.pl electronic document).
Work without a permit – The main rule for persons covered by the act
The most significant facilitation introduced by the Special Act is the possibility for eligible Ukrainian citizens to take up employment without the need to obtain a work permit.
This means that if a citizen of Ukraine meets the conditions of the Special Act (legal entry and stay), they do not need a standard work permit (Type A-S) or a declaration of entrusting work (oświadczenie) to work legally in Poland. They can take up employment with any employer under the same conditions as Polish citizens, provided their stay is legal under the Act and the employer fulfills the notification duty.
Employer’s key obligation: notification to PUP via praca.gov.pl
Although a work permit is not required, the Special Act imposes one key formal obligation on the employer:
- Notification of Commencement of Work: The employer must notify the competent District Labor Office (PUP) about hiring a Ukrainian citizen covered by the Special Act.
- Form: Notification must be submitted exclusively electronically, via the praca.gov.pl portal.
- Deadline: This must be done within 14 days from the date the Ukrainian citizen starts work. Missing this deadline is a critical error!
- Consequences of Non-Notification: If the employer fails to submit the notification within the required timeframe, the work of the Ukrainian citizen (even if their stay is legal) will be considered illegal. This carries the risk of high financial penalties for the employer.
The notification includes basic data of the employer, employee, and terms of employment (type of contract, position, place of work, salary, working hours).
Verification of legal stay – Before you hire
Remember, as an employer, you have the obligation before allowing work to commence to verify whether the Ukrainian citizen is indeed legally residing in Poland under the Special Act. Ask to see a document confirming this status (e.g., notification of PESEL UKR assignment, Diia.pl document, entry stamp after 24.02.2022) and keep a copy.
How long do these rules apply? The issue of temporary protection
The simplified access to the labor market for Ukrainian citizens is strictly linked to the period during which their stay in Poland is considered legal under the Special Act. This period stems from the EU Council’s decision to introduce temporary protection and Polish implementing provisions.
- Current Legal Status (April 2025): As of early April 2025, the regulations indicate that the stay of Ukrainian citizens covered by the act is legal until June 30, 2025. This means the simplified employment rules (work without a permit, based on notification) apply until this date.
- VERY IMPORTANT: This deadline has been extended several times and further extensions are possible, depending on the situation in Ukraine and decisions at the EU and national levels. Therefore, it is essential to strictly follow official announcements from the Polish Government, the Ministry of Interior and Administration (MSWiA), and the Office for Foreigners (UDSC) on this matter.
- What After Protection Expires? If the provisions of the Special Act expire and are not extended in their current form, Ukrainian citizens wishing to continue working in Poland will generally need to obtain standard work authorization documents (work permit or declaration) and regularize their stay (obtain an appropriate temporary residence permit), unless they qualify for other exemptions.
Ukrainians residing in Poland before Feb 24, 2022
It should be noted that Ukrainian citizens who were legally residing and working in Poland before February 24, 2022, based on standard visas or residence and work permits, generally remain subject to those standard procedures (unless they later acquired legal status under the Special Act).
Scenario: hiring a ukrainian woman with PESEL UKR
Ms. Olena arrived from Ukraine to Poland in March 2022 and has a PESEL number with UKR status. She finds a job in a clothing store starting May 1, 2025.
- The employer (store owner) verifies Ms. Olena’s documents – the UKR status confirms her stay is legal under the Special Act (currently valid until June 30, 2025).
- Ms. Olena starts work on May 1, 2025. She does not need a work permit.
- The employer has until May 15, 2025 (14 days) to log into the praca.gov.pl portal and submit the electronic notification about hiring Ms. Olena.
- Ms. Olena works legally. Both she and her employer should monitor information about potential extensions of the Special Act beyond June 30, 2025, to take necessary steps for obtaining standard permits if needed.
Need help understanding the regulations?
The rules for employing Ukrainian citizens, although simplified by the Special Act, can raise doubts, especially regarding the changing validity dates of temporary protection. Our law firm offers assistance:
- In verifying the current legal status of a Ukrainian citizen.
- In correctly and timely submitting the notification via praca.gov.pl.
- In advising on the steps to take after the temporary protection expires.
- In ensuring the compliance of the employment process with applicable regulations.
Simplified access to the labor market is a huge facilitation for Ukrainian citizens seeking refuge and work in Poland. However, the employer’s fulfillment of the notification obligation is crucial, as is awareness of the temporary nature of these solutions and the need to stay updated on legal changes.
(Please remember that the information in the article reflects the legal state as of early April 2025. The legal situation of Ukrainian citizens under temporary protection is dynamic. Always verify current deadlines and rules on official government websites such as gov.pl, udsc.gov.pl. This article does not constitute legal advice.)
