Employment Under the Guise of a Religious Mission: What Risks Do Foreign Nationals Face in Poland

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You are offered a job at a warehouse or production facility, and during the registration process it turns out you are required to become a participant in a religious mission. You have not misunderstood. Some agencies on the Polish labour market do indeed make such offers. The agency explains this as a way to start working more quickly, bypassing the need for a work permit. For someone in need of income, such an offer may seem convenient. Before agreeing, however, it is worth understanding the legal basis on which you would be registered and how it relates to your actual duties.

How the Scheme Works

The mechanism of engaging foreign nationals in ordinary commercial work through religious organisations was described by journalists at TVN24 in their investigative report “Święty biznes” (Holy Business). According to their findings, foreign nationals were registered as missionaries and engaged in work, including at construction sites. In the model described by the journalists, the company settled payments with the agency, a portion of the funds went to the religious organisation, which then paid the workers. Such payments could be documented as reimbursement of mission expenses.

The Legal Exemption and Where Its Boundaries Lie

This arrangement rests on a genuine statutory exemption. The Regulation of the Minister of Family, Labour and Social Policy of 20 November 2025 provides for the possibility of working without a permit for certain categories of persons performing work in connection with their religious function. This refers to work within a church, a religious association or their organisational units. Work at another organisation on the basis of an appropriate referral is also permitted. The condition for this exemption, however, remains the existence of a connection between the work performed and the religious function. This is precisely why a referral letter from a church cannot be treated as a universal substitute for a work permit of any kind. If a person is formally registered for religious activities while in practice participating in ordinary production shifts without any such connection, grounds arise to question whether the exemption has been lawfully applied. This follows from point 11 of paragraph 1 of the Regulation referred to above.

A separate matter concerns insurance. Special rules apply in Poland to the financing of certain ZUS (Zakład Ubezpieczeń Społecznych) contributions for clergy. Under conditions prescribed by law, part or all of the contributions may be covered by the Fundusz Kościelny (Church Fund). At the same time, work performed under an employment contract creates a separate insurance basis that must be taken into account. A promise of savings on contributions through a religious form of employment therefore requires careful verification in the light of the actual working conditions.

What Risk the Worker Faces

For the worker, the most serious problems may arise during an inspection of the legality of employment. If the required permit does not exist and the exemption applied does not correspond to the circumstances, the work may be found to be illegal. Liability for the violation applies both to the entity that unlawfully entrusted work to a foreign national and to the foreign national themselves.

The consequences may also relate to the right to stay in Poland. The situation is particularly sensitive when it was the performance of a religious function that formed the basis for obtaining a residence permit: the declared purpose must correspond to the actual one. Where the statutory grounds are met, a decision obliging the person to return may be issued. The specific outcome depends on the individual’s status and the circumstances of their case.

Problems with the employment arrangement may also complicate the recovery of earned wages. When documents describe a religious mission and payments are labelled as reimbursement of expenses, in the event of a dispute it will be necessary to establish what relationship actually existed between the parties. Evidence of work performed and of payment arrangements will be of material significance. Where the indicia of an employment relationship are present, the person may seek its recognition and the associated rights, including the right to holiday pay. An inappropriate name given to the contract does not in itself eliminate these possibilities.

The question of insurance deserves separate attention. For the purposes of receiving sickness benefits, the specific type of insurance covering the individual is decisive. For clergy, sickness insurance is voluntary. A general assurance that ZUS contributions are being paid is therefore insufficient for a full understanding of one’s rights. It is worth knowing on what basis registration was made and what range of insurance it covers.

There is also a practical vulnerability: if a single organisation simultaneously handles registration, payments and accommodation, a conflict with it may affect several important areas of life at once. Under such circumstances, it is particularly important to hold one’s own copies of all signed documents and to understand what obligations each party has assumed.

Before starting work, establish who exactly you are concluding an agreement with and who will be responsible for payment. If you are promised employment without a permit, ask for the specific legal basis to be identified and explained in relation to your duties. Documents relating to religious activities warrant particular scrutiny when the vacancy on offer involves ordinary commercial work.

For information on current Gremi Personal vacancies and employment conditions, call: +380 50 334 93 51, +48 525 275 003.

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