Joanna Markiewicz-Stanny

In 2026 as of the most recent data, 979,980 individuals are registered under temporary protection in Poland. [UNHCR]. Since 2022 the legal framework governing temporary protection, and the associated public–private partnerships, has undergone significant evolution. These developments largely correspond to successive phases in the response to large-scale inflows of displaced persons, encompassing the stages of initial reception, secondary reception, and integration.
At the outset of the war, spontaneous civic engagement played a significant role, the scale of which can be regarded as unprecedented. It can be argued that the reception of approximately three million individuals who entered Polish territory during the initial weeks of the conflict was made possible largely through the actions of civil society actors and local authorities. It is noteworthy that the response involved private individuals, civil society organisations, as well as – on a previously unprecedented scale – business actors and economic entities [S. Jarosz, W. Klaus, The Polish School of Assistance: Reception of Refugees from Ukraine in Poland in 2022, Migration Consortium Warsaw 2023, https://konsorcjum.org.pl/en/report-the-polish-school-of-assistance/, 68-77]. An important area of humanitarian assistance involved hosting displaced persons in private apartments and homes which significantly contributed to Poland’s capacity to host such a large number of arrivals. [Ł. Baszczak, A. Kiełczewska et.al., Pomoc polskiego społeczeństwa dla uchodźców z Ukrainy, Warszawa, Polski Instytut Ekonomiczny, 2022, https://pie.net.pl/wp-content/uploads/2022/07/Pomoc-pol-spol-UKR-22.07.2022-D-1.pdf, 23]. Most of these initiatives were undertaken spontaneously and on an ad hoc basis.
These measures were complemented or, in some instances, replaced by structural and systemic solutions based on the establishment of two distinct legal regimes of temporary protection. The first of these, referred to as “special temporary protection,” was introduced by the Act of March 12, 2022, on assistance to Ukrainian citizens in connection with the armed conflict on the territory of this on the territory of this state (hereinafter: the Assistance Act). The personal scope of this regime was narrowly defined and limited to Ukrainian nationals, as well as specified members of their families, who lawfully crossed the Polish border after 24 February 2022 as a direct consequence of the armed conflict (Article 2(1) of the Assistance Act).
Conversely, third-country nationals and stateless persons falling within the scope of Article 2 of Council Implementing Decision (EU) 2022/382, to whom the Assistance Act did not apply, were covered by the “general temporary protection” mechanism implementing Council Directive 2001/55/EC, under Article 107(1) of the Act of 13 June 2003 on Granting Protection to Foreigners in the Territory of the Republic of Poland (hereinafter: the Protection Act). This group did not benefit from a comparable level of support from either public authorities or the host society, which substantiates the assertion that, in Poland, the framework for assistance to other displaced persons mirrors a phenomenon of selective hospitality. [W. Klaus, S. Jarosz, Those left behind. Selective hospitality and uneven reception of people fleeing Ukraine in Poland. “Crime, Law and Social Change” 2026, vol. 84: 20].
“Special temporary protection” was based on extensive simplification of registration and connected with it regularization of stay; the provision of free accommodation through both public and private arrangements; access to healthcare independent of insurance coverage or employment status; simplified entry to the labour market; and the ability to conduct business under the same conditions as Polish citizens. The system was, and continues to be, based on the rapid integration of displaced persons into the labour market, the provision of accommodation primarily through the private rental sector, as well as the inclusion of Ukrainian children into the education system.
One of the most notable features of Polish approach to displacement was the two-year state support for free accommodation provided to displaced persons by private entities. Any entity, in particular a natural person running a household, which provided accommodation and meals to Ukrainian citizens was entitled for this purpose to a financial allowance of 40 PLN per day per person (Art.13 (1) of the Assistance Act), initially for a period of 60 days, which it was possible to extend to 120 days. In particularly justified cases, the above-mentioned period of benefit payment could have been extended further still. This allowance was paid on the motion. According to data available, 1,211,110 applications for this financial allowance were registered in 2022, with over 560,000 applications registered in 2023 (Asylum Information Database (AIDA) Temporary Protection. Poland, Brussels: European Council of Refugees and Exiles 2023, 40), M. Cwalina, P. Downarowicz et al., Prywatne przyjmowanie i wspieranie osób uciekających przed wojną w Ukrainie. Raport badawczy, CMR Working Papers 136/194, 2023, https://www.migracje.uw.edu.pl/wp-content/uploads/2024/01/CMR-WP-136-194.pdf).
This form of state support was repealed in June 2024 by an amendment to the Assistance Act which simultaneously introduced an obligation for partial payment for stay in collective accommodation centers, as well as restrictions on the duration of residence in such centers. These changes, however, did not apply to individuals belonging to the most vulnerable groups.
It can be stated that, since that time, there has been a gradual phasing out of various forms of support for individuals benefiting from special temporary protection, or a restriction of such support solely to measures that enable displaced persons to survive during their initial weeks in Poland.
On 23 January 2026, the Polish Parliament adopted a new law providing for the gradual repeal of the Assistance Act and the transfer of its provisions concerning temporary protection into the Protection Act. The entry into force of these changes is still subject to the President’s signature. Nevertheless, they will be discussed here because they reflect the Polish state’s approach to the fate of displaced persons in Poland. In this manner Poland establishes a single, coherent support framework for all foreigners under temporary protection, irrespective of their nationality. It ensures equal rules regarding access to benefits, the labour market, and healthcare. In the explanatory memorandum (uzsadnienie) it was emphasized that these solutions fully correspond to Council Recommendation of 16 September 2025 on a coordinated approach to the transition out of temporary protection for displaced persons from Ukraine (C/2025/5129).
The scope of the introduced changes is extensive, encompassing both substantive and procedural aspects of the legal status of beneficiaries of temporary protection [brief discussion in English here]. Nevertheless, the legislation was adopted at an exceptionally rapid pace, following less than one month of legislative work and without prior public consultations. It is therefore unsurprising that the changes have been subject to critical assessment, both by employers and by the Commissioner for Human Rights. Under the new legislation, the automatic extension of the lawful stay of Ukrainian nationals in Poland was carried out for the last time, while simultaneously providing for the obligation for beneficiaries of temporary protection to obtain alternative residence titles by 4 March 2027. The adoption of legal solutions aimed at ending the current state of protracted temporariness is, in principle, desirable. However, it is difficult to envisage how the already overstretched voivodeship offices will be able to process approximately one million applications within a one-year period.
Additional serious concerns arise from the lack of empirical data presented in the legislative proposal. The explanatory memorandum merely states, in very general terms, that most Ukrainian nationals have integrated into Polish society and are in employment, and that most children attend Polish schools. Meanwhile, UNHCR study indicates that economic inclusion and access to decent work remain significant challenges for beneficiaries of temporary protection in Poland. Similar concerns apply to a substantial number of children who remain outside formal education systems due to language barriers and other structural obstacles, which underscores the urgent need for enhanced support for educational integration, including language training – forms of assistance that, hat have already been withdrawn under the new legislation. Finally, it should be emphasised that Poland still lacks a coherent strategy for the integration of foreigners, and the regulations governing these issues are scattered across various laws. It can be said that this is currently mainly an area of activity for non-governmental organisations, which play a key role here.

This blogpost is one of the scientific outcomes of the CoSME Project (www.cosmeproject.eu) in partnership with IntoME (www.intome.eu).