As of 1 January 2026, the legal framework for the MOS Case Management Module is in force. While the regulations are active, the system itself will launch only after a formal announcement from the Ministry of Interior — likely in H1 2026.

1. What MOS Is and What It Changes

MOS is an IT system intended to handle residence applications electronically only, including:

• temporary residence permits,
• permanent residence permits,
• EU long‑term resident permits.

Forms will be structured, guiding applicants step‑by‑step and requiring signatures via:

• a trusted profile, or
• a qualified electronic signature.

The goal: reduce errors and incomplete applications.

2. End of the Passport Stamp

The traditional passport stamp confirming a complete application will be eliminated.
It will be replaced entirely by an electronic confirmation generated in MOS.

Implications for employers:

• no physical evidence of submission,
• need to redesign HR processes and rely on digital documentation.
  
  

3. Role of Attorneys – New Risks

Attorneys may assist, but the foreigner must personally sign the application using their electronic identity tools.

This may result in:

• informal sharing of trusted-profile access,
• risks related to data security and access to other government services,
• more formal errors due to limited role of professional agents.
  
  

4. Organisational Challenges for Employers

MOS requires employers to adapt:

• employer-issued documents must be signed with a qualified electronic signature,
• if offices demand signatures only from individuals listed in the National Court Register,
  → management boards may face heavy operational burdens, especially in large companies handling hundreds of applications.
  
  

5. Partial Digitalisation Only

Despite online submission, foreigners must still appear in person at the voivodeship office to:

• confirm identity,
• provide biometric data.

Long waiting times in major cities will continue to affect workforce planning.

Expert View: Łukasz Akuczonek (Project Manager, EY Poland)

MOS is a major step toward digitalisation, yet it does not resolve systemic problems such as lengthy processing times or mandatory personal visits.
Employers should:

• adapt HR procedures,
• implement electronic-signature standards,
• help foreign workers navigate the MOS system.

Early preparation will reduce operational risks and support smoother migration processes in the coming phases of digitalisation.

The text was created based on expert support - ABSL Expertise Partner - EY Polska