End of “stay resetting”: EES System from September 2026
The Entry/Exit System (EES) will definitively end the era of flexible interpretation of stay regulations. Through biometrics and automation, the system will record travel documents and replace traditional passport stamping. It will strictly enforce the limit of 90 days of stay in every 180-day period across the Schengen area.
The biggest challenge: Automated control prevents “resetting” the stay through short trips outside the zone, which will particularly affect specialists from the USA, Japan, or South Korea. According to the latest updates, the system is expected to be fully operational in September 2026, giving employers additional time to audit the stays of their management staff.
Temporary protection for Ukraine until 2027 – new rights and pitfalls
The legality of stay for Ukrainian citizens (with UKR status and those on visas or visa-free travel) has been extended until March 4, 2027.
EU Blue Card: Since January 1, 2026, Ukrainian citizens with UKR status can once again apply for this permit for highly qualified workers.
Sanction Reform: Failure to submit a notification of entrusting work within 7 days no longer results in illegal employment, but only in a fine.
New Obligation: From March 5, 2026, every new contract (even with Pole’s Card holders) requires a notification to the Labor Office (PUP) within 7 days.
Expensive declarations and e-signatures for boards: Employer obligations
The labor market reform has significantly raised financial and operational barriers. Since December 1, 2025, legalization fees have increased up to four times, with the cost of a declaration of entrusting work now at 400 PLN.
Online only: Work permit applications must be submitted exclusively via the praca.gov.pl portal; paper documents are left without consideration.
Criminal liability: Employers must submit declarations of no criminal record under penalty of perjury, which, combined with the requirement for Polish e-signatures for board members, is a key procedural challenge.
June 30th Deadline: What about your students?
A student ID is no longer the sole guarantor of the right to work without a permit. This right now depends on whether the university meets specific statutory criteria.
June 30, 2026, is the last day of the transition period for students from universities that do not meet the new requirements.
Starting July 1, 2026, employers must obtain work permits for students from universities not included on the ministerial list.
2026 HR Calendar: Deadlines you cannot miss
- February 1, 2026 – Requirement for the foreign parent’s professional activity in Poland as a condition for receiving the 800+ benefit.
- March 4, 2026 – Deadline to submit work notifications under current rules to ensure safe, indefinite employment.
- March 5, 2026 – Official start of the new legal order; 7-day notification duty for all new contracts with Ukrainians.
- April 1, 2026 – Polish authorities cease to recognize non-biometric passports issued by the Russian Federation.
- June 30, 2026 – Critical deadline for students from non-compliant universities.
- SEPTEMBER 2026 – Planned full operational status of the EES system and absolute calculation of the 90-day Schengen limit.
- March 4, 2027 – New horizon for temporary protection for Ukrainian citizens.
The complexity of the new regulations means that employing foreign nationals in 2026 requires companies to implement strict auditing and digital procedures. Changes to reporting deadlines and new requirements for students mean that immediate verification of staff is necessary to avoid severe financial penalties and litigation risks for board members. Grant Thornton experts provide comprehensive support in adapting your organisation to the new immigration regime.