On 4 March 2026, the simplified rules for legalising the stay and work of Ukrainian citizens introduced in 2022 may come to an end. This does not mean the end of EU temporary protection (valid until 4 March 2027), but rather the end of Poland’s extraordinary national solutions and a shift to a systemic model.
For employers, this means operating under two parallel legal regimes, managing two distinct groups of workers, and mitigating the risk of misclassifying the legal status of employees.

1. Temporary Protection – EU Framework, Different National Models

Temporary protection was activated on 4 March 2022 and remains in force until at least 4 March 2027.
Poland supplemented EU rules with a special Ukrainian Act, creating a mass, simplified system based on:

• PESEL number with UKR status,
• the electronic document diia.pl,
• automatic extensions of stay and work authorisations.

This resulted in two categories of Ukrainian citizens:

1. Beneficiaries of temporary protection (PESEL UKR).
2. Individuals on automatic extensions of other residence titles.

Both groups hold legal stay until 4 March 2026.

2. The 2025 Lesson – Legislative Uncertainty

Extensions of the special act occurred at the last possible moment in 2025. The President announced there would be no more automatic prolongations and that Ukrainians should transition to general rules.
Employers must therefore assume changes will take effect in 2026 and not rely on further special extensions.

3. The “Sunset Act” Proposal – Moving to a Systemic Model

Published on 23 December 2025, the draft introduces the phasing-out of the special act and transfers selected solutions to the general law on protection.

Key changes for employers:

• PESEL UKR and diia.pl remain the main confirmation of temporary protection (including for travel).
• The duration of protection becomes automatically tied to the EU decision (currently: until 4 March 2027).
• Simplified employment based on labour office notification will apply only to beneficiaries of temporary protection (PESEL UKR).
• A 14‑day deadline to apply for PESEL UKR after crossing the border.
• Running a business like Polish citizens — only for holders of PESEL UKR.
• For others, residence permits and documents will be extended to March 2027.
• Suspension of deadlines in residence procedures will continue until 2027, prolonging uncertainty.
  
  

4. Two Scenarios for March 2026

Scenario 1 – The Sunset Act Enters into Force

• Beneficiaries of protection:
  – status confirmed via PESEL UKR and diia.pl,
  – employment based only on notification to the labour office.
• People on extended residence titles:
  – documents extended to 2027,
  – simplified notification no longer available,
  – employment requires standard procedures (typically: declaration, 400 PLN fee, 2–3 weeks processing).

Scenario 2 – The Sunset Act Does Not Enter into Force

• Temporary protection EU-wide continues, but documentation changes:
  – status confirmed via paper certificates issued by the Head of the Office for Foreigners,
  – possible months-long waiting times and inability to travel.
• Beneficiaries: full access to the labour market with no notifications.
• Individuals on extensions:
  – risk of illegal stay after 4 March 2026 without another residence basis,
  – need to apply to the voivode beforehand,
  – possible fallback: 90 days visa-free stay if holding a biometric passport.
  
  

5. 2026 as the Year of Choosing a Long-Term Path

The proposal indicates that the extension to 4 March 2027 is the last one.
Ukrainian citizens must therefore stabilise their status.

For beneficiaries of protection:

Options include:

• temporary residence permits (work, Blue Card, family, business),
• or the expected CUKR residence card, a transitional path for persons genuinely settled in Poland (conditions include: uninterrupted UKR status for 365 days, UKR status on 4 June 2025).

For those outside protection:

• CUKR will not be available,
• only standard residence applications remain,
• without the Sunset Act, they face urgent deadlines in early 2026.

Employers must maintain accurate and up‑to‑date information on each Ukrainian employee’s residence basis.

6. Preparing Organisations for March 2026

Companies should:

1. Verify for each Ukrainian employee whether they have PESEL UKR or remain on extended residence documents.
2. Review compliance with employment notification requirements.
3. Plan employees’ future residence paths (CUKR, regular permits).
4. Provide clear internal communication — 2025 demonstrated that information gaps quickly create operational risk.

Expert Commentary – EY Poland

Łukasz Kunda, Manager, Immigration Team, EY Poland
Rafał Rogala, Senior Manager, Immigration Team, EY Poland

According to the experts, 2026 will require employers to navigate two parallel legal frameworks and manage two distinct employee groups.
The largest operational change concerns work authorisation:

• With the Sunset Act: notifications become exclusive to PESEL UKR holders, requiring rigorous status verification at recruitment and during employment changes.
• Without the Act: notifications remain widely available, but confirming residence status becomes difficult.

2026 will be a decisive year for long-term migration planning — either through standard residence permits or the new CUKR pathway.

*The text was created based on expert support - ABSL Expertise Partner - EY Polska and takes into account the legal status and the stage of the legislative process as of January 9, 2026.