Brexit is old news by now: the UK left the EU on 31 January 2020, and the transition period that kept the old rules running ended on 31 December 2020. Six years on, the practical question for British nationals is no longer “what will change” but “what actually applies today.” Here is the current picture for 2026: who still gets EU-style treatment, who doesn’t, and what that means for living, working and doing business in Poland.
– Two different regimes since Brexit
– Residence rights today
– Working and running a business
– Short-stay travel, EES and ETIAS
– FAQ
Two different regimes since Brexit
Since 1 January 2021, Poland treats British nationals under one of two entirely different regimes, depending on when they arrived:
- Withdrawal Agreement beneficiaries: UK nationals (and their family members) who were already legally resident in Poland under EU free-movement rules before 31 December 2020. They keep rights that closely mirror those of EU citizens: residence, work, self-employment, and a path to permanent residence, guaranteed directly by the EU-UK Withdrawal Agreement rather than by any Polish decision that could be revoked.
- Everyone else: UK nationals who arrived after the transition period, or who never exercised EU residence rights in Poland before it ended. They are treated as ordinary third-country nationals, on the same footing as, say, a US or Canadian citizen without any special agreement, subject to the general Polish immigration and work-permit regime, which was itself tightened further by reforms that entered into force on 1 June 2025.
There is one further, narrower group: UK nationals who were posted workers in Poland (temporarily assigned by a UK employer) before the end of 2020. They are not covered by the Withdrawal Agreement, but Polish law gives them a separate special temporary residence permit (valid 5 years) and exempts them from needing a work permit, provided they can show they were actually working in Poland before 31 December 2020.
In short: Brexit did not close the door on Poland for British nationals, but for anyone without pre-2021 ties here, it is now a standard non-EU immigration process, not a formality.
Residence rights today
Withdrawal Agreement beneficiaries keep their right to reside under the same conditions that applied to EU citizens (employment, self-employment, sufficient means and health insurance, or being a family member of an EU/Polish citizen). Poland runs a declaratory system: their legal status does not depend on holding a specific document, though they can apply for one confirming their rights. Periods of legal residence before and after the end of the transition period both count toward the 5 years of continuous residence needed for permanent residence, so someone who moved to Poland in, say, 2017 and stayed legally could already have qualified for permanent residence years ago.
Everyone else needs to go through the same routes available to any other third-country national: a temporary residence permit tied to employment (Art. 114 of the Act on Foreigners), business activity (Art. 142), study (Art. 144), or family reunification. Since 27 April 2026, most such applications must be filed electronically through the MOS (Moduł Obsługi Spraw) system. For the full mechanics of these permits, see our guide to residence permits in Poland.
One further route worth knowing: a UK national of Polish descent can apply for a Karta Polaka (Pole’s Card). Holders are exempt from needing a work permit or a business-activity permit at all, and gain an accelerated path to permanent residence and citizenship; see our dedicated Karta Polaka guide.
Working and running a business
For Withdrawal Agreement beneficiaries, the right to work and to be self-employed continues on the same terms as for Polish citizens, including registering a sole proprietorship (JDG), under Article 49 TFEU as preserved by the Agreement.
For everyone else, the picture splits by legal form:
| Route | Who can use it |
|---|---|
| Sole proprietorship (JDG) | Only with a qualifying residence status: permanent residence, EU long-term resident permit, Karta Polaka, or a temporary residence permit specifically tied to business activity |
| Limited liability company (Sp. z o.o.) | Open to anyone, regardless of nationality or residence status: minimum capital 5,000 zł, no residence permit required to be a shareholder or director |
| Employment | Requires a work permit or an integrated residence-and-work permit, subject to the June 2025 rules (no more working in Poland on a visa issued by another Schengen country) |
In practice, this means most UK nationals arriving in Poland today without a qualifying residence permit cannot simply register a JDG, but they can set up a Sp. z o.o. from day one, without any residence requirement at all. For the full process (capital, registration routes, costs), see our guide on opening a company in Poland. And if you do eventually get a residence permit tied to running a business, note that a business-based karta pobytu doesn’t automatically protect against B2B contract reclassification under the 2026 PIP reform, the same reform applies to everyone working under a civil-law or B2B contract in Poland, regardless of nationality.
Short-stay travel, EES and ETIAS
Visa-free short stays are unaffected: British nationals can still travel to Poland and the rest of Schengen for up to 90 days in any rolling 180-day period without a visa, for tourism, business meetings, or short visits.
Two EU border-management systems change the practical experience of crossing the border, though neither affects long-term residents:
- EES (Entry/Exit System): became operational from October 2025. Short-stay visitors register biometric data (fingerprints, photo) on first entry; the record is valid for three years. Long-term residents, including Withdrawal Agreement beneficiaries, are exempt.
- ETIAS: a pre-travel authorisation (like the US ESTA), required for visa-exempt travellers including UK nationals. As of mid-2026, ETIAS has not yet launched: the European Commission’s confirmed start is the last quarter of 2026, with a fee of around €20 and validity of up to three years once it does. No application is needed yet.
FAQ
Do UK nationals still need a visa for a short trip to Poland? No. The 90/180-day visa-free rule for Schengen still applies. From late 2026, short-stay visitors will additionally need an ETIAS travel authorisation, but that has not started yet.
Can a British citizen just move to Poland and start working? Only if they qualify as a Withdrawal Agreement beneficiary (already resident before 31 December 2020). Everyone else needs a work permit or an integrated residence-and-work permit, the same as any other non-EU national.
Can a UK national register a company without a Polish residence permit? Yes. Setting up a Sp. z o.o. does not require any residence status; only registering a sole proprietorship (JDG) does.
What happened to UK nationals who were already living in Poland before Brexit? They kept their EU-style residence, work and self-employment rights under the Withdrawal Agreement, and periods of residence before and after 2020 both count toward the 5 years needed for permanent residence.
Bibliography and Legal Basis
- Agreement on the withdrawal of the United Kingdom from the European Union (2019/C 384 I/01): residence, work and self-employment rights of Withdrawal Agreement beneficiaries.
- Act on Foreigners of 12 December 2013, consolidated text Dz.U. 2025 poz. 1079, Art. 114 (work), Art. 142 (business), Art. 144 (study).
- Reforms to the admissibility of foreign employment in Poland, in force since 1 June 2025.
- Regulation (EU) 2018/1240 establishing the European Travel Information and Authorisation System (ETIAS).
Author: Moja Firma team.
This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific facts involved. Book a free consultation with our team if you have questions.
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