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

Stabilisation, not a wave: the year of the great status switch

The total number of foreign nationals holding a valid residence document rose by 41,900 in 2025 — an increase of 2.1%. The group as a whole amounts to roughly 5.4% of Poland’s population. Ukrainian citizens account for 77.4% of it (1.56 million), yet their number grew by just 1.5%.

The real change happened in the structure. Over the year, the number of Ukrainian citizens under temporary protection fell by 21,300, while Ukrainian temporary residence permits rose by 27,100, EU long-term resident cards by 38.8% (from 33,800 to 47,000), and the number of people under subsidiary protection by 55%. This is not an inflow of newcomers but people already here settling in and formalising their status. Anyone moving from temporary protection to a standard permit is vetted in a full administrative procedure: fingerprints on file, a stable employment situation, a predictable tax status.

In the background, the mix of origins is diversifying. The number of Colombian citizens holding a valid residence document rose by 172% in a year (from 3,000 to 8,000), Nepalese citizens by 58% and Filipino citizens by 36%. The Georgian (−12%) and Russian (−8%) groups, meanwhile, shrank. Poland is becoming a country of multi-directional immigration — with everything that implies for official communication, conducted today mainly in Polish, English, Ukrainian and Russian.

The bottleneck is procedural, not substantive

The year 2026 has brought no slowdown. In the first half of 2026, 286,027 people applied for a temporary residence permit, 14.7 per cent more than in the same period of 2025 (249,404); by the end of July the figure had risen to 321,122. Residence applications of all three kinds (temporary residence, permanent residence and EU long-term resident status) came to 311,932 in the half-year against 275,262 a year earlier (+13.3 per cent). We give no decision counts for 2026: the cumulative table to 31 July reports fewer positive decisions than the table for the half-year alone, as the methodology explains. The annual figures for 2024 and 2025 below are the reference point for this trend.

In 2025, 509,200 people applied for a temporary residence permit — 10.6% more than a year earlier. Over the same period, officials issued outcomes for 416,700 people. The difference — around 92,500 — approximates how fast the stock of pending cases is growing, and it is widening: a year earlier it stood at 62,500. The system is processing more than ever (positive decisions rose by 18,300), and the queue keeps lengthening anyway.

The structure of 2025 outcomes rewards a careful read: 78.8% were positive decisions, 6.2% refusals, 2.9% discontinuations — and 12.1% applications left unexamined, meaning closed without substantive review. That last category, more than 50,000 cases a year, covers applications the office could not assess on the merits at all — because of formal defects, missing documents, an unpaid fee or a failure to appear. For comparison, refusals on the merits numbered 25,900. In Poland today, a formal error closes more residence cases than a substantive refusal does.

The problem is also spread very unevenly. Among Ukrainian citizens, 6.2% of cases end up left unexamined; among Belarusians, 7.0%. But among Uzbek citizens the figure is 23.6%, among Colombians 39.9%, and among Georgians 41.0%. Counting success only among cases decided on the merits, a positive decision goes to 99.2% of Ukrainian applicants, 90.3% of Belarusian, 83.9% of Colombian and 71.2% of Georgian ones. The conclusion from these two series of figures is unambiguous: the main risk an applicant faces in the Polish system is not a negative assessment of their situation but a procedural stumble. The risk of that stumble is distributed extremely unevenly across citizenship groups, which points to an information and language barrier, not to differences in the merit of the applications.

Application completeness is the cheapest capacity reserve the system has. Every percentage point shaved off the “left unexamined” category is more than 4,000 cases a year (at the 2025 volume of outcomes) that nobody has to handle a second time — without hiring a single additional official.

The appeals system is running at full tilt

In 2025, the Head of the Office for Foreigners (UdSC) received 22,900 appeals in legalisation cases. Among resolved appeals concerning temporary residence, 47.5% ended in a decision favourable to the applicant (a year earlier: 33.8%), 15.6% in the case being returned for reconsideration, and 20.7% in the decision being upheld (a year earlier: 35.6%). In EU long-term resident cases, the share returned for reconsideration jumped from 9.9% to 26.9%.

We do not read these figures as an indictment of officials — we read them as a gauge of pressure. Case volume is growing at around 10% a year, and a record-loaded first instance is being corrected by the second. The system works, and corrects itself. Except that every correction means a second, and sometimes a third, round — in the first instance, in the second, and in the first once again.

Four waves: 2026–2031

The calendar of Poland’s residence-legalisation system for the next five years is not a forecast. Four dates are already written into the law and depend on nobody’s predictions. Only the scale of each is unknown, and where we have no data, we say so plainly rather than supply a number.

Wave one: the CUKR window (in progress)

Between 11 August and 8 September 2026 the number of people with active UKR status in the PESEL register fell from 950,286 to 868,037, that is by 82,249 people (8.7 per cent). It is the largest change between two consecutive publications of the register since January 2025; the previous one, in October 2025, came to 39,000. We recomputed the figures ourselves from the files the Ministry of Digital Affairs publishes every month in public dataset no. 2715 on dane.gov.pl, summing the 380 powiats; the details are in the methodology.

The loss was not spread evenly. Among people born in 2009 or later, that is children and teenagers, around 58,000 active statuses were lost, or 18 per cent of that group. Among people born in 2008 or earlier around 24,000 were lost, or just under 4 per cent. Among people born in 2022 or later the loss was around 3 per cent. We do not know how many of these people have left and how many remain in Poland under a different status; no institution has said.

The fall coincides in time with 1 September 2026. On that day, under Article 25 of the act of 23 January 2026 on the phasing out of arrangements (Dz.U. 2026 poz. 203), people who had received a PESEL number with UKR status on the basis of a declaration and had not confirmed their identity with a valid travel document by 31 August had their status changed ex officio to NUE. With it they lost the entitlement under Article 106(1) of the Act on granting protection to foreigners, that is the legality of residence that flows from temporary protection. No authority has said how many people that change covered, or linked it to the fall in the register. Nor do we; we set the dates side by side and ask.

NUE status on its own does not mean illegal residence: in the PESEL register it is held, as a rule, by every non-EU foreigner without UKR status, including people with a residence card. What the statutes do say plainly is what losing UKR status means for a person who has no other basis for residence. Publicly funded health-care benefits are due to people with UKR status in four cases: children under 18; women during pregnancy, childbirth and the postpartum period; victims of torture or rape; and residents of collective accommodation centres (Article 112c(1) of the Act on granting protection to foreigners). The 800+ child benefit is also tied to UKR status (Article 1(2)(2)(ca) of the Act on state aid in raising children), and the authority verifies ex officio the right to benefits already granted (Article 43(3) of the phasing-out act). The duty and the right to education do not depend on residence status (Article 165 of the Education Law). An application for a temporary residence permit filed during illegal residence ends, as a rule, in a refusal (Article 100(1)(9) of the Act on foreigners); the exceptions include spouses of Polish citizens (Article 165(1) of the Act on foreigners) and cases where the right to family life or the rights of the child require it (Article 187 points 6 and 7, read with Article 191(1)(4) of that act). The CUKR card requires UKR status on the day the application is filed. A renewed grant of the status is tied by the statutes to the date of re-entry into Poland and to an application within 30 days of crossing the border (Article 44b of the Act on the population register, Article 110a(2) of the special act). Whether another route exists is a question for the Ministry of the Interior and Administration (MSWiA).

The second date that changes the picture is written in two different acts. Council Implementing Decision (EU) 2026/1912 of 30 July 2026 extended temporary protection “do dnia 4 marca 2028 r.” (until 4 March 2028), and Polish law picked the date up automatically: Article 106(1) of the Act on granting protection to foreigners, as worded by the phasing-out act, ties the legality of residence directly to the Council decision, “do dnia, w którym ta decyzja zachowuje moc obowiązującą, chyba że ustawa stanowi inaczej” (until the day on which that decision remains in force, unless a statute provides otherwise). When Brussels extends protection, the domestic deadline moves by itself, with no amending statute.

The CUKR window does not follow that date. Article 42x of the special act fixes it rigidly, “do dnia 4 marca 2027 r.” (until 4 March 2027), and makes no reference to the Council decision; the provision contains no delegation to change it by regulation or by notice. Only an amending statute can move that date, and no such bill exists today either in the Government Legislation Centre (RCL) or in the Sejm (as at 16 September 2026). For anyone planning to stay in Poland on a CUKR card, the extension of protection has not added a single day. The year’s gap between the two dates is now in the hands of the legislature. The question is whether a change will come at all and, if so, whether it will come in good time.

No institution publishes how many people are eligible. Dopomo Data Lab estimates the figure at 720,000 to 780,000, or roughly 750,000. Our starting point is the 868,037 active UKR statuses as at 8 September 2026 in the PESEL register published by the Ministry of Digital Affairs (dane.gov.pl, dataset 2715). We subtract people who registered after 4 June 2025, since they can never satisfy the condition tied to that date: nearly 94,000 people registered in the second half of 2025, a further 41,500 in the first half of 2026, and around 3,900 in July. We correct that for the estimated share who have already left, and we add back children born in Poland, who qualify despite late registration. A control calculation by a second route — from the number of people holding status in mid-2025, less a year of departures and less the September fall in the register — lands in the same range. If every eligible person applied, the fees alone would come to PLN 316 to 343 million, all paid up front by the applicants. The first version of this report, calculated from the 959,000 statuses as at 1 July 2026, put the figure at 810,000 to 875,000; the difference is explained by the register losing 82,249 people between 11 August and 8 September 2026, as set out in the methodology. The government regulatory impact assessment, that is the document attached to the bill of the phasing-out act (Sejm print no. 2172), assumed around 800,000 eligible people.

Applications so far are far fewer. By 30 June 2026, 14,000 had been filed; by 31 July, 24,600 (UdSC reports “as at 1 July” and “as at 1 August 2026”); July alone added 10,600. If July’s pace held until the window closes, around 100,000 applications would have arrived by 4 March 2027, fewer than one in seven of the 750,000 eligible. For the CUKR route to cover everyone eligible, the pace would have to rise roughly tenfold, and to cover most of them, roughly fivefold. That is arithmetic, not a forecast: where deadlines are hard, applications arrive in the greatest numbers in the final weeks, and UdSC has not yet published its report for August.

We do not describe the card itself in detail here; its conditions are well known. The residence card bearing the annotation “Poprzednio posiadacz ochrony czasowej” (formerly a holder of temporary protection) is a three-year temporary residence permit for people who held UKR status on 4 June 2025, hold it on the day the application is filed and held it without interruption for at least 365 days. Applications have been filed since 4 May 2026 electronically only, through the Moduł Obsługi Spraw (MOS, the Case Handling Module), and in person, with fees of PLN 440 per person paid up front. The card relieves the applicant of documenting the purpose of their stay and their sources of income, and filing the application discontinues by operation of law any pending proceedings for an ordinary temporary residence permit. A full description of the conditions, documents and most common mistakes is in the CUKR guide on dopomo.pl.

Being eligible is not the same as having applied. An application requires a valid travel document, a fee of PLN 440 paid up front for each person, complete data in the state registers, and filing electronically and in person only. For a family of four, the fees alone come to PLN 1,760. How many eligible people each of these barriers will stop is unknown, and we do not estimate it.

Wave one is therefore predictable as to its deadline and unpredictable as to its shape. How many eligible people will apply, and when, depends on the information that reaches them and on whether they file a complete application the first time. Every application left unexamined on formal grounds comes back to the same desk; every complete one relieves it. That is why, instead of a forecast, we give the deadlines written in the statutes and figures that can be checked. Waves described in this way are something government offices, employers and local authorities can prepare for.

Summary: the burden is already settled, its shape is not

As at 8 September 2026, roughly 750,000 people were eligible for a CUKR card, and legal residence based on temporary protection runs, under the law as it stands, until 4 March 2028. September 2026 showed on a small scale what the day a status expires looks like: the register lost 82,249 people, and those among them who lost UKR status and have no other basis for residence lose, by law, the benefits tied to that status (including publicly funded health care for children and pregnant women, and the 800+ benefit), while a temporary residence application filed without legal residence ends, as a rule, in a refusal. On 4 March 2028 the same situation will face everyone who has not obtained another basis for residence by that day, and the window for the simplest of them, the CUKR card, closes on 4 March 2027. Several routes exist, but all of them lead to the same sixteen voivodeship offices. The chaos that would arise if hundreds of thousands of people were left without a basis for residence on a single day can be avoided: the deadlines are known, and the rules can be refined in advance.

The fact that few people are using CUKR today will not take the work away from those offices. It will change only when that work reaches them and how much it costs. CUKR is the lighter route, and the government says so itself: it relieves the applicant of documenting the purpose of their stay and their sources of income. An ordinary temporary residence permit demands those documents, so a case taken down that road costs the caseworker more time.

On top of that comes everything that follows the application. Every card issued must be collected in person within 60 days. Every card expires after three years. The CUKR card itself cannot be extended: staying on means filing an ordinary temporary residence application with the full set of documents. And those who stay will enter, in the years that follow, the EU long-term resident procedure, which in 2025 grew faster in percentage terms than any other.

One question remains open: whether the legislature will move the CUKR window as well. Without an amendment, protection runs until 4 March 2028 and the window closes a year earlier, on 4 March 2027. Where deadlines are hard, applications usually arrive in the greatest numbers in the final weeks before the window closes. If an amendment moves the window to 2028, Wave 1 stretches and shifts, and the three-year cliff moves with it to 2030–2031; cards already issued are unaffected, since they expire three years from issue. In both variants the four-wave model stands; what changes is the timing, not the mechanics. The earlier the decision comes, the more time government offices, employers and the applicants themselves have to prepare.

The four waves are therefore neither speculation nor anyone’s choice. They are four stages of the same matter, spread out over time, and the same group of people passes through all of them. The direction, moreover, has been set by the EU itself: the Council Recommendation of 16 September 2025 (C/2025/5129) describes a coordinated transition from temporary protection to national statuses, and the CUKR card is Poland’s mechanism for that transition. The extension of protection allows more time for it, but it does not take the cases off the desks. Predictability is a resource here: known deadlines make it possible to plan staffing, information and procedures, and an application that is complete the first time is a case no official has to handle twice.

What works: a complete application the first time

Poland’s residence legalisation is an inherently distributed system: sixteen voivodeship offices, separate fee accounts, local practices, four main applicant languages — and, from this year, a fully electronic, do-it-yourself procedure in which no representative can fix anyone’s mistakes. In such an environment, the cheapest intervention is not an extra staff position but information that makes the application complete the first time.

Digitalising procedures through MOS is a step in the right direction — register-level validation stops some errors before a case ever reaches an official’s desk. The second link is preparing the applicant. That is what dopomo.pl is for — a Polish legal-tech startup that provides verified information about legalisation procedures free of charge in four languages (Polish, Ukrainian, Russian and English). The platform’s AI assistant bases its answers on official sources and attaches a source reference to each one. Questions about international protection are routed to UNHCR and the Office for Foreigners before the model is run. A bank account number is shown only when it comes from a verified source: the answer is held back until that check has run. The platform checks eligibility for the procedure and guides users step by step through the MOS application, creates a biometric photo and checks it against official requirements, and points to the correct, verified fee accounts for each voivodeship. The same information engine works for every next procedure and every next language group.

The goal is shared by all sides: fewer cases left unexamined, fewer summonses and fewer fees irretrievably lost — and shorter queues, including for Polish citizens handling their own affairs at the same offices.

This report and the dopomo.pl service are for information purposes only and do not constitute legal advice in any individual case.

Ten questions the data does not answer

We make no policy recommendations; that is what state institutions are for. But ten questions emerge from the registers and the statutes, questions that will have to be answered whatever the political colours. Each has an addressee.

1. How many people the status change covered. To the Ministry of the Interior and Administration (MSWiA): how many people lost UKR status on 1 September 2026 under Article 25 of the act of 23 January 2026, and is it the same group the register shows as 82,249 people fewer?
2. The reasons a status ended, in the data. To the Ministry of Digital Affairs: will dataset no. 2715, published every month on dane.gov.pl, be supplemented with the reason a status ended (departure, change of status, death), given that the fall from 950,286 to 868,037 is the largest change in the series since January 2025?
3. Children with NUE status. To MSWiA and the Ministry of Health: on what residence basis, and with what access to health care, are children from the 2009 and later birth cohorts, around 58,000 of whom have dropped off the register, living in Poland today if they have not left the country, given that Article 112c of the Act on granting protection to foreigners ties health-care benefits to a PESEL number with UKR status?
4. The way back. To MSWiA: does a person with NUE status have any route back to temporary protection other than re-entry and an application within 30 days (Article 44b of the Act on the population register, Article 110a(2) of the special act)?
5. Information campaign. To MSWiA and the Office for Foreigners: is a nationwide information campaign on the CUKR card planned, and will it explain in advance what awaits card holders in 2029–2030?
6. A year’s gap. To the legislature: will Article 42x of the special act be aligned with Council Decision (EU) 2026/1912, and when, given that protection runs until 4 March 2028, the CUKR window ends on 4 March 2027, and no bill exists in either the RCL or the Sejm?
7. The government’s arithmetic. To MSWiA: the government regulatory impact assessment attached to the phasing-out bill (Sejm print no. 2172) assumed around 800,000 eligible people. Will it be recalculated now that the register stands at 868,037 and 24,600 applications were filed by the end of July?
8. A plan for February 2027. To the Office for Foreigners and the wojewodas: what plan do the offices have for the final weeks of the window if CUKR card applications pile up before 4 March 2027, and how do they intend to inform eligible people in advance?
9. The path after CUKR. To the legislature: will a simplified path to the next permit be created for CUKR card holders before the three-year cards start expiring in 2029–2030, or will each of these people file a full temporary residence application?
10. Multilingual information. To central and local government: if a formal error closes more cases than a substantive refusal, and the next applicant groups speak Spanish, Nepali and Tagalog — who is responsible for making sure the information they need actually reaches them?

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