The government’s migration strategy is disappointing. The long-awaited comprehensive document turns out to be a brief collection of short statements lacking deeper analysis.
However, one can hope that this document is merely a starting point for a broader debate on a genuine migration strategy, which will soon be presented. This communication outlines three potential opportunities and three key risks that may arise from the proposed approach.
The published strategy seems to bring little change: the primacy of security is already the prevailing approach, as reflected in the fact that migration issues are placed under the Ministry of the Interior and Administration. In many aspects, the document merely repeats existing policies (such as the labor market test).
The main risks include: 1) an excessive and absolute focus on security, overshadowing other goals of migration policy; 2) a worsening of Poland’s demographic challenges; 3) the potential restriction of immigrants’ access to certain professions.
On the other hand, the strategy creates hope for: 1) addressing the key problem of lengthy administrative procedures; 2) liberalizing access to high-demand and regulated professions; 3) avoiding the mistakes made by Western European countries by implementing a well-considered integration policy.
Migration is a multidimensional and complex phenomenon. Legislators regulating migration must balance economic, social, and national security needs, social welfare systems, and the country’s capacity to integrate migrants into society. In 2024, it is no longer possible to ignore the need for a comprehensive approach to migration. Today, Poland is home to around 2.5 million foreigners, who account for nearly 7% of those insured in the social security system (ZUS). The operations of many businesses would no longer be possible without the contribution of foreign workers. 1
At the same time, both the existing legal framework and the functioning of public administration remain woefully inadequate for this new reality. Regulations often lack coherence and, in some cases, even contradict each other. This problem has been recognized by the new government, which presented a migration strategy (the last such document was adopted over a decade ago). Unfortunately, despite its title and initial announcements, it is hard to see this document as truly “comprehensive and long-term.” 2
Migration policy should aim to create a coherent legal framework that minimizes barriers and fosters an environment encouraging the integration of migrants. 3 It should also take advantage of Poland’s potential to decentralize the governance structure, which has been largely overlooked in the current legislative approach. While ensuring national security is undoubtedly essential and a top priority— especially in the current international climate—it should not serve as a pretext for closing the labor market or ignoring Poland’s economic challenges.
Three Risks and Three Hopes of Government’s Migration Strategy
The strategy document titled “Regaining Control, Ensuring Security” amounts to just 36 pages of general statements. Detailed implementation plans for its goals are supposed to be outlined in a separate follow-up program. As a result, the strategy lacks an in-depth explanation of its assumptions, data, examples, or thorough analysis. Under these circumstances, conducting a detailed review of such a superficial document would be futile. Instead, it is worth examining the hopes and risks that may stem from it.
Risk 1: The Absolute Supremacy of Security
The main risk of the strategy appears to be the absolute and overly broad emphasis on security within migration policy. While it is beyond dispute that ensuring security is a fundamental duty of the state, and migration policy cannot function without safeguarding it, the document’s exclusive focus on security may lead to restricting migration and, as a result, limiting its positive effects. Migration is a complex phenomenon, and legislators must approach it comprehensively. Developing a single-purpose policy focused solely on security risks harming the economy and diminishing societal welfare.
The strategy explicitly states as its first principle the “overriding priority of security.”4 Migration affairs are already handled by the Ministry of the Internal Affairs and Administration, under the governmental domain of “internal affairs.” For years, organizations working on migration have pointed out that this institutional assignment does not reflect the true nature of migration, which primarily concerns the labor market. 5 The new strategy fails to recognize this problem and, in fact, reinforces this misalignment. Equally concerning is the strategy’s repeated reference to “uncertainty” as a metric of security. 6 This is a subjective criterion, which could be used as a pretext to shape migration policy based on electoral considerations and political popularity rather than the common good.
Risk 2: Worsening Demographic Challenges
The strategy includes a troubling assumption that “demographic and social changes in the labor market should not be addressed through immigration policy instruments.” 7 According to projections from the Social Insurance Institution (ZUS), Poland’s population is expected to shrink to 32.5 million by 2060, and to only 28.5 million by 2080. 8 By 2060, there will be 105 people of non-working age for every 100 working-age individuals. 9 Migration could help mitigate the negative effects of population decline, which would otherwise lead to challenges in maintaining pension levels and an increase in elderly poverty.
Migration also contributes directly to economic growth. Without immigration since 2015, Poland’s GDP in 2023 would have been 2.3% lower. 10 By 2050, the absence of immigration would reduce Poland’s GDP by 12.5%. 11 Without migrants, Poland will be a poorer country, yet the government strategy seems to ignore this fact.
Risk 3: Labor Market Protectionism
The migration strategy acknowledges the problem of declining competitiveness in the Polish economy due to labor shortages in high-demand occupations. However, it fails to recognize that immigration contributes to broader labor market competition, which in turn boosts consumer welfare. The authors reference challenges faced by Western European countries due to mass migration, yet provide no examples or data to substantiate these concerns. 12 At the same time, they overlook the positive economic effects of immigration.
The strategy proposes maintaining the declaration procedure, but also states that access to the Polish labor market for foreigners under a special procedure will depend on: 1) holding citizenship of an OECD country or a country with which Poland has a readmission agreement; 2) possessing unique skills or where labor needs cannot be met domestically; 3)receiving wages comparable to Polish workers; 4) engaging in strategic projects for the economy or national defense. This implies that the outdated and bureaucratic labor market test will be maintained. 13 The mention of “strategic projects” suggests a further tightening of access to the labor market, based on arbitrary criteria, historically prone to abuse 14 (for instance, justifying state ownership of companies by labeling them “strategic”). Such an approach could also lead to the discrimination of private employers, as projects deemed strategic by politicians are typically implemented by state-owned enterprises. The “new model of labor market access for foreigners based on a points system,” mentioned briefly in the strategy, 15 remains vague. Such systems inevitably risk falling into the “fatal conceit” of bureaucracy, where officials dictate which types of workers are needed. It would be prudent for the government to consider the critical assessments of the Australian system—likely the inspiration for this idea—which in practice has fallen far short of the optimistic evaluations sometimes presented in Europe. 16
Hope 1: Rationalization of Administrative Procedures
For years, one of the biggest challenges in Polish migration law has been the excessive length of residence permit procedures handled by local governors (wojeowdowie). In 2019, the Supreme Audit Office (NIK) raised the alarm about this issue, but the situation has only worsened in subsequent years. 17
In 2020–2021, the average processing time for temporary residence permits exceeded 500 days 18 in the worst-performing regional offices. Appeal procedures before the Head of the Office for Foreigners were similarly slow. 19 Such delays create significant uncertainty for immigrants, preventing them from taking up employment.
Without addressing staff shortages and improving administrative processes, no migration policy can achieve long-term success. For example, although Poland theoretically has relatively liberal naturalization requirements, its naturalization rate remains below the EU average. One of the main reasons is the difficulty of proving continuous residence and stable income due to the months-long delays in processing residence permit applications. 20
In this area, the strategy outlines a plan for extensive digitalization of residence legalization processes and preventing staff turnover in the provincial offices and the Office for Foreigners 21—offering some hope for improvement. Another opportunity for streamlining these processes is decentralization of migration policy, mentioned only briefly in the strategy through a vague reference to the principle of subsidiarity. 22 The government should make full use of decentralization, which is consistent with the constitutional principle of decentralized governance and would help ease the burden on central administration. 23
Hope 2: Shortage and Regulated Occupations
In terms of the number of regulated professions, Poland ranks among the most restrictive countries in the EU, with as many as 352 regulated occupations. In the past—and still today—foreigners face legal barriers that prevent or significantly hinder their ability to work in regulated professions, 24 including as civil servants, teachers, firefighters, or municipal guards. An equally absurd situation concerns high- demand occupations—those in which there is a clear lack of workers. 25 Despite this, existing laws continue to make it difficult for foreigners to be employed in these fields. 26
The government’s strategy mentions plans to “enable the use of the existing system for identifying shortage and surplus occupations (labor market monitoring) in the implementation of migration policy”27 and to prioritize work permits in shortage occupations. For long-term shortage occupations, special regulations are planned—though this seems to refer primarily to “strategic investments,”28 which, as discussed earlier, could be a risk due to arbitrariness. While the document does not directly address regulated professions, there is partial overlap between the two categories. The mention of shortage occupations could prompt a broader debate and increase awareness of this problem. One should hope that raising the issue in the public debate will encourage the government to liberalize the requirements for these professions. Liberalizing access to regulated professions, rather than creating special privileges for so-called “strategic investments.”
Hope 3: Integration of Foreigners
The long-term success of migration policy depends on the integration of foreigners. Migrants who are integrated into the host society and active in the labor market not only contribute to increased national wealth, but also improve public acceptance of migration, thanks to direct interaction with local communities.29
The government’s migration strategy acknowledges this link and, albeit briefly, addresses key aspects of integration: language proficiency, labor market participation, and engagement in the education system. It is good that the strategy recognizes the difficulty some migrants face integrating into liberal and democratic societies, an issue that has become one of the main challenges for Western countries. It is self-evident that a failure of the state to manage integration will lead to social tensions, including the radicalization of segments of the host population and a rise in the popularity of populist parties— ultimately undermining political stability and making reforms more difficult. This risk can be mitigated, for example, by choosing the countries of origin of migrants when shaping migration policy.
However, integration will be hard to achieve without enabling foreigners to enter the labor market efficiently. Countries with the greatest success in migrant integration—such as the United States, Australia, and Canada—combine liberal labor market policies with low barriers to entry in regulated professions.30 For this reason, the previously discussed topics—streamlined administrative procedures and access to regulated professions—are crucial. Equally important is the ease of starting a business in Poland, an area where many foreigners still face practical difficulties31. Unfortunately, the government’s migration strategy does not propose improvements in this regard.
Summary
Migration strategy should enhance legal certainty and clearly outline the legislator’s priorities, along with the assumptions and analyses on which those priorities are based. Unfortunately, the adopted strategy is such a shallow document that it is difficult to engage in any meaningful discussion about it. It gives the impression of a text written primarily to address short-term political needs, rather than to guide long-term migration policy. 32
References
1 See Polski Instytut Ekonomiczny, Co trzeci Polak zawyża liczbę cudzoziemców w Polsce, June 18,2024, https://pie.net.pl/co-trzeci-polak-zawyza-liczbe-cudzoziemcow-w-polsce/.
2 See Odzyskać kontrolę. Zapewnić bezpieczeństwo. Kompleksowa i odpowiedzialna strategia migracyjna Polski na lata 2025–2030, Annex to Resolution No. 120 of the Council of Ministers of October 15, 2024, https://www.gov.pl/web/premier/odzyskac-kontrole-zapewnic-bezpieczenstwo—strategia-migracyjna-na-lata- 2025—2030.
3 See Cykl raportów Kierunek Polska – rekomendacje dla polskiej polityki migracyjnej: https://for.org.pl/2024/07/31/raport-kierunek-polska-rekomendacje-dla-polskiej-polityki-migracyjnej/.
4 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p. 12.
5 See R. Trzeciakowski, K. Wąsowska, Potrzebujemy imigrantów. Jak zatrzymać ukraińskich pracowników w Polsce?, Analysis 7/2018, Civil Development Forum (FOR), July 17, 2018, https://for.org.pl/2018/07/17/analiza-7- 2018-potrzebujmy-imigrantow-jak-zatrzymac-ukrainskich-pracownikow-w-polsce/.
6 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p. 2, 12.
7 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p. 22.
8 J. Hagemajer, A. Kulesa, Znaczenie imigracji dla rozwoju gospodarczego Polski, Civil Development Forum (FOR) Warsaw 2024, p. 19, https://for.org.pl/wp-content/uploads/2024/08/raport-fioletowy_znaczenie-imigracji-dla- rozwoju-gospodarczego-Polski.pdf.
9 Ibidem, p. 19.
10 Ibidem, p. 27.
11 Ibidem, p. 22.
12 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p.22.
13 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p.22 – 23.
14 O. Babakova, T. Gomon, K. Naranovich, P. Oliński, Ułatwienia w zatrudnianiu cudzoziemców spoza UE, Civil Development Forum (FOR) Warsaw 2024, p. 21, https://for.org.pl/wp-content/uploads/2024/08/raport- zolty_ulatwienia-w-zatrudnianiu-cudzoziemcow-spoza-UE.pdf.
15 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p.23.
16 See. J.B., Why points-based immigration systems don’t work, The Economist, July 12 2016, https://www.economist.com/the-economist-explains/2016/07/12/why-points-based-immigration-systems-dont- work. 17 O. Babakova, T. Gomon, K. Naranovich, P. Oliński, Ułatwienia w zatrudnianiu cudzoziemców spoza UE, Civil
17 Development Forum (FOR) Warsaw 2024, p. 29-31, https://for.org.pl/wp-content/uploads/2024/08/raport- zolty_ulatwienia-w-zatrudnianiu-cudzoziemcow-spoza-UE.pdf.
18 Ibidem.
19 Ibidem.
20 Ibidem, p. 25–26.
21 O. Babakova, T. Gomon, K. Naranovich, P. Oliński, Ułatwienia w zatrudnianiu cudzoziemców spoza UE, Civil Development Forum (FOR) Warsaw 2024, p. 16, https://for.org.pl/wp-content/uploads/2024/08/raport- zolty_ulatwienia-w-zatrudnianiu-cudzoziemcow-spoza-UE.pdf.
22 Ibidem, p. 12.
23 See M. Górski, Korzyści z decentralizacji polityki migracyjnej, Civil Development Forum (FOR), Warsaw 2024, https://for.org.pl/wp-content/uploads/2024/08/raport-pomaranczowy_korzysci-z-decentralizacji-polityki- migracyjnej.pdf.
24 See A. Drozd, T. Gomon, P. Oliński, Uwolnić potencjał: otwarcie zawodów regulowanych dla obywateli Ukrainy – Recommendations of FOR and the Polish-Ukrainian Chamber of Commerce, April 5, 2022, https://for.org.pl/2022/04/05/uwolnic- potencjal-otwarcie-zawodow-regulowanych-dla-obywateli-ukrainy/.
25 The list of shortage occupations is currently compiled by the Regional Labour Office in Kraków on behalf of the Minister for Labor. See: K. Antończak-Świder, A. Biernat, E. Półchłopek, Barometr zawodów 2024. Raport podsumowujący badanie w Polsce, Regional Labour Office in Kraków, Kraków
2023, https://barometrzawodow.pl//forecast-card-zip/2024/report_pl/raport_ogolnopolski_2024.pdf.
26 Ibidem.
27 Odzyskać kontrolę. Zapewnić bezpieczeństwo, p. 23.
28 Ibidem, p. 22.
29 See N. Karlson, Reviving Classical Liberalism Against Populism, Palgrave Studies in Classical Liberalism, Cham 2024, 1. 93
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