According to the draft regulation published in the legislative work schedule of the Ministry of Family and Social Policy (MRPiPS) on 6 February 2026, the list of such countries will include Colombia, Venezuela, and Georgia. The draft stipulates that citizens of these countries will not be able to legally work in Poland during visa-free stays, even if they hold a work permit. In practice, this means that both a residence document in the form of a visa or temporary residence permit and a legal work title are required.
The stated aim of the regulation is to limit abuses of the visa-free movement, strengthen migration control, and increase labor market transparency. For Colombia, the draft also formalizes a practice applied by the Ministry of Foreign Affairs since August 2024.
The Act of 20 March 2025 allows differentiating the permissibility of work depending on the basis of a foreigner’s stay. It specifies that entrusting work to a foreigner requires not only a valid work permit but also compliance with legal stay conditions, meaning not all forms of stay automatically entitle foreigners to work.
In practice, this means the legislator permitted implementing executive regulations that restrict work in certain migration scenarios. The MRPiPS draft regulation exercises this legal possibility by specifying particular countries subject to restrictions.
The draft explicitly states:
“Citizens of countries listed are not entitled to perform work in the territory of the Republic of Poland during visa-free stays, even if they hold a work permit.”
The rationale provided reads:
“The draft regulation was initiated by a request from the minister responsible for foreign affairs, who noted the need to include countries such as Colombia, Venezuela, and Georgia due to high migration risk related to the entry of citizens from these countries into the Schengen area, and the need to limit the risks of mass migration. The Ministry of Interior also supported the issuance of this regulation. For citizens of Georgia, Colombia, and Venezuela, visa-free movement is systematically used contrary to its intended purpose, particularly for taking up paid work bypassing legal requirements. This results in high rates of illegal stay and illegal employment, growth of the gray market, labor market destabilization, and an increase in exploitation and human trafficking cases.”
Such measures represent a fundamental change in the recruitment model for employers and staffing agencies, particularly in sectors relying on rapid mobilization of seasonal or short-term workers.
The regulation is expected to be issued in Q2 2026, leaving limited time to adjust employment processes for workers from Colombia, Venezuela, and Georgia.
According to the Social Insurance Institution (ZUS), the number of foreigners covered by social insurance exceeded 1.13 million, accounting for almost 7% of all insured employees in Poland. This growth has been fueled in part by workers from Latin America and Asia.
Data from Statistics Poland (GUS) indicate that in February 2024, over 1 million foreigners were employed in Poland, with Georgians representing about 2.5% of all foreign employees.
The growth of new migration directions is clear. In 2023 alone, the number of Colombians registered in the ZUS system increased by over 3,500, indicating a growing role of this direction in international recruitment.
Exact forecasts depend on the final shape of executive regulations and visa policy. However, based on current trends, realistic scenarios can be outlined.
If Georgians represent roughly 2.5% of the working foreign population and more than 1 million foreigners work in Poland, this translates into about 25–30 thousand Georgian workers present in the labor market at any given time. Additionally, several thousand new workers per year come from Colombia and Venezuela.
If a visa requirement replaces recruitment under the visa-free regime, the inflow of new workers from these countries may drop by 30–60% in the initial period, which in 2026–2027 could mean a reduction of 10–20 thousand people overall. The biggest decline would affect sectors relying on rapid short-term hiring.
The most significant change will be the need to plan recruitment further in advance. The model based on quick arrival of a worker under the visa-free regime and almost immediate employment will no longer be possible.
The recruitment process will require obtaining a visa beforehand, which may extend recruitment timelines by several months, increase administrative costs, and heighten the risk of visa refusals. Temporary employment agencies and logistics companies may experience reduced operational flexibility, especially during peak demand periods.
Sectors most exposed include manufacturing, logistics, food processing, construction, and cleaning services – all industries heavily dependent on foreign workers.
With the declining supply of workers from Ukraine and increasing competition from Germany and other EU countries, limiting one rapidly growing migration route may increase wage pressure and employee turnover.
If inflow from Colombia, Venezuela, and Georgia is restricted, employers may intensify recruitment in South and Southeast Asia, particularly Nepal, India, the Philippines, and Bangladesh – countries already among the fastest-growing sources of labor migration to Poland.
Other alternatives include Eastern European and Balkan countries, though their potential is limited demographically and migrationally, or countries still under visa-free regimes, such as Mexico, Guatemala, Honduras, Panama, and Peru.
For those holding valid temporary residence permits or other stay titles enabling work, the changes should not have an immediate effect. The regulations primarily concern new entries and work under visa-free stays.
Indirect consequences may include longer legalization procedures, increased inspections, and the need to more precisely match the basis of stay with the employment contract.
This group will be most immediately affected. Upon the enforcement of new regulations, merely being in Poland under visa-free conditions will no longer suffice to work. Even with a work permit or statement, employment could become illegal.
Workers will need to obtain a new basis of stay – a national visa or temporary residence permit – as soon as possible, which in many cases may require leaving and re-entering Poland on a visa. Employers face the risk of immediate suspension of work and potential liability for illegal employment.
Key is whether the worker already has legal stay status during the procedure (e.g., passport stamp confirming timely submission). In this case, new rules generally won’t immediately prohibit work.
Workers have a relatively stable situation, though additional controls or clarification of employment basis may be required. Employers must carefully monitor documents, particularly the transition from visa-free stay to “pending legalization.”
New regulations likely won’t significantly change the worker’s current situation. The rules apply only to work during visa-free stays. If the basis of stay is already a national visa or residence card, employment can continue under existing conditions, provided permits are valid and comply with employment terms.
The lowest risk occurs here, but it is not zero. Risks arise if permits expire or if the worker returns under a visa-free regime, when the new rules will apply. Recommended action: implement monitoring of visa/residence card expiry dates and plan renewals in advance.
The draft regulation signals a shift in state management of labor migration – from flexible and reactive to more controlled and planned. In the short term, this creates operational difficulties for employers and staffing agencies and potential labor shortages in high-turnover sectors.
Medium- and long-term effects will depend on whether visa and legalization facilitation measures are implemented for other migration directions and whether employers adapt recruitment models to the new reality.
