AutoSmart GuidebooksWhat 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
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
CUD-01Valid work permitsImmediate
- The law
- Act on the Conditions for Entrusting Work to Foreigners (from 1 June 2025) · 2025 Act: work permits, declarations, exemptions
- What we check
- Every foreign worker (mechanic, car washer, driver) has a valid basis to work: a permit, a declaration or an exemption (for example Ukrainian citizens with a notification).
- What it can cost
- Up to PLN 50,000 per person.
- Evidence
- List of permits
CUD-02Contract matches the permit7 days
- The law
- Act on the Conditions for Entrusting Work to Foreigners (from 1 June 2025) · terms of employment matching the permit (position, pay, hours)
- What we check
- The foreign worker works in the position, with the pay and the hours stated in the permit.
- What it can cost
- Treated as illegal employment: up to PLN 50,000.
- Evidence
- Contracts + permits
CUD-03Contract submitted electronically7 days
- The law
- Act on the Conditions for Entrusting Work to Foreigners (from 1 June 2025) · duty to send a copy of the contract through the online system
- What we check
- The contract with a foreign worker is sent electronically before work starts.
- What it can cost
- PLN 1,000–3,000 for each breach.
- Evidence
- Confirmations
CUD-04Legal residenceImmediate
- The law
- Act on the Conditions for Entrusting Work to Foreigners (from 1 June 2025) · Act on Foreigners: legal stay
- What we check
- The employer checks the residence document and keeps a copy for the whole period of employment.
- What it can cost
- Illegal employment: up to PLN 50,000.
- Evidence
- Document copies
CUD-05Subcontractors and agencies30 days
- The law
- Act on the Conditions for Entrusting Work to Foreigners (from 1 June 2025) · liability when using agencies and subcontractors
- What we check
- Car washes, temp agencies and cleaning firms employing foreign workers on the dealer's premises are checked.
- What it can cost
- Border Guard and PIP inspections at the showroom, and damage to reputation.
- Evidence
- Contracts + audits
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.
