Hiring in Poland: the labour market test is gone, and what replaced it

If you last looked at hiring foreign workers into Poland before mid-2025, most of what you know is out of date. A new Act took effect on 1 June 2025, replacing the 2004 law that had governed the area for two decades, and it changed both the thing employers complained about most and the things they were not worrying about at all.

The labour market test is gone

For years the first obstacle in a Polish work permit was the informacja starosty — the local labour office confirming that no suitable Polish or EU candidate was available. It was slow, it was the step most applications died at, and for general blue-collar roles it was often unwinnable.

It has been abolished.

In its place, district authorities may publish lists of occupations for which permits will be refused in that area, based on local labour market conditions. The logic is inverted: instead of proving a negative for every application, you check whether your occupation appears on a local exclusion list.

For an employer this is a genuine improvement, and it is the headline most people have not caught up with. It is also not the whole story.

What replaced it is administrative, and it bites

The new Act moved the burden from proving labour market need to proving you are a properly run employer. Four duties matter most.

Everything is electronic. Applications, correspondence with the authorities and appeals go through praca.gov.pl. Employers need their own account on the system. There is a transition period for paper, but building the process around paper now is building it twice.

The contract has to be in a language the worker understands — and translated. You must provide the contract in a language comprehensible to the foreign worker, with a professional sworn translation into Polish, and keep both versions for two years. Failing to hold that documentation carries fines reported at up to PLN 30,000.

The contract goes in before the work starts. Employment contracts are submitted electronically before the person begins, not at the first convenient moment afterwards. Changes in employment status are reportable within 7 to 15 days depending on the change.

You must tell the worker about their right to join a trade union, in writing. An unfamiliar duty for most employers coming from outside Poland, and an easy one to simply never do.

Who can no longer be employed

The Act closed a route a lot of employers were quietly relying on. Foreign nationals who entered Poland on a Schengen visa or visa-free travel cannot obtain a work permit or an employment declaration while there. Several other visa categories — family visit, non-university education, medical treatment — are now barred from work altogether, with narrow exceptions.

If your plan involved somebody arriving on a short-stay visa and regularising afterwards, that plan no longer exists.

Enforcement got considerably sharper

Unannounced inspections are available to the authorities. Illegal-employment fines run from PLN 3,000 to PLN 50,000 per worker, scaled to the number of people involved. Permits can be refused on new grounds, including where an employer obstructed an inspection within the previous 24 months, or where the authority concludes a company exists mainly to bring foreigners into the country rather than to trade.

That last ground is aimed at letterbox operations, and it is worth knowing which side of it your supplier sits on.

What it means for your plan

Three practical conclusions.

Poland got faster, not easier. Removing the labour market test takes out the step that caused most of the delay and most of the refusals. The documentation and reporting that replaced it is predictable work — which is the kind of difficulty you can plan around, unlike a labour office decision you cannot influence.

The paperwork is where files now fail. Missing sworn translations, contracts submitted late, status changes unreported. None of it is difficult. All of it is easy to skip when nobody owns it.

Compare it properly against the alternatives. For an employer weighing where in the region to place a hiring programme, Poland's position has improved relative to markets where a labour market test still applies. Our Poland hiring guide sets out the permit routes and current lead times, and Latvia or Lithuania: a practical comparison covers the two Baltic alternatives.

Rules of this kind are revised, and the position described here reflects the Act in force from 1 June 2025. Check the current position before committing to a timeline — or tell us the roles and the start date and we will give you the realistic sequence for your case rather than the best case.