Earthquake on the job market

The Polish labor market is facing a significant transformation that may result from the new regulations on employing foreigners, which came into effect on June 1. To what extent could these changes actually impact foreign workers and employers? Experts from Smart Solutions HR analyze how individual legal amendments may affect the number of foreigners employed in Poland.

Data from the Central Statistical Office indicates that by the end of 2024, over one million foreigners were legally employed in Poland, accounting for 7 percent of all workers. Just a decade ago, this number was only several tens of thousands, highlighting the scale of change in the labor market. Additionally, it is estimated that tens of thousands more operate in the so-called gray zone — inspections by the National Labor Inspectorate and Border Guard reveal up to 10,000 cases of illegal employment each year. These statistics show that foreigners make up a substantial part of the Polish labor market. Could the regulations that took effect on June 1, 2025, change that?

“The amendment of regulations regarding the employment of foreigners is an important step toward greater transparency and order in the labor market,” says Tetiana Hrynchyshyn, a legalization specialist at Smart Solutions HR. “The biggest difference compared to the previous regulations lies in the increased administrative responsibility on the employer’s side — this requires maintaining detailed records and responding immediately to changes in employment. It’s no longer just about paperwork — it’s a real shift in how the work legalization process is managed.”

On the one hand, the new regulations bring order and clarity to procedures. On the other hand, they demand greater vigilance from companies, more administrative resources, and adjustments to internal processes. For many employers, this could mean greater organizational effort and longer recruitment timelines. The tightening of migration policies — including more restricted access to visas and stricter rules for work legalization — may reduce the number of foreigners employed in Poland.

Greater transparency…

The most significant change effective from June 1 is the full digitalization of the procedures for legalizing the employment of foreigners. All applications — from declarations to appeals — must now be submitted exclusively online. In the short term, this may present technical challenges for some employers, but ultimately it is expected to reduce bureaucracy and streamline the permit issuance process.

“It’s worth noting that the current number of processed applications is significantly higher than the actual demand, leading to delays and disruptions in administrative work. According to reports from the Ministry of Family, Labour and Social Policy, in 2023, out of 506,000 registered declarations, 32% were later reported as cases where the foreign worker did not take up employment. In 2024, this figure increased to 39%. And this refers only to declarations — it does not include notifications or work permits. This means that on average, 40% of individuals do not start work, making the administrative procedures unnecessary and requiring later cancellations.

Moreover, data from Smart Solutions HR for the years 2022–2024 show that out of 100% of recruited candidates, only half actually started working. The shift to a fully electronic document flow is particularly important in preventing such situations,” explains Natalia Myskova, Managing Director at Smart Solutions HR.

…but also greater control

The second major change is the elimination of the so-called labor market test — the requirement to obtain confirmation from the local labor office that no unemployed local candidates are available for a given position. This is a significant facilitation for employers, allowing them to hire foreigners more quickly, especially in industries struggling with labor shortages. At the same time, however, local authorities (starosts) have been granted a new tool — the ability to create lists of professions for which work permits for foreigners will not be issued.

“The introduction of such ‘blacklists’ may limit the availability of jobs for foreigners in certain sectors, potentially pushing some companies to search for local workers — or to hire off the books if no alternative is found,” says Hrynchyshyn.

The legislation also increases obligations toward the workers themselves. Employers must provide foreign employees with a contract before the start of employment, in a language they understand — and if the document is in Polish, a translated version must also be provided. This is an important step toward improving employment standards, but it also means higher costs and greater formal requirements, especially for companies hiring seasonal or temporary staff, which may discourage them from initiating the process.

“The amendment also affects the education sector. Starting in July, universities will not be allowed to admit more than 50% of foreign students in relation to the total number of students. The goal is to eliminate the so-called ‘diploma mills’ — institutions that recruited large numbers of international students solely to facilitate legal residence and work. As a result, the number of international students — currently exceeding 100,000 — may stabilize or slightly decrease, which will also impact the labor market, as many of them held part-time jobs,” Hrynchyshyn predicts.

Equally decisive measures have been introduced regarding work visas. Companies that issue fictitious job offers solely to enable a foreigner to enter Poland may now face fines of up to 100,000 PLN. This marks the end of mass “invitation-based” recruitment and is likely to significantly reduce the number of visas issued.

“The new regulations may primarily affect students, who will no longer be allowed to work, apply for residence permits, or change the purpose of their stay. In addition, foreigners working in Poland on the basis of a residence permit issued by another Schengen country will now be restricted to stays of no more than 90 days and will no longer be eligible to apply for legal residence here,” notes Myskova.

Legal employment comes first

Stricter formal requirements may also accelerate the growth of the “gray zone.” To prevent this, the amendment introduces new, significantly harsher penalties for illegal employment — ranging from 3,000 to as much as 50,000 PLN, depending on the number of undeclared workers. Additionally, the Border Guard and the National Labour Inspectorate (PIP) are now authorized to carry out unannounced inspections. These regulations may reduce the scale of illegal work and compel companies to formalize cooperation with foreigners — although for some, this could become a barrier discouraging them from continuing to employ foreign workers.

“The direction of these changes is toward greater quality and control at the expense of quantity,” says Myskova. “Poland still intends to benefit from the labor of foreigners, but primarily those who are legally employed, essential to the economy, and not in direct competition with Polish workers. In the short term, employment statistics may shift slightly — most likely, the share of formally employed foreigners will remain high (6–7%), but growth may slow down. The number of foreigners employed under standard work contracts is expected to rise due to the requirement for formalization, while the percentage employed under civil contracts or without contracts at all is likely to decline due to stricter regulations.

Overall, a more balanced and controlled participation of foreigners in the labor market is anticipated, which should help prevent abuse, though it may also reduce the flexibility that the market has grown accustomed to during the migration boom years. A key indicator in the coming months will be whether employers manage to adapt smoothly to the new rules — if they do, the employment of foreigners should remain high, and the ‘gray zone’ is expected to gradually shrink,” Myskova predicts.

Sources: Central Statistical Office (GUS), Social Insurance Institution (ZUS), Ministry of Family and Social Policy (MRPiPS), internal analysis by Smart Solutions HR.