A new draft act that would dismantle the extraordinary legal framework created for Ukrainian refugees in March 2022 was adopted by Poland’s Council of Ministers on 20 January and submitted to parliament on 22 January. The UNHCR’s 26 January Protection-Sector Legal Update confirms that the legislation aims to fold temporary-protection provisions into Poland’s standard 2003 Foreigners Act, bringing national rules into closer alignment with the EU Temporary Protection Directive.
If enacted—as early as 4 March 2026—Ukrainian citizens would transition from near-citizen entitlements to a mainstream integration model similar to that offered to other third-country nationals. Access to social benefits, healthcare and labour-market support would be harmonised, potentially reducing costs for Poland’s public finances but increasing compliance obligations for employers of Ukrainian staff.
![Draft Law to Phase Out Special Protection Regime for Ukrainian Refugees Moves to Polish Parliament]()
Human-rights NGOs have urged lawmakers to provide clear grace periods and maintain labour-market flexibility, warning that abrupt changes could push tens of thousands of Ukrainians into irregular status. For multinational companies, the bill could translate into new work-authorisation steps or residence-card reissuance for Ukrainian assignees who currently rely on the Special Act’s simplified provisions.
Corporate mobility teams should begin mapping affected employee populations, budget for possible re-filing fees and watch for implementing regulations that clarify documentation timelines. Early stakeholder engagement—with payroll vendors, local HR and external counsel—will be critical to avoid gaps in lawful stay and work permission once the special regime sunsets.
If enacted—as early as 4 March 2026—Ukrainian citizens would transition from near-citizen entitlements to a mainstream integration model similar to that offered to other third-country nationals. Access to social benefits, healthcare and labour-market support would be harmonised, potentially reducing costs for Poland’s public finances but increasing compliance obligations for employers of Ukrainian staff.
Human-rights NGOs have urged lawmakers to provide clear grace periods and maintain labour-market flexibility, warning that abrupt changes could push tens of thousands of Ukrainians into irregular status. For multinational companies, the bill could translate into new work-authorisation steps or residence-card reissuance for Ukrainian assignees who currently rely on the Special Act’s simplified provisions.
Corporate mobility teams should begin mapping affected employee populations, budget for possible re-filing fees and watch for implementing regulations that clarify documentation timelines. Early stakeholder engagement—with payroll vendors, local HR and external counsel—will be critical to avoid gaps in lawful stay and work permission once the special regime sunsets.
Source: UNHCR Protection-Sector Update
