Poland: changes to special regime for ukrainian nationals
On 5 March 2026, Poland implemented significant changes affecting the legal stay of Ukrainian nationals by phasing out key provisions of the special regime introduced in 2022. The reform marks a transition from temporary, flexible measures toward the standard immigration framework under Polish law.
Which law introduced the changes?
Act of 23 January 2026 on the termination of solutions resulting from the Act on assistance to Ukrainian citizens in connection with the armed conflict in Ukraine, and on amendments to certain other acts (Dz.U. 2026, item 203).
What are the changes?
1) Temporary residence permits:
Applications are now assessed under the general provisions of the Aliens Act. Standard eligibility criteria and refusal grounds fully apply.
Previously: Ukrainian nationals could obtain temporary residence permits under simplified conditions, including cases where standard requirements were not met.
2) Return procedures and departure deadlines:
Return procedures are now conducted under general rules, with no special legal basis allowing authorities to suspend or refrain from initiating proceedings. Deadlines for voluntary departure and compliance with return decisions are no longer extended.
Previously: Authorities could decide not to initiate or to discontinue return proceedings, provided no security or public order concerns were involved. Deadlines for departure were also extended under the special regime.
3) Validity of documents and legal stay
The validity of certain documents and legal stay statuses has been extended until 4 March 2027. This applies to:
- national visas and their permitted periods of stay;
- temporary residence permits;
- residence cards and certain identity documents issued to foreigners;
- legal stay based on visas, residence titles issued by other Schengen states, or visa-free travel where the permitted stay had been exhausted.
Previously: These documents and stay periods were automatically extended without a fixed long-term end date.
It is important to note that Ukrainian nationals benefiting from temporary protection and holding PESEL UKR status remain eligible to apply for specific types of temporary residence permits, including:
- temporary residence and work permit;
- EU Blue Card;
- temporary residence permit for business activity;
- temporary residence permit for family members of Polish citizens;
- temporary residence permit for family reunification.
This pathway is now regulated under the new law, replacing the previous provisions of the Special Act.
Impact
The reform signals a shift from an emergency-based migration regime to a standardised legal framework. While core protections, including temporary protection status and extended document validity, remain in place, Ukrainian nationals are now subject to stricter compliance requirements when applying for residence permits or regularising their stay.
For employers and foreign nationals, this means increased scrutiny of applications and reduced flexibility compared to the previous regime, reinforcing the importance of meeting all formal legal criteria under Polish immigration law.