GMI Legal Update: Employment of university students without a Work Permit and submitting notifications under the new rules from 1st June

I. Students’ employment and work permits

The transitional period, which exempted all full-time students from the requirement to obtain a work permit, expired at the end of May. The Regulation of the Minister of Family, Labor and Social Policy on Special Cases in Which a Foreigner Authorized to Reside in the Territory of the Republic of Poland May Work Without a Work Permit or a Declaration of Entrusting Work to a Foreigner, of 20th November 2025, replaced the Regulation of 21st April 2015, and allows work without a work permit only to those studying at universities approved by the Minister as institutions that may accept foreign students or those that do not require such approval. The regulation entered into force on 1st December 2025, and the transitional period for those already working under the old rules was six months.

It is worth conducting an internal audit as soon as possible to ensure that no student employees have lost the opportunity to work without a work permit.

II. Notifications via praca.gov.pl

Please also bear in mind that in accordance with the announcement of the Minister of Family, Labor and Social Policy of 30th April 2026, from 1st June notifications regarding issued work permits and declarations of entrusting work to a foreigner must be submitted via the praca.gov.pl portal. Notifications submitted otherwise will not be considered.

When is notification required?

1. In the case of a work permit:

• Termination of work at least 2 months before the permit expires;
• Failure to commence work within 2 months of the permit’s validity date;
• The break in work lasts at least 2 months.

Deadline for submitting notification: 7 days from the occurrence of the circumstances indicated above.

2. In the case of a declaration of entrusting work:

• Commencement of work within 7 days of the declaration’s validity date;
• Failure to commence work by the foreigner within 14 days of the declaration’s validity date;
• Termination of work before the declaration’s expiry date or definitive failure to commence work by the foreigner.

Upcoming changes

A preview of a draft bill amending the Act on Foreigners (project UD408) has been published on the website of the Prime Minister’s Office. This bill aims to introduce an interesting solution – the possibility of tacitly concluding the procedure for obtaining a residence permit for citizens of certain countries designated by the Council of Ministers by regulation. The bill is expected to be adopted by the Council of Ministers in the second quarter of this year. We eagerly await the content of the draft and the announcement of the list of countries deemed “satisfactorily safe.”

Download the PDF document: here.