Poland's 2025 reform made hiring foreign workers administratively simpler and, deliberately, harder to do badly. The labour-market test disappeared; the enforcement regime around illegal employment and actual working conditions was strengthened. Here is the compliance picture for a Polish employer.
Before Employment Starts
- A valid work permit covering this worker, this employer, this position and this place of work. The permit is specific — a worker permitted as a welder at one site is not covered driving a forklift at another.
- A written contract matching the permit: same position, same working time, and pay no lower than stated in the permit application.
- No tax or ZUS arrears, which are now explicit grounds for refusing a permit in the first place.
On Employment Start
- ZUS registration within seven days. This is the obligation most commonly missed with foreign hires, and it is the one that causes the worker real harm — no registration means no healthcare entitlement.
- Occupational health and safety training in a language the worker understands. For Indian crews that means English or Hindi materials for the induction, with Polish phased in.
- Medical examination confirming fitness for the role before work begins.
During Employment
- Pay what the permit states. Paying less than the declared salary is both a permit breach and a labour-law breach.
- Working time records kept accurately. Overtime, night work and rest periods are checked.
- Keep copies of the permit, visa or residence card, contract and identity documents for the duration of employment and the statutory retention period.
- Track expiry dates. Employing a worker whose permit or residence document has expired is illegal employment, regardless of whether a renewal is pending.
What Changes Require Action
A change of position, place of work, or a significant change in working conditions can require a new or amended permit. A change of employer requires a new permit entirely. Employers who redeploy foreign workers between group companies without checking this create exposure they are usually unaware of.
Inspections
The National Labour Inspectorate (PIP) and the Border Guard both have competence over the legality of foreign employment. Inspections look at permits and their match to actual work, contracts, ZUS registration, pay records and working-time records, and accommodation conditions where the employer provides housing.
Penalties
Illegal employment of foreign nationals carries financial penalties for the employer and, in serious or repeated cases, consequences that extend beyond fines — including restrictions on obtaining future permits. The 2025 Act strengthened this regime deliberately, as the counterweight to removing the labour-market test.
Accommodation Standards
Where the employer provides housing, it must be of an appropriate standard, and any deduction must be transparent and agreed. Overcrowded worker accommodation is a recurring inspection finding and a reputational risk with clients who audit their supply chains.
The Practical Checklist
Permit matches the actual work. Contract matches the permit. ZUS registered within seven days. Safety training delivered in an understood language. Pay as declared. Records kept. Expiry dates tracked with alerts at 90 and 30 days. Accommodation adequate and transparently charged.
Employers who hold those eight points have straightforward inspections. For the filing side see the type-A permit walkthrough and the 2025 Act summary. This article is general information, not legal advice.
