Residence legalisation in Poland 2026–2031: the chaos that can be avoided

Methodology and caveats

Dopomo Data Lab · version 2.0 · September 2026

Sources.

All figures on numbers of people and on registrations come from the monthly reports of the Urząd do Spraw Cudzoziemców (the Office for Foreigners), “Raport na temat obywateli Ukrainy” (Report on citizens of Ukraine). With each figure we give the edition and the reference date, because the reports differ from one another and some data appears only in periodic breakdowns. We used the editions for 1 July 2025, 1 October 2025, 1 December 2025, 1 January 2026, 1 June 2026, 1 July 2026 and 1 August 2026. Figures on applications, outcomes and the number of valid residence documents come from the UdSC annual releases: for 2024 (as at 31 December 2024) and for 2025 (as at 1 January 2026). Application figures for 2026 come from the monthly UdSC activity reports (“Informacja o działalności Urzędu do Spraw Cudzoziemców”, as at 30 June and 31 July 2026). Figures on the duration of temporary residence proceedings at the voivodeship offices come from the MSWiA reply of 27 July 2026 to parliamentary interpellation no. 18089 (Sejm of the 10th term, api.sejm.gov.pl; as at 6 July 2026). The number of people with active UKR status in parts 2–4 comes from the PESEL UKR register published by the Ministry of Digital Affairs (dane.gov.pl, dataset 2715), recomputed by us from the powiat files. The population of Poland (37,332,500 as at 31 December 2025) is taken from Statistics Poland (GUS). Data on procedures, conditions and fees comes from the official information pages on the CUKR residence card. We base the language requirements for EU long-term resident status on the Act on Foreigners and on the regulation setting out the list of accepted certificates. Figures on the number of people sitting the state certificate examinations come from the statistics of the State Commission for the Certification of Proficiency in Polish as a Foreign Language (certyfikatpolski.pl).

Stock versus flow.

The number of people holding a valid document or an active status is a stock on a given day, not a count of applications filed in a year. These are two different quantities and should not be set side by side without that caveat. Decisions issued in a given year relate in part to applications from earlier years, so the gap between filings and decisions is an approximate measure of how fast pending cases are accumulating, not a backlog counter.

Estimate of the number of people eligible for a CUKR card.

No institution publishes this figure. Our estimate is 720,000 to 780,000 people, roughly 750,000. Our starting point is the 868,037 people with active UKR status as at 8 September 2026 in the PESEL register (Ministry of Digital Affairs, dane.gov.pl, dataset 2715, file STATYSTYKI_POWIAT_UKR_20260908; the sum of 380 powiats, recomputed by us). That is the right starting set, because an application for a CUKR card requires UKR status on the day it is filed (Article 42c of the special act). We subtract people who obtained status after 4 June 2025, because they can never satisfy the condition tied to that date, however long they have held status. Across the whole of 2025, 152,703 people registered for temporary protection, and 58,739 by the end of June, leaving 93,964 for the second half of the year. In the first half of 2026, a further 41,545 Ukrainian citizens registered. Part of June 2025 falls after the cut-off date, and for it we assume roughly 8,500 people, spreading the first half-year’s registrations evenly across the months. We add the July 2026 registrations to the post-cut-off group: according to the UdSC reports, 41,545 Ukrainian citizens had registered by 30 June 2026 and 45,400 by 31 July, so around 3,900 in July; registrations from August and the first days of September are not known to us and we do not estimate them. Together that gives around 148,000 registrations after the cut-off date. Not all of those people still hold status. Between 1 July 2025 and 1 July 2026 the stock moved from 988,654 to 959,000 alongside around 135,000 new registrations, which implies around 165,000 departures over the year. We assume that between 70 and 90 per cent of the group registered after the cut-off date remains, or 104,000 to 133,000 people. We add back children born in Poland after the cut-off date, because neither the 4 June 2025 condition nor the 365-day requirement applies to them. None of the reports gives their number; we assume 5,000 to 15,000 and flag this as an assumption external to the data. We also subtract people who held status on 4 June 2025 but never accumulated a continuous year. Nobody counts that group either; we assume a range of zero to 17,000. After these steps we arrive at 720,000 to 780,000, with both ends of the range rounded outward — wider, and so more cautious, than the arithmetic on its own. The register losing 82,249 people between 11 August and 8 September 2026 enters the calculation in full, through the new base. A PESEL number with UKR status granted on the basis of a declaration — and art. 25 of the act of 23 January 2026 reaches only that group — could be obtained only until the third sentence of art. 4(13) of the special act was repealed by the act of 15 May 2024, so nobody registered after 4 June 2025 could have belonged to it. If part of the fall did nonetheless concern people registered after the cut-off date, we would be subtracting them twice and the true number of eligible people would be higher, by at most a little over ten thousand. A control calculation by a second route, from the 988,654 people holding status on 1 July 2025 less a year of departures and less the September fall, gives around 740,000, and so falls inside the range. The regulatory impact assessment of the phasing-out act (Sejm print no. 2172, p. 125) assumed that “z dobrodziejstwa ww. regulacji prawnych może skorzystać około 800 tys. uprawnionych cudzoziemców” (around 800,000 eligible foreigners may benefit from the above legal arrangements). If every eligible person applied, the fees alone would come to PLN 316 to 343 million, at PLN 440 per person. For comparison, the 14,000 applications filed by the end of June 2026 correspond to PLN 6.16 million.

What we do not estimate.

We do not forecast the number of applications. Eligibility follows from conditions written into the law and can be estimated. How many eligible people will actually apply depends on human decisions, and that cannot be read out of the available data. So we publish the number of eligible people and the number of applications actually filed, and we leave empty space between them rather than fill it with a guess of our own.

How we read the 365-day condition.

The 365-day period need not run immediately before the application is filed. Any uninterrupted period from the moment status was obtained is enough, and a gap between that period and a subsequent reacquisition of status is permissible. Interrupted spells are not added together. This condition is independent of the condition of holding status on 4 June 2025, and the two should not be conflated.

Uncertainties worth knowing about.

The word “registered” in the reports may refer to registration events rather than to people registering for the first time. If so, we are subtracting too much, and the true number of eligible people lies in the upper half of our range. The register itself can shift abruptly. Between 1 October and 1 December 2025 the stock fell from 1,005,006 to 965,180, that is by nearly forty thousand in two months. We do not know the cause of that change and we do not attribute it. We treat it as a measure of how far wrong any single figure in parts 2–4 could be. Eurostat data on the number of temporary protection beneficiaries in Poland differs from the PESEL register data for the same dates. We do not set the two sources against each other. In parts 4 and 5 we use the UdSC reports; the number of eligible people in parts 2–4 starts from the PESEL UKR register published by the Ministry of Digital Affairs (dane.gov.pl, dataset 2715), whose stocks for the same periods agree with the UdSC reports to within rounding (951,000 in the report as at 1 August 2026 against 950,286 in the file of 11 August).

Other public estimates.

We do not put our estimate forward in a vacuum. The regulatory impact assessment of the phasing-out bill (UD345, Ministry of the Interior and Administration, version of 23 December 2025, Government Legislation Centre: https://legislacja.rcl.gov.pl/projekt/12405609) states: “Szacuje się, że z dobrodziejstwa ww. regulacji prawnych może skorzystać około 800 tys. uprawnionych cudzoziemców” (it is estimated that around 800,000 eligible foreigners may benefit from the above legal arrangements), and for the voivodeship offices it projects a total of “ok. 900 tys. nowych wniosków” (around 900,000 new applications). These figures are not the same quantity as ours. We estimate the eligible population, 720,000–780,000 people, not the number of applications, which we deliberately do not forecast. We treat the order-of-magnitude agreement with the impact assessment as an independent validation of our eligibility arithmetic, not as confirmation of an application forecast.

Left unexamined.

This category covers a range of causes: formal defects, non-payment, failure to appear, abandonment of the case. Public data does not give their breakdown, so we do not attribute it to a single cause.

Data and corrections.

All the figures used in the report are available for download as a CSV file, with the source and reference date given for each entry. The file at https://dopomo.pl/pl/raport/legalizacja-pobytu-2026/dane.csv opens straight into a Polish-locale Excel: columns are separated by semicolons and decimals by a comma. The same dataset in strict RFC 4180 form — comma-separated columns, decimal points — is served at https://dopomo.pl/pl/raport/legalizacja-pobytu-2026/dane-rfc4180.csv for analytical tools and newsrooms outside Poland. We accept corrections publicly and apply them with a date.

Extension of temporary protection.

The Council extended temporary protection by Implementing Decision (EU) 2026/1912 of 30 July 2026. The Office for Foreigners confirmed it in a communiqué of 6 August 2026 (“Extension of temporary protection to 4 March 2028”, gov.pl/web/udsc) and, separately, extended its published card-processing times on 10 August 2026. Three elements of the decision change the conditions for entering the system, not the date in art. 42x of the special act. First, from 31 July 2026 art. 2 of the decision grants protection only to people who have fulfilled their military obligations in Ukraine, with proof required “where appropriate”; the decision deliberately sets no age or sex limits, and anyone protected on 30 July 2026 or earlier keeps that protection on the previous terms. Second, new arrivals register for PESEL UKR at any municipal office under art. 110a(1) of the Act on granting protection to foreigners, for as long as the Council decision remains in force, but the application must be filed within 30 days of crossing the border; missing that deadline means protection expires (art. 109b(1)(1) of that act). Third, the date of 4 March 2027 in art. 42x of the special act, the last day on which filing a CUKR card application guarantees legal residence until the case is closed, cannot be moved by an implementing act: the provision carries no delegation to change it by regulation or communiqué, so only an amendment to the statute could move it — and there is none as of this version. The special act itself sets no deadline for filing the application: the condition is holding UKR status on the day of application (art. 42c). None of these changes affects the data for 2024 and 2025 in parts 4 and 5.

The fall in the PESEL UKR register between 11 August and 8 September 2026.

Between the dataset 2715 publication of 11 August 2026 and the publication of 8 September 2026, the number of people with active UKR status fell from 950,286 to 868,037, that is by 82,249 people (8.7 per cent). We recomputed these figures ourselves, summing the rows of the 380 powiats in the STATYSTYKI_POWIAT_UKR files; in every file the sum of women and men matches the overall total to the person. It is the largest change between two consecutive publications in the whole series since January 2025; the previous one, in October 2025, came to 39,000. The fall is not spread evenly: the 2009 and later birth cohorts lost around 58,000 people, or 18 per cent of that group, and the 2008 and earlier cohorts around 24,000, or just under 4 per cent. The publisher masks cells below two people in the files, so the birth-cohort figures are a lower bound; the overall totals are exact. The fall coincides in time with 1 September 2026, when under art. 25 of the act of 23 January 2026 on the phasing out of arrangements (Dz.U. 2026 poz. 203) the UKR status of people who had been given a PESEL number on the basis of a declaration and had not confirmed their identity with a valid travel document by 31 August was changed ex officio to NUE status, and those people lost the entitlement under art. 106(1) of the act on granting protection to foreigners. No authority has said how many people that change covered, or linked it to the fall in the register; nor do we. The coincidence in time and the scale of the fall among children are nonetheless reason to ask publicly the questions the data does not answer: what happened to those 82 thousand people; on what basis are those of them who have not left now residing in Poland; whether and how they can recover their status, given that art. 44b of the act on the population register ties a renewed grant of UKR status to the date of re-entry; and what becomes of their applications for temporary residence and for family reunification. Until those answers come, we treat the figure of 868,037 as the starting point of parts 2–4, and that is how we have recalculated the eligibility estimate.

Data for 2026: UdSC activity reports (as at 30 June and 31 July 2026).

The application counts for 2026 come from the monthly “Informacja o działalności Urzędu do Spraw Cudzoziemców” (UdSC activity reports; sheet “Meldunek”, table “Sprawa | wnioski | decyzje”, values cumulative from 1 January): for the first half of 2026, 286,027 applications for temporary residence, 10,348 for permanent residence and 15,557 for EU long-term resident status, 311,932 in total; to 31 July 2026, 321,122, 11,431 and 18,062 respectively, 350,615 in total. Year-on-year comparisons are computed against the same table in the report for June 2025 (249,404, 10,551, 15,307, 275,262 in total). We print no decision counts for 2026: the report for the first half-year gives 190,870 positive decisions in temporary-residence cases, while the report cumulative to 31 July gives 159,698, that is fewer for a longer period, which is possible only if one of the two compilations was revised; until this is clarified we describe outcomes with the annual data for 2025. The category “left unexamined” does not appear in the monthly compilations, so there too we stay with the annual data. The figure of 12,500 applications for EU long-term resident status in the first half of 2026 comes from the UdSC report on Ukrainian citizens and covers that group only; across all nationalities there were 15,557.