Temporary protection extension for Ukrainians 2026: what employers must verify

Key data

If you have Ukrainian workers in your company, this regulation affects you directly. Council Implementing Decision (EU) 2026/1912 of 30 July 2026 extended temporary protection for persons displaced from Ukraine that began in 2022 with the Council Implementing Decision (EU) 2022/382. The corrigendum published on 4 August 2026 is strictly technical in nature and does not modify the content of the extension, but its publication is the signal for HR departments to update their documentation.

Temporary protection grants beneficiaries specific rights in all EU Member States: residence, access to the labour market, education and social benefits. For employers, this means that hiring a beneficiary of this protection is legal, but only while the documents proving that protection are valid.

What does this regulation establish?

Council Implementing Decision (EU) 2026/1912 extends the temporary protection regime that the EU activated in 2022, for the first time in its history, to respond to the mass displacement of persons from Ukraine. This temporary protection guarantees beneficiaries the following rights in Member States:

• Residence permit in the host Member State
• Access to the labour market (work permit)
• Access to education for minors and adults
• Access to social benefits and healthcare

The corrigendum published on 4 August 2026 is of exclusively technical nature: it corrects formal errors in the text of Decision 2026/1912, but does not alter any of the recognised rights or the extension periods. There are no substantive changes affecting the situation of workers or the obligations of employers arising from the original rule.

Economic and operational impact

For companies, the impact is not direct cost, but operational and compliance risk. Hiring a person whose work permit has expired or is not correctly linked to the current temporary protection framework may result in an irregular hiring situation, with the administrative and labour consequences that entails.

The operational points of attention for HR departments are:

• Document validity: the work and residence permits of Ukrainian workers must reflect the extension approved by Decision 2026/1912.
• File updates: HR services must verify that the documents held by the company are up to date and correspond to the current extended framework.
• New hires: before incorporating a new worker beneficiary of temporary protection, it is essential to verify that their documentation is valid under the new framework.
• Internal communication: those responsible for recruitment and personnel administration must be aware of the existence of this extension to avoid rejecting candidates with valid documentation or accepting expired documentation.

Who does it affect?

• Employers in Spain and in any EU Member State who have Ukrainian workers on their payroll who are beneficiaries of temporary protection
• Human Resources departments responsible for document management and regulatory compliance in labour immigration matters
• Temporary work agencies (TWAs) that provide Ukrainian workers to user companies
• Labour advisors and management firms that manage contracts and registrations with Social Security of foreign workers
• Public administrations of Member States that manage temporary protection records and documents
• Persons displaced from Ukraine who reside and work in the EU under this regime

Practical example

A logistics company in Madrid has 12 Ukrainian workers on its payroll hired in 2023 under the temporary protection activated by Decision (EU) 2022/382. With the publication of Decision 2026/1912 and its corrigendum, the HR manager must:

1. Review the work and residence permits of the 12 workers to verify that their validity is aligned with the extension approved in July 2026.
2. Request workers whose documents are about to expire to provide evidence of renewal under the new temporary protection framework.
3. Update internal files with renewed documentation before previous permits expire.

If the company does not carry out this verification and a worker continues to provide services with an expired permit, the company could face an irregular hiring situation, even if the intention was to comply with the regulation. The corrigendum published on 4 August 2026 does not change the deadlines, but it is the ideal time to carry out this review.

What should companies do now?

1. Identify affected workers: locate in your payroll all Ukrainian employees working under temporary protection (Decision 2022/382 and its extensions).
2. Review the validity of their permits: verify that the work and residence permits of each worker are valid under the framework extended by Decision 2026/1912.
3. Request updated documentation: ask workers with documents about to expire to provide renewal or evidence of the extension issued by the competent authority.
4. Update personnel files: incorporate renewed documentation into internal files and the HR management system.
5. Inform the recruitment team: ensure that those managing new hires are aware of the existence of this extension and know which documents are valid for hiring new beneficiaries.
6. Consult with your labour advisor: if you have doubts about the specific validity of any document or about the renewal procedure in your autonomous community, consult with a professional specialising in labour immigration.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D1912R(01)