IT outsourcing to Central Europe stopped being a cost-cutting trick years ago: Poland, Czechia, and Hungary are now genuine relocation destinations for companies that already have an experienced team and simply need a stable, EU base for it. Since 2022 we’ve helped a growing number of IT teams from Ukraine, Belarus, and elsewhere move their whole operation here. This guide covers the legal options for 2026: which residence permit fits a group relocation, how the intra-corporate transfer (ICT) route works, and what’s changed in the application process this year.
- Two ways to relocate an IT team
- Setting up a Polish company and hiring your team
- Intra-corporate transfer (ICT) permits
- Unified permit: the standard route for new hires
- Applying through the new MOS portal
- Alternative: the business incubator model
- Employment conditions your Polish entity must meet
- PIP 2026 and the B2B question for relocated teams
- FAQ
Two ways to relocate an IT team
Broadly, there are two routes: (1) relocate through a Polish legal entity (your own subsidiary, branch, or a newly incorporated Sp. z o.o.) and hire the team under Polish employment contracts, or (2) relocate without setting up a separate company, using a business-incubator / umbrella structure that handles compliance while each specialist keeps sole-trader (JDG) status. Which one fits depends mostly on team size, whether people are being transferred within the same corporate group, and how long you expect to stay in Poland.
Setting up a Polish company and hiring your team
A limited liability company (Sp. z o.o.) is available to foreign owners regardless of nationality, with a minimum share capital of PLN 5,000 and same-day online registration through the S24 system. It’s taxed at 19% CIT (9% for small taxpayers under the current EUR 2 million revenue threshold). Once incorporated, the company becomes the employer of record for your relocated team, which then needs individual residence-and-work permits (see below); see our articles on Sp. z o.o. and CIT in Poland for the details.
Intra-corporate transfer (ICT) permits
If your team is being transferred within the same company or corporate group, not hired locally from scratch, the ICT permit (zezwolenie na pobyt czasowy w celu wykonywania pracy w ramach przeniesienia wewnątrz przedsiębiorstwa) is usually the better fit. It transposes EU Directive 2014/66/EU and is set out in Articles 139a-139p of the Foreigners Act (Journal of Laws 2025, item 1079).
– Managers and specialists: employed within the same company/group for at least 12 months immediately before the transfer.
– Trainees: employed for at least 6 months before the transfer, and holding a university degree.
– Permit duration: up to 3 years for managers/specialists, up to 1 year for trainees.
Procedurally, only the receiving Polish unit, not the foreign employer or the employee, is a party to the proceedings, which simplifies paperwork for HR teams coordinating several transfers at once. An ICT permit also carries an “ICT” annotation on the residence card, which lets the holder work short-term in other EU member states as part of the same transfer (the “mobile ICT” mechanism), without applying for a fresh national permit each time.
Unified permit: the standard route for new hires
For team members hired fresh, or who don’t meet the 12-/6-month prior-employment requirement, the standard unified permit for temporary residence and work (Art. 114 of the Foreigners Act) applies instead. Since 1 June 2025, the labour market test (the local starosta’s opinion on the local job market) has been abolished for most unified-permit and work-permit cases, which meaningfully shortens the paperwork on the employer’s side.
– Unified permit decision: PLN 440
– Residence card issuance: PLN 100
– Total: PLN 540 per person
The statutory deadline for a decision is 60 days, but in practice actual waiting times vary a lot by voivodeship office and season, often several months, and sometimes close to a year in the busiest offices (Warsaw, Kraków, Wrocław). Budget for this when planning a relocation date.
Applying through the new MOS portal
From 27 April 2026, applications for temporary residence, permanent residence, and EU long-term resident permits (including unified permits and ICT permits) must be filed exclusively electronically through the new MOS (Moduł Obsługi Spraw) portal. If you’re planning a relocation later in 2026, build the MOS filing step into your HR timeline; some procedures may still run on the old paper-based track during the transition period.
Alternative: the business incubator model
For smaller teams or individual specialists, some companies use a business incubator (“umbrella project”) instead of setting up an Sp. z o.o. Under this model, each team member operates as an individual entrepreneur (JDG) inside the incubator’s legal umbrella: there’s no separate limited company, so there’s no CIT layer at all; income is taxed once, at the individual level, under PIT or ryczałt. That’s a real structural difference from a Sp. z o.o. (which pays 19%/9% CIT and then PIT again on dividends), not literally “0% tax” as older marketing copy on this topic sometimes claimed; see our articles on the business incubator vs. JDG and JDG in Poland for a fuller comparison. The incubator route can be opened and closed within days, with no liquidation procedure, useful if you’re not sure yet whether the relocation is permanent.
Residence permits work the same way regardless of the model chosen: team members (and their families) can get a temporary residence permit first, and after 5 years of continuous legal residence, a Polish EU long-term resident permit.
Employment conditions your Polish entity must meet
Whichever structure you use, if the team is employed under Polish employment contracts, the entity has to comply with Polish labour law basics:
- Minimum wage: PLN 4,806 gross/month in 2026 (a single rate for the whole year), or PLN 31.40/hour minimum for civil-law contracts.
- Annual leave: 20 or 26 days/year depending on the employee’s overall work experience.
- Maternity/parental leave and sick leave: apply on the same terms as for Polish employees, funded largely through ZUS.
- Overtime pay: a 50% or 100% supplement depending on when the overtime falls.
IT salaries are usually well above these floors, but the minimums still matter for the residence-permit income test and for any junior/support staff on the team.
PIP 2026 and the B2B question for relocated teams
If part of your relocated team is meant to work as B2B contractors under the incubator/JDG model rather than as employees, with a single client, fixed hours, and day-to-day direction from that client, the same subordination test applies as for any other B2B contract in Poland. Since the 2026 Labour Inspectorate (PIP) reform (Journal of Laws 2026, item 473), PIP can reclassify such a relationship as employment and order backdated ZUS contributions and PIT withholding, regardless of the legal wrapper chosen for the relocation. There’s a transitional window running to roughly 8 July 2027 for contracts already in force. We cover the four hallmarks of disguised employment and how to structure a genuinely independent B2B relationship in our PIP 2026 series.
FAQ
Can I relocate my whole IT team without setting up a Polish company? Yes: through the business incubator model each specialist keeps their own JDG status, so there’s no need to incorporate a separate entity. It works best for smaller teams or when you’re not yet committed to a permanent Polish presence.
Does the ICT permit apply to a newly-incorporated Polish subsidiary? Yes, as long as the transferred employee has worked for the same company or corporate group for the required 12 (or 6, for trainees) months before the transfer; the receiving unit doesn’t need to be old, just part of the same corporate structure.
What’s the real difference between ICT and the unified permit? ICT is for genuine intra-company transfers with EU-wide mobility built in and a shorter list of documents (only the receiving unit is a party to the case); the unified permit is the general route for anyone hired locally or who doesn’t meet the prior-employment requirement.
Do family members get residence permits too? Yes: spouses and children can apply for their own temporary residence permits based on family reunification once the main applicant has a valid permit.
Bibliography and Legal Basis
- Act of 12 December 2013 on Foreigners (consolidated text, Journal of Laws 2025, item 1079), Art. 114, Art. 139a-139p
- Amendment introducing the MOS system (Journal of Laws 2025, item 1794)
- Directive 2014/66/EU on the conditions of entry and residence of third-country nationals in the framework of an intra-corporate transfer
- Act of 2026 on the State Labour Inspectorate reform (Journal of Laws 2026, item 473)
Author: MojaFirma team.
This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific contract and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.
Got a question about this article?
Write it in a comment below. We read every one and reply.









Dear Sirs,
I'd like to apply for relocation of by freelance business to your business incubator in accordance with Poland Business Harbour program. Please advise what would be the sequence for proceeding? Shall I fill in some applications?
Regards,
Valentina Gurina
Dear Valentina,
Yes, we work with people relocating under Poland Business Harbour, and freelancers are a common case.
What we would need first: your citizenship, whether you already hold a PBH visa or are still applying, and how your clients are contracted, since that decides whether an incubator arrangement or your own registered activity fits better.
Write to us with those details and we will come back with the steps, the documents required and the cost.