# Parlament Europejski, Komisja Petycji (petycja 2170/2026) | petycja 2170/2026 (portal: 40679) | 20.08.2026
# Uzupełnienie petycji 2170/2026: 90-dniowy termin dla jednolitego zezwolenia (dyrektywa 2024/1233) - główna ścieżka legalizacji w Polsce
# źródło tekstu: transkrypcja Claude Opus opublikowanej wersji
# dokument: https://glos-migranta.eu/dokumenty/gm-pe-petycja-2170-2026-uzupelnienie-2026-08-20.pdf

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PETITION No 40679 - ADDITIONAL INFORMATION
Petition 40679 - additional information: the 90-day deadline under
Directive (EU) 2024/1233 and the main residence channel
Dear Members of the Committee on Petitions,
I respectfully submit additional information to my petition no. 40679, lodged on 11 August 2026. The petition as filed concerns the
90-day deadline for EU Blue Cards under Article 11(1) of Directive (EU) 2021/1883. The information below extends the same factual
pattern to the channel through which the overwhelming majority of applications in Poland are processed.
1. The main channel was outside the scope of the original petition. In Poland, most third-country nationals in employment
apply for a *zezwolenie na pobyt czasowy i pracę* - the national single permit. According to the Ministry of the Interior and
Administration, the average duration of such proceedings is 341 days and 463 487 cases were pending (reply to parliamentary
question no. 12584, situation as of 13 October 2025). By region the average ranges from 242 days in Małopolskie to 658 days in
Sląskie (reply to parliamentary question no. 18089, as of 6 July 2026). The statutory national deadline is 60 days (Article 112a(1) of
the Act on Foreigners).
2. Union law now sets a 90-day ceiling for this channel as well. Directive (EU) 2024/1233, recasting the single permit
directive, requires in Article 5(2) a decision on a complete application within 90 days, extendable by 30 days only "in exceptional
and duly justified circumstances linked to the complexity of the application" (Article 8(3)). The transposition deadline was 21 May
2026 (Article 18(1)) and Directive 2011/98/EU was repealed with effect from 22 May 2026 (Article 19). The Polish average
therefore stands at almost four times the current Union ceiling.
3. A question about transposition that the Committee is better placed to answer than I am. Consulting the EUR-Lex
database of national transposition measures for Directive (EU) 2024/1233 on 20 August 2026, I found no Polish transposition
measures listed, while measures notified by several other Member States were shown. I do not treat the state of a database as proof of
a failure to notify, and I make no such assertion. I respectfully ask the Committee to establish, with the assistance of the European
Commission, whether Poland has notified transposition measures for that directive and, if so, when.
4. Why this matters for the petition as a whole. The original petition described a deadline breach affecting highly qualified
workers. The information above shows the same breach in the ordinary employment channel, on a scale of hundreds of thousands of
pending cases. Both instruments set the same ceiling of 90 days; the national practice exceeds it by a factor of nearly four. I also note
that the national provision suspending the running of procedural deadlines in residence cases - Article 10od of the Act of 12 March
2022 on assistance to citizens of Ukraine, extended until 4 March 2027 - applies to all foreigners regardless of nationality, and that its
compatibility with Union law is currently before the Court of Justice in Case C-254/25, where the Advocate General delivered an
opinion on 16 April 2026 (ECLI: EU:C:2026:320).
5. Request. In addition to the requests already made, I respectfully ask the Committee to extend its examination to Poland's
compliance with Article 5(2) of Directive (EU) 2024/1233 and to include the question of transposition of that directive in any request
for an opinion addressed to the European Commission.
All figures cited above come from documents of the Polish authorities themselves; source references are available on request.
Yours faithfully
P. (petitioner in petition no. 40679)
