Phasing out aid for citizens of Ukraine – what changes with Draft UD345 and Print No. 2172?
After four years of extraordinary aid measures, Polish migration policy is entering a phase of radical reconstruction. The government bill (UD345) ends the period of the “Special Act”.
Evolution of the Migration Policy Paradigm of the Republic of Poland
Nearly four years after the escalation of the armed conflict in Ukraine, the Polish legal and administrative system is entering a phase of fundamental transformation. The current model, based on interventionist solutions and the Special Act, is being exhausted in favor of systemic solutions. By adopting the draft act on January 20, 2026, regarding the expiration of solutions resulting from the Act on Assistance to Citizens of Ukraine in Connection with the Armed Conflict on the Territory of that State and on the amendment of certain other acts (No. in the list of legislative works: UD345), the Council of Ministers defined a new direction for state policy. [1]
The draft concerns the gradual phasing out of special regulations introduced after the outbreak of the war in Ukraine. It involves unifying the rules of assistance for persons under temporary protection and adapting the law to the current migration situation. The new regulations also implement EU recommendations regarding the granting of temporary protection until March 4, 2027 (Council Directive 2001/55/EC) and the gradual transition to general rules for all foreigners, while maintaining solidarity with persons affected by the war. [1]
This report constitutes an analysis of the government plan, examining the implications of the transition from the “crisis management” stage to the “stabilization and integration” stage. The analysis is based on the assumption that the proposed regulation is not merely a technical amendment, but a change in support policy – from unconditional humanitarian aid towards conditional integration based on identity verification, economic independence, and the unification of standards for all foreigners staying in the territory of the Republic of Poland. [2]
Geopolitical and Social Context of the Reform
The government’s decision to phase out the Special Act of March 12, 2022, results from an assessment of the stabilization of the refugee situation. According to data from the Ministry of the Interior and Administration (MSWiA), the majority of adult Ukrainian citizens have taken up employment, and their children have been included in the education system, which makes maintaining extraordinary legal preferences unjustified in the long term. [2] At the same time, Poland, implementing the decisions of the Council of the European Union, is obliged to ensure temporary protection until March 4, 2027, which necessitates balancing between phasing out privileges and maintaining minimum standards of international protection. [2]
It is worth noting that the change in internal policy does not mean Poland is withdrawing its support for Ukraine as a state. Parallel to the work on the act, the government continues material, military, and political aid. This indicates a dual strategy: tightening requirements for migrants within the country while maintaining support for the Ukrainian state in the international arena.
Legislative Architecture of Project UD345
The draft act, adopted by the Council of Ministers at the request of the Minister of the Interior and Administration, assumes a precise schedule for phasing out support instruments. The key date for the entry into force of the new regulations is March 5, 2026, which corresponds to the cycle of decisions on temporary protection. [2]
Implementation Schedule
The complexity of the legislative process required the design of transitional periods aimed at avoiding regulatory shock for both beneficiaries and public administration. The table below presents the key timeframes resulting from the draft:
| Cut-off Date | Legislative Event or Legal Effect | Source |
| January 20, 2026 | Adoption of the draft act by the Council of Ministers. | [2] |
| March 5, 2026 | Entry into force of the main part of the act; beginning of the new legal regime. | [2] |
| June 30, 2026 | Expiration of rights to collective housing for existing vulnerable groups. | [2] |
| August 31, 2026 | Final deadline for identity verification (showing a passport) for PESEL UKR holders. | [2] |
| March 4, 2027 | The date until which temporary protection is extended in the territory of the Republic of Poland. | [2] |
Analysis of the schedule indicates a culmination of social effects in mid-2026. Two critical deadlines coincide then: the loss of housing (June) and the final passport verification (August). This may generate increased pressure on voivodeship and commune offices during the holiday period.
New Regime of Legal Stay and Identity Verification
The foundation of the reform is the tightening of the registration system. In the initial phase of the conflict, the priority was the speed of registration, which led to the granting of UKR status based on declarations or documents that were not travel documents. Project UD345 recognizes this state as temporary and unacceptable in the long term.
The Passport Imperative and PESEL UKR Status Verification
The new regulations introduce an absolute obligation to verify identity at the commune office using a valid travel document (passport). This applies to persons who obtained a PESEL number based on other documents or declarations. The deadline for fulfilling this obligation expires on August 31, 2026. [2]
The legal consequences of failing to meet this requirement are far-reaching. Lack of verification will result in the loss of UKR status, and consequently – the cessation of temporary protection. From the perspective of state security, this is a mechanism eliminating persons with unconfirmed identities from the system. However, taking into account the difficulties in obtaining passports by Ukrainian citizens (especially men of draft age staying abroad), this provision may lead to the systemic exclusion of part of the refugee population from legal circulation in Poland.
The “30 Days” Procedure for New Arrivals
The project radically changes the legal situation of persons newly arriving in Poland. A sine qua non condition for benefiting from temporary protection will be the submission of an application for a PESEL number with UKR status within a non-extendable deadline of 30 days from the date of arrival in the territory of the Republic of Poland. [2]
Failure to submit an application within this deadline will be interpreted as a resignation from temporary protection. This is a significant tightening of the course compared to previous practice, which allowed for some flexibility. The introduction of a rigid deadline aims to eliminate the phenomenon of “residence tourism” and organize the status of foreigners immediately after crossing the border.
Digitalization as a Tool for Control and Integration
Digital tools will play a key role in the process of legalizing stay. The legislator decided to maintain the Diia.pl electronic document as an official confirmation of the legality of stay in Poland, serving as a residence permit in the Schengen area. [2] Additionally, refugees will gain broader access to the mObywatel application, which fits into the broader strategy of digitizing public services implemented by the Ministry of the Interior and Administration. [3]
The maintenance of an entry and exit registry by the Border Guard complements the digital system. This registry will allow for automatic verification of the continuity of stay, which is crucial for determining the right to benefits and maintaining protection status (loss of status after departure for more than 30 days). [3]
Transformation of the Social and Living Benefits Sphere
The most noticeable change for beneficiaries will be the reduction in the scope of social aid. Project UD345 moves away from the principle of equating the rights of refugees with the rights of Polish citizens in terms of family benefits, shifting the burden of support to mechanisms typical for assistance to foreigners.
Redefinition of Social Assistance
Under the new regulations, access to social assistance will be limited to a catalog of benefits available to foreigners staying in Poland based on consent for tolerated stay or for humanitarian reasons. [2] This means a drastic narrowing of support forms to:
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The right to shelter.
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Meals.
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Necessary clothing.
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Targeted allowance. [2]
This is a return to international standards, where refugee aid is interventional and minimal in nature, rather than transfer-based and income-oriented. Benefits such as “800+” or “Good Start” will be gradually phased out after the end of transitional periods, which is expected to bring tangible savings to the state budget and encourage migrants to become fully professionally active.
Reform of the Housing System
Particularly important changes concern housing policy. The current system, based on broad access to collective accommodation and financing of stays with private individuals, is being replaced by a two-pillar model focused on the groups most in need.
The project provides for the expiration on June 30, 2026, of rights to reside in collective centers for groups that previously benefited from protection as “vulnerable” (e.g., parents with three children, temporary guardians). [2] The legislator assumes that the four-year period of stay was sufficient to achieve housing independence.
The new system assumes a division into:
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Short-term accommodation (crisis): Intended for persons fleeing war, available for a maximum of 60 days (with a limit of 12 months from the outbreak of a given refugee wave). [2]
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Long-term accommodation: Reserved exclusively for persons objectively incapable of independent existence, i.e., the elderly, disabled persons, pregnant women, mothers with infants, and persons after hospitalization. [2]
Changes in the Health Care System
In the area of medical care, there is a transition from a budget model (financed from the state budget) to an insurance model (financed from contributions). This is a systemic change aimed at equalizing the obligations of Ukrainian citizens with the obligations of other residents.
The Insurance System as a Rule
The new regulations assume that Ukrainian citizens will be subject to general health insurance rules. This means that the right to free benefits will depend on the payment of contributions (e.g., under an employment contract). Uninsured persons will lose the right to free care, being treated analogously to uninsured Polish citizens. [2]
Exceptions and Protective Clauses
Despite tightening the rules, the Polish state will retain care functions for particularly vulnerable groups. Free health care will be maintained for:
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Children.
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Women during pregnancy and the postpartum period.
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Victims of violence.
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Wounded soldiers.
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In cases of sudden threat to life. [2]
Such a solution aims to secure public health and ensure humanitarian treatment of the weakest, while simultaneously sealing the system against abuse.
Labor Market: Challenges and Perspectives
Integration into the labor market remains a key goal of the amendment. Project UD345 maintains simplified access to the labor market but introduces modifications that raise concerns among business circles.
How will the rules for employing Ukrainian citizens change?
In the version of the project sent for government proceedings, however, the postulates of employers were taken into account. Firstly, transitional provisions were introduced to increase stability in the labor market.
Experts from the Lewiatan Confederation explain that the project specifies what information a notification on entrusting work to a citizen of Ukraine must contain and in what situations it will be necessary to submit a new notification.
A new notification will be required in strictly defined cases, including, among others, at the moment of:
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a change in the type of contract between the employer and the employee,
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a change of position or type of work performed,
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a reduction in working time or the number of hours,
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a reduction in the monthly or hourly wage rate indicated in the notification.
At the same time, the project introduces a significant change compared to the regulations in force so far: the lack of notification will not result in the illegality of the entrustment of work. Citizens of Ukraine under temporary protection will retain free access to the labor market, and employers will still be able to employ them without the need to obtain a work permit (with the exception of positions reserved for Polish citizens).
Additionally, failure to fulfill the notification obligation will be punishable by a fine ranging from PLN 1,000 to PLN 3,000.
Transitional Provisions Crucial for the Labor Market
The adopted project also includes transitional provisions, which — according to employers — are of significant importance for the stability of the labor market. According to them:
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notifications of entrusting work made before the entry into force of the new regulations will retain legal effects and allow for the legal continuation of work without the threat of a fine,
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during the three-year transitional period, notifications may also concern citizens of Ukraine staying in Poland legally, and not exclusively those covered by temporary protection.
These are solutions consistent with the postulates submitted during the work on the project, as emphasized by employment experts. However, a continued struggle for the interests of companies is announced.
On the list of employers’ priorities remains the abandonment of the suspension of deadlines in cases conducted by voivodeship offices and the maintenance of temporary protection in the event of the departure from Poland of Ukrainian citizens directed to perform work or provide services outside of Poland for a period longer than 30 days.
Education: End of the Transitional Period
The area of education has been treated specifically, taking into account the school year cycle. The legislator decided to extend the validity of special act solutions until the end of the 2025/2026 school year. [2]
Until then, the following will be maintained:
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Additional Polish language lessons.
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Preparatory classes.
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Simplified rules for employing teachers and intercultural assistants. [3]
After this date, full inclusion of Ukrainian students into the Polish education system on general terms will take place. This is a clear signal that four years after the outbreak of the war, the stage of linguistic and cultural adaptation should be completed in favor of full curriculum integration.
Summary and Final Conclusions
The draft act on the expiration of solutions resulting from the act on assistance to citizens of Ukraine (Project UD345) constitutes a watershed moment in the history of Polish migration policy. It is a legal act of an ordering nature, which closes the stage of extraordinary state mobilization in favor of a systemic, long-term integration policy.
Key Solutions in Brief
Solutions from the Special Act that will be incorporated into the systemic act on granting protection to foreigners:
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confirmation of legal stay through a PESEL number with the appropriate status;
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electronic identity confirmation instead of paper documents;
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the possibility of using the mObywatel application;
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simpler rules for access to work and conducting business activity.
The project organizes the rules of access to:
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public health care,
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social benefits,
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food aid and accommodation – still facilitated for persons in difficult situations, e.g., the elderly or persons with disabilities.
Transitional provisions will cover:
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completion of family benefit payments in the current period;
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settlement of funds transferred to local governments for commissioned tasks;
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maintenance of the validity of visas and residence documents until March 4, 2027;
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preservation of professional, educational, and economic rights acquired under the Special Act;
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settlement of the Assistance Fund.
Until the end of the 2025/2026 school year, the following will be maintained, among others:
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additional Polish language lessons;
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preparatory classes in schools;
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simplified rules for employing teachers and intercultural assistants.
The registry of entries and exits kept by the Border Guard is maintained. This will allow checking whether a given person is actually staying in Poland and for how long.
