On 12 December 2025, Poland's president signed a major amendment to the Act on Foreigners (the act of 21 November 2025 amending the ustawa o cudzoziemcach). It changes how legalization applications are filed, introduces a new card for Ukrainians, and — separately, in parliament — a tightening of citizenship requirements is under debate. Here's what's already in force, what's being rolled out, and what's still just a proposal.

MOS is already live: what changed on 27 April 2026

The MOS portal (Moduł Obsługi Spraw) officially launched on 27 April 2026 — available at mos.cudzoziemcy.gov.pl. Since that date, applications for a temporary residence permit (zezwolenie na pobyt czasowy), permanent residence (pobyt stały), and EU long-term resident status can be filed only electronically. Paper applications sent but not received by a voivodeship office before 27 April aren't reviewed at all — the postmark date doesn't count.

What you need to file through MOS:

After submission, you can save the application as a PDF and XML and download the UPO (official proof of receipt). Once a voivodeship office employee verifies your application, the system generates a zaświadczenie o złożeniu wniosku — a certificate that now replaces the old stamp in your passport and confirms your legal stay while the case is being reviewed. The voivode will then summon you for an in-person appointment to take fingerprints, a signature sample, and check your original passport.

Don't leave filing until the last day of your legal stay — gathering every attachment in a single day often isn't realistic, especially if you need a signature from an employer or university, which can take weeks to obtain.

What's still on paper. Not everything has moved online — applications are still filed on paper for: intra-corporate transfers (ICT) and related long-term mobility for managers/specialists, and family reunification (or applications from a family member of a Polish/EU/UK citizen) when the applicant is currently outside Poland.

The CUKR card for Ukrainians: what it is and who qualifies

Since spring 2026, Ukrainians holding PESEL UKR (temporary protection status) can obtain a residence card valid for 3 years — the so-called CUKR card (officially: a card annotated "Poprzednio posiadacz ochrony czasowej" — "former temporary protection holder"). Applications go through the same MOS portal.

What the CUKR card provides:

Important: a 60-day deadline to collect your finished card

An easily overlooked rule: if a foreigner doesn't collect their finished residence card within 60 days of being notified by the voivodeship office that it's ready, the residence permit isn't issued and the card itself is invalidated. This applies to any residence card, not just the CUKR — and it's exactly the kind of technical detail that has historically cost applicants months of delay.

Ukraine's special law is winding down: what to sort out before March 2027

A separate strand of the reform is the gradual phase-out of the special law providing assistance to Ukrainian citizens. From 5 March 2026, most of its benefits are cancelled, and Ukrainians' residence status is gradually folded into the general Act on Foreigners. Legal stay is preserved until 4 March 2027 — by that date, you need a clear strategy:

Under debate: a possible extension of the residency period for citizenship, from 3 to 10 years

It's important to separate fact from proposal here. A presidential bill proposes extending the minimum continuous period of residence in Poland required to be recognized as a citizen from 3 to 10 years, plus a language exam, a loyalty declaration, and a tax-residency requirement. A tougher version proposed by PiS lawmakers (17 years) was rejected by the Sejm at first reading in January 2026. As of this article's publication, the presidential bill is still working its way through parliamentary procedure — this is not yet a rule in force, but it's worth tracking if citizenship is part of your legalization strategy.

What this means in practice

In short: filing has already become fully digital and, formally, more transparent — but the cost of a technical mistake has gone up too. Forgetting to re-register on the new MOS, requesting an employer's signature too late, missing the 60-day window to collect your card, or picking the wrong citizenship-timeline strategy — any of these small things can set the process back by months. The sensible approach is not to leave filing until the last day of your legal stay, and to check your situation against the current state of the reform before every major step, rather than relying on year-old information.

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Find out how the changes affect you

Rules are changing faster than chat groups and forums can keep up. Describe your situation — during a free consultation, we'll go through how the 2026 changes apply specifically to your case.

Frequently asked questions

Is MOS actually live, or is this still a plan? It's live: the system officially launched on 27 April 2026, and filing for temporary residence, permanent residence, and EU long-term resident status now goes exclusively through it. A handful of narrow bases (intra-corporate transfers, some family reunification cases filed from abroad) are still paper-only.

I had an account in the old MOS — can I still use it? No, old accounts weren't migrated to the new system and their data has been deleted. You'll need to register again.

Can I file through MOS myself, without a lawyer? Yes — the portal is free and designed for self-filing. A lawyer is still useful for assessing your legal basis, assembling an error-free document package, and accounting for the specifics of your situation (see our article on common refusal reasons).

What happens to temporary protection for Ukrainians after March 2027? The special temporary-protection regime is being phased out, and legalization shifts to either the CUKR card or the general grounds under the Act on Foreigners — depending on what basis a given person qualifies for.