KRAZ Registration in Poland and the Two Year Rule
An employment agency’s KRAZ number does not, by itself, show that the agency can provide every recruitment service involving foreign workers. For services covered by Poland’s two-year rule, the ordinary route requires two years from KRAZ registration, actual agency service provision and an amendment of the register entry. The restriction concerns job placement and temporary work for foreigners who require a work permit or a registered declaration of entrusting work.
For founders, this affects when a recruitment business can expand. For employers, it affects how an agency partner should be checked. A company incorporation date, an old certificate or a general statement that an agency is registered answers only part of the question.
This article explains how to assess the rule, what the historical exception means, and which records to check before committing to a recruitment project.
What KRAZ Registration Covers
KRAZ is Poland’s register of employment agencies. Job placement and temporary work are regulated agency activities. Temporary work involves supplying people to work for and under the direction of an employer user, while job placement involves connecting candidates with employers. The Warsaw Voivodeship Labour Office’s guidance explains the registration framework.
KRS, the National Court Register, records the company. KRAZ concerns its agency activity. When reviewing a business, keep both records available and match them to the same legal entity. A familiar trading name can conceal a difference between the entity advertising a service and the entity named in a contract.
The two-year rule is an additional restriction for specified foreign-worker services. It does not require every new recruitment agency to wait two years before carrying out any lawful agency activity.
Which Recruitment Plans Need the Two-Year Assessment
Start with the service being offered and the candidate’s work authorization route. Article 305(3) addresses job placement and temporary work for foreigners requiring a work permit or the declaration referred to in the foreign-employment legislation. Article 305(4) requires the relevant change to the agency’s register entry.
Use the following table to decide what to investigate. It is a preparation tool, rather than an approval of a particular business model.
| Planned situation | Check before proceeding |
|---|---|
| Recently registered agency serving candidates who require a permit or registered declaration | Assess the waiting period, actual service history and permitted scope before offering the covered service. |
| Established agency expanding into those services | Review its existing entry and prepare the amendment route. |
| Agency claiming the pre-June 2025 exception | Examine its earlier covered activity and the transition-related filing records. |
| Candidate using a different lawful work route | Identify that route individually; do not infer the answer from nationality. |
| Ordinary employer recruiting people directly for its own business | Review employer and worker compliance; distinguish direct hiring from providing agency services. |
The last row follows from the rule’s agency-specific scope. Supplying workers to another business requires a separate assessment of the actual arrangement. Calling the contract “outsourcing” does not explain who employs, directs or receives the workers.
Company Age and Actual Agency History
The relevant starting point is the agency’s KRAZ entry, rather than the incorporation of the company. The ordinary amendment route also requires a declaration of at least two years of job-placement or temporary-work service provision. The Olsztyn Labour Office’s explanation of agency obligations describes these conditions.
An Example for Business Planning
Suppose a company was incorporated in 2022, entered KRAZ in September 2025 and began providing agency services in January 2026. Its incorporation anniversary cannot answer the eligibility question. September 2027 would mark two years since entry, but the company would still need to examine its shorter service history and the amendment requirements.
This illustrative example explains why founders should track separate dates. It does not establish an approved start date for an actual agency.
Keep a dated record of contracts, completed assignments and the services delivered. If an agency has been dormant, suspended or inactive for part of its history, obtain a case-specific assessment before signing a declaration about two years of service provision
The Exception for Agencies Operating Before June 2025
The new framework took effect on 1 June 2025. A transitional exception concerned agencies already registered and providing the covered foreign-worker services before that date. It allowed those agencies to continue through the transition without satisfying the ordinary two-year condition, subject to the transition requirements. The Poznań Labour Office’s notice explained the amendment filing deadline as 31 August 2025.
That was a historical deadline. A newly established agency cannot select this transition as an alternative route today. Earlier registration alone also does not demonstrate that an agency provided the relevant services before the law changed.
For a business relying on the exception, review the original entry, evidence of earlier covered services, the amendment application and the current register record together. If the filing history is incomplete, resolve that issue before promising a client that the exception applies.
Ukrainian Candidates Require an Individual Status Check
Ukrainian citizenship alone does not determine whether the KRAZ two-year restriction applies. Identify the person’s lawful residence and employment route first.
An employer notification, commonly called a powiadomienie, is distinct from a registered oświadczenie. The State Labour Inspectorate’s guidance on changes from 5 March 2026 explains continued notification routes for eligible groups. This matters because the KRAZ provision specifically refers to foreigners requiring a permit or registered declaration.
Do not label all Ukrainian candidates as exempt or all as restricted. Record the legal route used for each recruitment project and confirm its conditions. An assessment that the specific two-year restriction does not apply leaves other agency, residence and employment requirements to be checked.
Preparing to Extend an Agency’s KRAZ Entry
Prepare the eligibility assessment before the commercial launch. A recruitment agreement can then describe an achievable scope rather than assume that an application will succeed.
Review the Registration and Service Records
- Identify the legal entity that will provide the service.
- Record its KRAZ entry date and current registered activities.
- Review when the relevant agency services actually began.
- Determine whether the ordinary route or historical transition is relevant.
- Identify which work authorization routes the planned candidates will use.
These are recommended preparation steps. They help the person signing the application distinguish verified facts from assumptions.
Prepare the Application Materials
For the ordinary foreign-service amendment, Article 313 provides for the service-history declaration, relevant non-arrears certificates, criminal-record documentation, the misdemeanor declaration and proof of payment. The service-history declaration carries criminal responsibility for false statements. Use the applicable authority’s current form and check the documents relevant to the agency and its managers or representatives.
Contracts and assignment records can help support the internal review of that declaration. Keep them available, while distinguishing supporting evidence from the prescribed application attachments.
Submit Through the Competent Authority’s Route
The voivodeship marshal administers the register, with the competent office determined by the applicable location rules. Official guidance directs applications through the electronic system. The Olsztyn registration procedure explains this route, and the STOR KRAZ portal provides access to registration services.
Check the resulting entry and scope before scheduling the covered activity. Allow the launch plan to accommodate requests for clarification or additional documents.
What Employers Should Check Before Engaging an Agency
Begin with the public KRAZ record. Match the agency’s legal name and identifiers to the contracting entity, then review the services shown. The public register can be accessed through STOR.
Ask the proposed partner to explain how its current entry covers the planned service and worker group. Where it relies on historical transition arrangements, request the records supporting that explanation. An old certificate can be useful background, but current verification should cover the present operation.
Keep agency due diligence separate from worker authorization. The first concerns whether the agency can provide the service. The second concerns whether the individual may lawfully stay and perform the proposed work under the actual employment conditions.
For larger projects, agree who checks each issue, who maintains the records and who responds when a worker’s circumstances change. This makes the compliance responsibilities clearer before recruitment begins.
Planning the Next Stage of Recruitment
Build a launch file containing the current agency entry, a dated service-history summary, the candidate authorization routes and the outcome of the eligibility assessment. Where an amendment is needed, include its status in the project schedule.
This preparation gives founders and HR teams a practical basis for deciding which services can proceed, which need an administrative step, and which require further review. It also helps avoid contracts built around an unsupported launch date.
7. FAQs
Does Foreign Ownership Remove the Two-Year Requirement?
Foreign ownership of a Polish recruitment company does not create an exception. Assess the registered agency and its activities. A foreign business delivering services into Poland also needs to examine the applicable registration framework; international experience alone should not be treated as Polish authorization. Olsztyn agency guidance
Do HR Consulting and Career Guidance Always Require KRAZ Registration?
Personnel consulting and career guidance were removed from the regulated agency-service categories under the 2025 framework. However, assess what the business actually does: matching candidates with employers or supplying temporary workers can bring the operation into the agency rules. Poznań Labour Office notice
Can Buying an Older Company Solve the Eligibility Issue?
A purchase needs due diligence on the registered entity, actual agency activity, filing history and current scope. The age of a shelf company is insufficient evidence. Before signing, ask the adviser reviewing the transaction to examine the specific recruitment plan against those records.
Where Should a Warsaw Agency Check Its Application Route?
Consult the Warsaw Voivodeship Labour Office’s KRAZ guidance and electronic filing instructions. The responsible authority is the voivodeship marshal; the Warsaw office supports the Mazowieckie register. Do not confuse agency registration with an individual worker’s immigration application. Warsaw KRAZ guidance
Discuss Your Recruitment Business Plans With Lex Corporation
Planning to establish or expand recruitment operations in Poland? Explore Lex Corporation’s business consultancy services and HR recruitment and outsourcing services, or contact the team to discuss your planned activities and the scope of support required.
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