On 27 April 2026, the full digitisation of the process for legalising foreigners’ stay in Poland came into force. Just a few days later, on 4 May, applications will open for the CUKR card for people covered by temporary protection. The changes are intended to simplify and speed up procedures, but in practice they mean a complete change in the rules: the end of paper applications, mandatory electronic processing and greater responsibility placed on foreigners and employers. All this is happening at a time of record pressure on public administration and with hundreds of thousands of potential new applications. The first system tests and emerging errors show that MOS 2.0 still requires refinement.
From 27 April, the only way to submit a residence application is through the MOS 2.0 system. A foreign national must independently create an account, have a trusted profile and sign the document electronically. However, this is only the first stage. In the case of work or study, the employer or educational institution is also included in the process, and must complete the data and sign the document in accordance with the rules of representation, either under the National Court Register or the business registration entry.
“Today, a foreign national is not able to submit an application independently, and at the same time the system leaves no room for formal errors. Already at the stage of completing the application, they indicate the email address of the organisation, which receives a dedicated link and is required to fill in data concerning the conditions of stay and employment. A response from the indicated entity is therefore necessary, and it must act within a specified time and in line with its adopted mode of representation. The signature must be provided by an authorised person — often a management board member — which further extends and complicates the process for companies. Only after these steps have been completed is the application considered effectively submitted. If something does not align, the application is not created and does not pass through the system,” says Julia Nowicka, expert in the legalisation of foreign employment at Grupa Progres.
A system with no margin for error
Although the regulations formally allow an application to be submitted even on the last day of legal stay, in practice the new rules completely change this reality. Given the current structure of the system, this assumption is purely theoretical. The process requires time, both to prepare the foreign national to use the system and to allow the employer to respond and gather the necessary documents.
“In reality, a foreign national should start the procedure at least one month, and preferably three months, in advance. Otherwise, they risk not being able to complete the process in time,” Julia Nowicka emphasises.
Failure to submit the application on time means an immediate transition into illegal stay. This brings further consequences: loss of the right to work and liability on the employer’s side, including fines ranging from PLN 3,000 to PLN 50,000 and the risk of inspection.
“I see a real risk that some foreigners will end up in the grey zone against their will, and that their stay will be considered illegal — not because of a deliberate breach of the rules, but because of a lack of knowledge and an inability to navigate the procedure,” adds the Grupa Progres expert in the legalisation of foreign employment.
Digitisation amid an overloaded system
The change comes at a time when the administration is already operating at the limits of its capacity. Data from Poland’s Supreme Audit Office show tens of thousands of pending cases, months-long delays and decisions issued after more than a year, and in extreme cases after several years. In one office, the number of cases exceeded 38,000, with nearly 690 proceedings on average per employee.
Even more alarming data come from Lower Silesia, where there are 60,600 overdue cases and 6,800 applications left unprocessed, with total arrears reaching almost 61,000 proceedings. In extreme cases, the waiting time for a decision can be as long as three years. This is accompanied by systemic costs: one office paid out more than PLN 12 million due to the excessive length of proceedings.
“These figures show one thing: the system is already overloaded. Digitisation is being introduced at a moment of maximum tension,” comments Julia Nowicka.
The scale of the challenge is growing along with the number of foreigners in Poland. More than 966,000 people have active UKR status, while the total number of PESEL UKR numbers issued has exceeded 2 million. This is a diverse group, including people from particularly vulnerable categories who may face the greatest difficulties in using a digital system.
“Unfortunately, a large proportion of foreigners do not know what a trusted profile is or how to use an electronic signature. There is also a shortage of officials who could explain this, and the lack of Polish language skills is an additional barrier. As a result, many people are unable to go through the electronic procedure on their own and often do not have real support in handling it,” notes the Grupa Progres expert.
The next wave: the CUKR card
On 4 May, the system will face an additional burden with the launch of applications for the CUKR card for people covered by temporary protection. This means hundreds of thousands of potential applications. More than 900,000 people currently benefit from temporary protection, which directly translates into the scale of the process and additional pressure on administrative offices. Although the regulations provide for 180 days to examine cases, administrative experience shows that these deadlines may be difficult to meet.
“We are facing an enormous number of applications — even around 800,000 or more in less than a year. This is not an ordinary administrative burden, but a scale that will have a real impact on the efficiency of the entire system. Offices will have to handle new cases while also catching up with existing backlogs, which in practice means a risk of further extending processing times,” Julia Nowicka points out.
At the same time, some foreigners — estimated at between 6% and 12% — will not meet the conditions for obtaining the card. This creates a risk of exclusion from the system and the lack of an alternative path to legalise their stay.
“We are dealing with a situation in which the system is accepting a huge number of applications while, at the same time, some people have no path to legalisation. This is a very difficult combination, because on the one hand pressure on the administration and case-processing times are increasing, while on the other there is a real risk that some foreigners will be excluded from legal stay,” the Grupa Progres expert stresses.
As procedures become more complex, the risk of a grey market in intermediary services and informal “assistance” with submitting applications is also growing.
“Where the system is difficult and unintuitive, intermediaries appear. This is a natural mechanism. The problem is that it often happens outside any control and generates further risks,” says Julia Nowicka.
MOS 2.0 has launched — and immediately encountered obstacles
The first experiences with the MOS 2.0 system on its launch day, 27 April, clearly show that despite the justified direction of digitisation, implementation took place in conditions where both users and the tool itself were insufficiently prepared. The system was tested by the Grupa Progres team, and employees began reporting questions already in the morning.
“Already on the first day, there was a surge of questions from foreigners about the possibility of submitting an application in paper form, which confirms that awareness of the changes is insufficient despite the information activities carried out. This means that a much longer adaptation period is necessary. In addition, emerging formal and technical errors, including inconsistencies between the generated forms and the requirements set out in the regulation, will lead to the need to supplement missing information, which will directly extend proceedings,” Julia Nowicka emphasises.
The expert in the legalisation of foreign employment at Grupa Progres adds that the way the form is handled by the employer is also a significant operational limitation. The lack of an option to save, edit or attach documents forces real-time action and error-free representation, or the prior preparation of powers of attorney. Even technical issues such as the photo format require additional tools and preparation, showing that the process is not intuitive for the end user.
In her view, the new system — instead of immediately simplifying procedures — is initially creating additional entry barriers, increasing the risk of formal errors and requiring much greater preparation from both foreigners and employers.
