When do you need to re-register a Ukrainian citizen? The most common employer mistakes in 2026

For many Polish HR departments, the simplified procedure for employing Ukrainian citizens under the special act has become a daily, almost automatic routine. The introduction of a notification mechanism to District Labor Offices (PUPs) significantly relieved companies of bureaucratic burdens. However, it is precisely this apparent simplicity that now generates the greatest legal risk. I often see clients holding a deep, yet mistaken, belief that a single submitted and accepted notification secures the legality of an employee's stay and work indefinitely. By mid-2026, the administrative reality is far more unforgiving. Any dynamic change in the company's structure, a promotion, renegotiation of rates, or modification of employment terms can unknowingly invalidate the existing legal basis. Employing Ukrainian citizens requires continuous monitoring of changes in employment conditions, and failure to re-register within the statutory deadline is treated by the National Labor Inspectorate as equivalent to completely illegal employment.

Re-registration of a Ukrainian citizen - when is it absolutely required?

Re-registration of a Ukrainian citizen with the District Labor Office via the praca.gov.pl portal is absolutely required whenever key employment conditions are modified, such as the type of contract, position, scope of duties, working hours, or reduction in remuneration.

The special act clearly defines the boundary conditions. The employer is obliged to notify the office about a Ukrainian citizen commencing work within the legally specified period. This notification includes very detailed parameters: the exact number of hours or full-time equivalent, the precise remuneration rate, the job title, and the type of contract being signed.

In 2026, any discrepancies between the actual situation (e.g., payment declared in ZUS statements) and the data recorded at the labor office are instantly detected thanks to automatic data exchange between the ZUS, tax offices, and PIP systems. Statistics show that over 42% of all formal irregularities detected during inspections of foreign employment this year concern precisely the lack of updated notifications after changes in working conditions. Employers simply forget that an addendum to a contract very often necessitates restarting the entire notification procedure.

Catalog of changes requiring notification to the office

Most companies do this incorrectly, assuming that since the employee is not changing employers and physically continues to come to the same factory or office, the office is not interested in the technical details of the contract. This is a mistake that costs thousands of zlotys during inspections.

There is a strict catalog of situations in which re-registration of a Ukrainian citizen is absolutely necessary:

• Change in contract type: (e.g., transitioning from a civil law contract to an employment contract).
• Change in job position: even within the same department (e.g., promotion from warehouse worker to senior forklift operator).
• Modification of duties: if the new tasks differ diametrically from the profile originally reported to the PUP.
• Reduction in working hours or number of hours: any reduction in full-time equivalent modifies the conditions for legal employment.
• Reduction in basic remuneration: any downward adjustment of salary requires a new notification (note: a salary increase usually does not create such an obligation, provided other conditions remain unchanged).

Myths surrounding changes to employment contracts and the risk of transitioning to B2B / Civil Law Contracts

When you DO NOT need to re-register an employee?

Many myths have arisen around the regulations, which in turn lead to bureaucratic overzealousness. Employers often ask whether signing another employment contract with the same employee (e.g., after the probationary period ends) always requires a new notification.

If an employee remains in the organization in the same position, with the same scope of duties, identical working hours, and unchanged (or higher) remuneration, the mere formal transition between types of employment contracts does not generate the obligation for a new notification. This applies to the following sequences:

1. Transition from a probationary contract to a fixed-term contract.
2. Transition from a probationary contract directly to an indefinite-term contract.
3. Extension of a fixed-term contract (signing an indefinite-term contract).

In these specific cases, the continuity of employment under identical conditions is maintained, so the original notification retains its legal validity.

The biggest risk: Change in cooperation form (Transition to a Contract of Mandate / B2B)

The situation changes dramatically when the company decides to change the legal nature of the relationship with the employee. The most common critical error is changing a contract of mandate to an employment contract or vice versa, without informing the labor office.

When an employee from Ukraine finishes performing tasks under a contract of mandate and signs an employment contract starting from the new month, they become a completely "new" employee for the legal system. The employer is obliged to close the old notification and, within the statutory period, send a completely new notification, taking into account the specifics of the position, the requirements of the Labor Code, and the new remuneration rules.

Evolution of the job position and employment conditions

Promotions and new responsibilities within the HR structure

A natural element of every employee's development within a company's structure is vertical or horizontal promotion. From an HR perspective, this is a source of pride; however, from the perspective of an employment legalization specialist, it is a moment of increased risk.

If an employee from Ukraine was registered as a "production worker" and after a year of diligent work is promoted to "foreman" (which involves a change in occupation code, increased responsibility, and team management), the old notification no longer reflects reality. During an inspection, a National Labor Inspectorate inspector will compare the entry in the contract/addendum with the notification at the District Labor Office. If they find a discrepancy in the job title, they will consider the work in the foreman position to be illegally assigned.

Cost cutting, reorganizations, and staff reductions

In the era of budget optimization in 2026, many companies are opting for flexible work time management. Reducing full-time employment to half-time or decreasing the monthly number of hours for a contract of mandate are popular methods to combat rising operating costs.

Remember: any reduction in working hours or decrease in remuneration (even if motivated by the company's difficult financial situation or the employee's direct request) absolutely requires going through the new notification procedure. The labor office must know whether the foreigner still earns an amount that meets the requirements for minimum wage or the minimum hourly rate, calculated for the specified working time.

Practical HR Checklist: Before signing an addendum or a new contract

To minimize the risk of human error in the HR team, before implementing any changes to the employment conditions of a Ukrainian citizen, you must absolutely answer the following checklist questions:

Tools for automating notification monitoring

Managing hundreds of notifications on the praca.gov.pl platform on a large scale can be challenging. Modern HR departments should leverage technology:

• HR and payroll systems integrated with modules for foreign nationals: Software that automatically blocks the generation of an addendum changing a position without simultaneously generating an alert for the HR specialist: "Warning! Employee covered by special legislation. Notification to the District Labor Office (PUP) required.".
• Centralized notification registers: Internal databases in Excel or Sharepoint-type systems, where scans of sent XML notifications are assigned directly to employee profiles, facilitating a quick internal audit before an anticipated visit from the Labor Inspectorate.

FAQ - Employing Ukrainian Citizens

1. How much time do I have to re-register a Ukrainian citizen after changing contract terms in 2026?

Regulations specify a strict, non-extendable deadline for submitting a notification to the labor office. Even a one-day delay means that work performed from the moment of changing conditions until the day the late application is submitted is considered illegal.

2. If an employee from Ukraine changes their place of work (e.g., a different company branch), do I need to send a new notification?

Yes. If the change in location involves a change in the geographical conditions of employment that were directly indicated in the original notification to the District Labor Office (PUP), an update must be made by submitting a new notification.

3. Does increasing the salary of an employee from Ukraine require re-notifying the office?

No. A change in conditions favorable to the employee, consisting solely of a salary increase (while maintaining the same position, employment type, and contract), does not impose an obligation on the employer to generate a new notification in the praca.gov.pl system. A standard salary addendum to the contract is sufficient.

4. What happens if I forget to send a new notification, and the employee has already been working in the new position for two months?

There has been a violation of regulations regarding the legality of employing foreigners. In such a situation, the situation should be legalized as soon as possible by sending a correct notification; however, the company must be aware that the two preceding months will be classified during a potential Labor Inspectorate (PIP) inspection as a period of illegal work assignment, with all legal and financial consequences.

5. Does a change of surname for a female employee from Ukraine (e.g., due to marriage) require a new notification?

No. A change in personal data or identity document number (passport) requires updating data in the ZUS database and potentially notifying the office about the change in formal data, but it does not invalidate the essence of the work assignment itself and does not require going through the notification procedure anew.

Key Takeaways

• Any addendum changing the position, employment type, or reducing the salary of a Ukrainian citizen automatically triggers the obligation to send a new notification to the District Labor Office (PUP).
• Transitioning from a contract of mandate to an employment contract without a new notification to the office is treated by the Labor Inspectorate (PIP) as blatant, illegal employment.
• Immediately implement an internal verification procedure in the HR department: no addendum for a foreigner can come into effect without simultaneous verification on the praca.gov.pl portal.

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