Poland is set to tighten its intra-corporate transfer (ICT) work permit regulations, with changes initially slated for May 1, 2025, but now expected around June 1, 2025, due to legislative delays. These new rules introduce significant hurdles for companies utilizing ICTs, demanding a closer look at corporate structures and international assignment strategies.
Key changes include requirements for direct or indirect shareholding or common management between the transferring and receiving entities, demonstration of actual business activity by the transferring entity in its country of registration, and proof that the employee is already employed by the transferring entity at the time of application. A service contract signed by the transferring entity will also be mandatory. These changes aim to limit the use of ‘letterbox companies’ and ensure compliance with Polish labor laws, minimum remuneration standards and authorized contact persons.
My insight: Employers should consider submitting ICT work permit applications well in advance of the effective date to avoid potential delays. These reforms are part of Poland’s broader immigration law overhaul, reflecting a trend of increased scrutiny of posted worker rules dating back to 2016, and aligning with anticipated immigration reforms later in 2025.