Poland will introduce new restrictions on the issuance of work permits under intra-corporate transfer (ICT) from 1 May 2025. Find out what changes await companies and employees working under these permits

From May 1, 2025, Poland will introduce a number of restrictions to the procedure for granting work permits within the framework of an intra-corporate transfer (ICT). Read about the main changes in the legislation and who will be affected by the innovations in this article.

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What will change in the intra-corporate transfer procedure in Poland?

The rules for intra-corporate transfer will become stricter, in particular:

- Shareholder or management relationship

A work permit will be granted only if one company owns shares in the other, or if they have common board members.

- Real business activity

A permit will not be granted if the company sending the employee does not carry out actual economic activity in the country of registration.

- The employee is already working in a corporation

A permit will be granted only if the employee is already working for the organization that will transfer him at the time of submitting the application.

- Service Agreement

To obtain a work permit for an intra-company transfer, a signed service agreement with the legal entity transferring the employee will be required.

- Other changes

There will be new requirements for an ICT work permit, including supporting documents confirming compliance with Polish labor law, minimum wage and contact persons.

Who will be affected by the new Polish ICT restrictions?

Multinational companies transferring employees to Poland under ICT permits must meet stricter eligibility criteria.

How will the legislative changes affect employees in Poland?

- Early application submission

Due to these changes, employers should apply for a work permit before the new restrictions come into force.

- Restrictions on “letterbox companies”

Such innovations will significantly limit the activities of companies that do not actually carry out commercial activities and only serve as formal organizations for transferring employees to Polish companies.

- Possible delays

As the authorities transition to the new rules, employers should expect delays in processing applications for permits from May 1, 2025.

- Changes in corporate structure

Many business models based on temporary postings of employees to Poland may become more complicated, and companies are likely to have to adjust their structures or contracts to comply with the new requirements.

These changes are part of broader reforms of Polish immigration law. The reforms come against the backdrop of planned large-scale changes to Poland’s immigration policy, expected in 2025.

Get advice from an employment lawyer to learn more about intra-corporate transfers (ICTs) in Poland.

Reminder! Poland will launch a special system that aims to prevent intermediaries from using visa meetings. We have already told you how the new system will work, why Poland is tightening the rules and how these changes will affect visa applicants.

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