What this guidebook covers
A new act in force from 1 June 2025 sets fines of PLN 3,000 to PLN 50,000 for each foreigner employed illegally, plus new electronic duties. Five car washers without permits can mean up to PLN 250,000. Not submitting a contract electronically costs another PLN 1,000 to PLN 3,000, and the voivode (regional governor) can refuse further permits.
This guidebook covers 5 standards for employing foreigners, with 10 checkpoints: valid permits, contracts that match the permit, contracts submitted in the electronic system, legal residence, and subcontractors and agencies. The guidebook PDF is in Polish.
The 5 standards for employing foreigners
| Code | Standard | Ideal fix time |
|---|---|---|
| CUD-01 | Valid work permits | Immediate |
| CUD-02 | Contract matches the permit | 7 days |
| CUD-03 | Contract submitted electronically | 7 days |
| CUD-04 | Legal residence | Immediate |
| CUD-05 | Subcontractors and agencies | 30 days |
How to run a Polish audit of employing foreigners, step by step
- Confirm what applies. Include everyone working on site, including car wash, cleaning and agency staff; Ukrainian citizens can work on the basis of a notification, so check the current special rules.
- Walk the site, standard by standard. Score each of the 10 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Compare the list of people with their permits and residence documents, compare 5 contracts with their permits, and check submission confirmations and subcontractor agreements.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the permit list, contracts and permits, submission confirmations, copies of residence documents, and subcontractor agreements and audits.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Boards: the risk per person
- HR: tracking permit deadlines
- Auditors: staff lists and contracts to check
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
