Two draft bills could transform how Polish employers hire foreigners

Legal advisory firm C&C Chakowski & Ciszek has drawn business attention to two draft laws released for consultation in late July that would fundamentally alter Poland’s rules for residence permits and the liability regime for illegal employment. The first proposal, prepared by the Ministry of the Interior, introduces a “silent-approval” mechanism for certain temporary-residence applications: if a voivode fails to issue a decision within 60 days, the permit would be deemed granted automatically. Crucially, however, the fast-track would apply only to nationals of a government-maintained ‘trusted countries’ list—currently just five states that do not supply large numbers of workers to Polish industry. Permits issued under silent approval would also be valid for a shorter period, and could lapse if the foreigner misses follow-up formalities, creating new compliance traps for employers. The second draft, from the Ministry of Labour, overhauls sanctions for illegal employment. Responsibility would shift from the formal “employer” to any entity that directly benefits from a foreigner’s work, sweeping many outsourcing and service-contract models into scope. The bill removes a long-standing defence based on lack of managerial control and re-structures fines so that penalties can multiply per employee. Inspectors would also gain the power to refuse or revoke work permits if a firm ignored a compliance notice within the previous 24 months. Taken together, the two projects continue a legislative trend that puts far greater compliance onus on companies while offering only limited procedural relief. Employers reliant on agency labour or foreign talent pipelines should participate in the August consultation window, conduct document-flow audits and ensure that HR or external vendors promptly track all official correspondence. If adopted in their current form, the measures could enter into force as early as January 2027, affecting tens of thousands of expatriate and third-country national staff in manufacturing, IT outsourcing and agriculture. International mobility managers should incorporate the potential changes into 2027 head-count and budget planning now.