Introduction
If you employ foreign nationals based on a type A work permit, this information is essential. It explains when it is possible to temporarily assign an employee to a different job position—without needing to obtain a new work permit.
With the new regulations on employing foreign workers in Poland effective from June 1, 2025, employers must stay informed about updated procedures to ensure compliance. These changes, signed into law in April 2025, aim to streamline processes while introducing stricter controls, including the removal of the labour market test and full digitization of applications. This guide incorporates the latest rules to help you navigate job position changes for foreign employees without risking penalties. As of August 2025, additional obligations like mandatory online submission of employment contracts have come into effect, starting from August 1 for work permits, to enhance transparency and compliance. For businesses hiring non-EU workers, understanding these nuances is key to avoiding fines that can now reach up to PLN 50,000 for illegal employment.
This guide incorporates the latest rules to help you navigate job position changes for foreign employees without risking penalties, while also providing a comprehensive overview of the entire work permit system in Poland for 2025.
Who needs a Work Permit in Poland?
By default, any non-EU/EEA/Swiss citizen requires a work permit to be legally employed in Poland. However, the new regulations provide a detailed list of exemptions. Understanding these is the first step to ensuring compliance.
Definitely Need a Permit:
- Third-country nationals (non-EU) without a special status (e.g., permanent residency).
- Tourists who decide to take up employment (this is illegal).
- Individuals holding residence cards without explicit work rights.
- Foreigners working in specific regulated professions or top management.
Who Can Work Without a Permit?
- EU/EEA/Swiss citizens and their family members. They only need to register their stay if it exceeds 3 months.
- Holders of specific residence cards: Permanent residence card, EU long-term resident card, or a card with the annotation “access to the labour market” (e.g., family reunification with a Polish citizen).
- Karta Polaka (Pole’s Card) holders.
- Graduates of Polish universities (for up to one year after graduation).
- Refugees and persons under protection in Poland.
- Citizens of Ukraine, Belarus, Georgia, Moldova, and Armenia can work for the first six months based on an employer’s declaration of entrusting work ( oświadczenie ), after which a permit is needed. (Note: Russia is no longer on this list).
Types of work permits in Poland
Poland offers several types of work permits, each designed for a specific employment scenario. While Type A is the most common, it’s important to know the full spectrum.
- Type A: For a foreigner employed by a Polish-registered company under an employment contract or a civil law contract (like B2B). This is the focus of our guide.
- Type B: For a foreigner serving as a member of the management board of a legal entity, residing in Poland for a period exceeding 6 months within a 12-month period.
- Type C: For a foreigner employed by a foreign employer and delegated to work in a Polish branch or entity for a period exceeding 30 days within a 6-month period (intra-company transfer).
- Type D: For a foreigner employed by a foreign employer without a Polish branch, delegated to Poland to provide an export service.
- Type E: For a foreigner employed by a foreign employer and delegated to Poland for a period exceeding 30 days within a 6-month period for purposes not covered by other permits (e.g., internships).
- Type S (Seasonal): For foreigners performing seasonal work in sectors like agriculture, horticulture, or tourism for up to 9 months.
- EU Blue Card: A special permit for highly qualified professionals, offering benefits like easier job mobility and a path to permanent residency. The 2025 updates have lowered the required experience to 3-5 years and allow business activity.
Step-by-Step Guide to the work permit application process
The 2025 regulations have fully digitalised the application process. All formalities are now handled online via the praca.gov.pl portal.
- Employer Initiates the Application: The employer, not the employee, must submit the application. This is done by creating an account on the praca.gov.pl portal.
- Labour Market Test is Abolished: The old requirement to obtain information from the starosta (poviat starost) proving no suitable Polish candidates existed has been removed. However, local authorities can now create “protected professions lists.” If the job is on this list, a work permit will be refused.
- Employer Submits Required Documents:
- Completed application form.
- A copy of the employment contract.
- Proof of no arrears in taxes and social security contributions (ZUS).
- Company documents (e.g., excerpt from the National Court Register – KRS).
- Details on the job offer: position, duties, salary, working hours.
- The employee’s passport copy and proof of qualifications.
- Processing and Decision: The Voivodeship Office reviews the application. Standard processing time is up to 60 days, but can be shorter for priority sectors.
- Employee Applies for a Visa: Once the permit is approved, the employee must apply for a national work visa (Type D) at a Polish consulate in their home country.
- Arrival and Registration: Upon arrival, the employee must register their residence and, if staying long-term, apply for a temporary residence card.
Changing job positions: The 30-day rule (Type A)
For employers operating in dynamic sectors like manufacturing, logistics, or construction, the ability to reallocate staff is crucial. The new Type A work permit allows for the temporary reassignment of an employee to a different role or job type.
The Core Rule:
- This flexibility is limited to a total of 30 calendar days per calendar year.
- Within this limit, a foreign employee can perform different duties without the need for a new permit.
- All other conditions outlined in the original permit (e.g., salary, working hours, employer) must remain in full force and comply with regulations.
When can temporary worker position be changed without new work permit and visa?
A type A work permit, allows for the temporary reassignment of an employee to a different role or job type. This is particularly relevant for businesses operating in dynamic and flexible environments. These businesses are manufacturing, logistics, or construction—where the need to reallocate staff can arise suddenly and require quick action.
However, this flexibility is limited to a total of 30 days per calendar year. Within this timeframe, a foreign employee can perform different duties without the need for a new permit. It is crucial that all conditions outlined in the original permit remain in force. Also any reassignment complies with applicable regulations.
Under the updated 2025 rules, certain changes—such as a shift in job title while retaining the same scope of duties, an increase in working hours with proportional remuneration, or modifications to company details like registered office or legal form—do not require a new work permit or amendments. This aligns with the European Commission’s guidelines on temporary residence and work permits, which emphasize that only significant alterations (e.g., changes in employer, position, lower remuneration, or contract type) trigger the need for a new application. Employers in sectors like IT, manufacturing, or healthcare can leverage this for short-term flexibility, but exceeding the 30-day limit or failing to meet other permit conditions could lead to fines up to PLN 50,000 for illegal employment.
In fast-paced industries where quick staffing changes are common, it is valuable to know that this option exists. However, employers must also ensure that all legal requirements are met to remain compliant.
Additionally, as of August 2025, standard work permits are not issued for roles involving less than 25% of full-time hours (typically 40 hours weekly), which may impact part-time reassignments.
Employer’s obligation to notify authorities
The employer is obliged to notify the Voivode (Regional Governor) who issued the work permit of any such reassignment. This notification must be submitted in writing within 7 days of the employee starting the new role.
This requirement ensures transparency and oversight in the employment of foreign nationals and helps protect their rights.
The notification is particularly required when:
- foreign employee begins work of a different nature or in a different position than originally specified in the permit as outlined in Article 88f, section 1b.
Failing to provide this information can result in legal issues due to non-compliant employment practices. To avoid such problems, employers should ensure all documentation is accurate and submitted on time. This supports smooth and lawful workforce management.
As per the June 2025 amendments, notifications have expanded: Employers must now inform the voivode within 15 business days of job termination, changes in company details, job title, working hours, or contract type for temporary residence and work permits. Additionally, for declaration-based work, notify the local labour office within 14 days if the worker doesn’t start, or 7 days if they end early. The new digital portal for submissions (transitioning fully online within two years) makes this easier, but unannounced inspections by the National Labour Inspectorate (PIP) and Border Guard mean compliance is critical.
Check also article: work permit type A Poland – common mistakes.
Full Digitalisation and Compliance: The New Reality
The 2025 reforms have cemented Poland’s move to a 100% paper-free processing system.
- All applications, notifications, and attachments must be lodged exclusively through the praca.gov.pl e-portal.
- Employers must now upload scans of every passport page, sworn Polish translations of any foreign-language documents, and, for regulated professions, proof of qualifications.
- Labour inspectors have been given powers to check that documents were uploaded before the start of work and to fine companies for non-compliance.
- The National Labour Inspectorate (PIP) and Border Guard are authorised to conduct joint, unannounced inspections.
Conditions for reassigning a foreign Employee to another position
Under Article 88f, section 1b, it is permissible to assign a foreign employee to a different position or job type, provided that:
- the reassignment does not exceed 30 calendar days per year,
- all other conditions stated in the original work permit and in Article 88d remain fulfilled.
Besides the time restriction, employers must also avoid breaching any other conditions agreed upon when the original permit was issued. This is crucial not only for legal compliance but also to prevent complications during potential inspections.
The 2025 updates introduce new grounds for permit refusal, such as if the employer has obstructed inspections in the last 24 months, or if the application appears designed solely for entry into Poland (e.g., high unused permits or lack of social insurance registration). Employers must now submit employment contracts electronically via the official portal before work starts, keep sworn Polish translations if needed, and inform workers of trade union rights. For new entities operating less than a year, permits are limited to one year. These changes enhance transparency but increase scrutiny—employers in high-demand fields like logistics can benefit from fast-tracked applications for strategic roles.
Step-by-step Guide to notifying the voivode
To ensure compliance during a reassignment, follow these steps:
- Assess the change: Confirm the reassignment is temporary (under 30 days/year) and doesn’t alter core permit conditions like remuneration or contract type.
- Prepare documentation: Gather details on the new role, duration, and how it aligns with the original permit. Include a sworn Polish translation of the contract if it’s in a foreign language.
- Submit notification: Send a written notice to the voivode within 7 days of the start date, via the digital portal if available.
- Upload contract (Post-August 2025): For new or changed permits, submit the contract online before work begins.
- Monitor and record: Retain records for at least two years post-employment, as required under the new rules.
This process helps avoid refusal grounds, such as obstructing inspections or failing to register for social insurance.
Work permit application reforms impact on job changes
The June 1, 2025, reforms have eliminated the labour market test, replacing it with lists of restricted professions to prioritize Polish workers. For Type A permits, this means faster processing for eligible roles, but stricter rules on part-time work (no permits for under 25% full-time). Visas for tourism, family visits, or education (non-university) now prohibit work, even with permits. Employers face higher fines and unannounced inspections, emphasizing the need for accurate notifications during reassignments. As of August 2025, the full rollout of electronic contract submissions has further digitized the process, reducing paperwork but requiring tech-savvy compliance.
| Change type | Requires new permit? | Notification required? | 2025 Impact |
|---|---|---|---|
| Job title (same duties) | No | No | Streamlined, no labour test needed |
| Temporary reassignment (<30 days) | No | Yes (7 days) | Allowed, but monitor for inspections |
| Employer change | Yes | N/A | Full new application via digital portal |
| Hours Increase (Proportional Pay) | No | No | Prioritized for renewals |
| Part-time (<25% Full-Time) | Permit Not Issued | N/A | New restriction from July 2025 |
The EU Blue Card: An Alternative for Skilled Workers
For highly qualified professionals, the EU Blue Card offers a more flexible pathway. The 2025 updates make it an even more attractive option:
- Lowered Eligibility: Applicants can now qualify with 3 years of professional experience instead of a university degree.
- Greater Mobility: Blue Card holders can change employers without applying for a new permit.
- Business Activity: They can now run their own business in Poland.
- Family Reunification: Simplified procedures for family members.
- Path to Permanent Residency: After a period of legal residence, they can apply for EU long-term resident status.
Common FAQs on type A work permit job changes
Q: Can a foreign worker be reassigned multiple times in a year? A: Yes, as long as the total doesn’t exceed 30 days. Track carefully to avoid non-compliance.
Q: What if the reassignment involves a third party? A: Generally not allowed without a new permit, unless via a temping agency.
Q: How do the 2025 rules affect renewals? A: Renewals for the same position/employer get priority and don’t need starost information.
Q: What penalties apply for failing to notify? A: Fines up to PLN 10,000, plus potential permit revocation.
Conclusion
Navigating job position changes under a Type A work permit requires careful adherence to rules, especially with the 2025 updates emphasizing digitization and compliance. By understanding when a new permit is needed and fulfilling notification duties, employers can maintain flexibility while avoiding legal pitfalls. For more on “Poland foreign worker job change rules 2025,” consult official sources or related articles like “work permit type a poland – common mistakes.” Visit the Office for Foreigners or EU Immigration Portal for official guidance.