Office for Foreigners

The Office for Foreigners reminds you that the legal provisions in force from 27 April 2026 [i] stipulate that an application for a temporary residence permit, a permanent residence permit or a long-term resident’s EU residence permit lodged electronically via the form available in the Case Handling Module (MOS) must be signed with a qualified electronic signature or a trusted signature exclusively by the foreigner who is the applicant, or – in cases where that person does not have full legal capacity – by the relevant legal representative (parent, guardian, curator). The law does not provide for the possibility of the application being signed on the MOS portal by any other person, including a person to whom the applicant has granted power of attorney to act in the proceedings to be initiated by this application. The law [ii] treats the signing of the application in electronic form with a valid signature by an authorised person as a condition for the application to be deemed lodged. 

If the application form for a residence permit is signed on the MOS portal by a person other than the applicant themselves, and in respect of whom it can be unequivocally established that they cannot act as the foreigner’s legal representative, the application cannot be deemed to have been lodged. In legal terms, this will be a non-existent application which will have no legal effect on the foreigner to whom it was to relate and cannot be supplemented. In such a case, the voivode will not request that the formal deficiencies in the application be rectified by having it signed by an authorised person, on pain of the application being left unexamined [iii], but will merely notify the foreigner to whom the application was to relate that it cannot be deemed to have been lodged and, consequently, is a legally non-existent application. 

The Office for Foreigners also reminds applicants that, from 27 April 2026, applications to the voivode for a temporary residence permit [iv], a permanent residence permit and a long-term resident’s EU residence permit may only be lodged via the MOS portal. Any application lodged without complying with these requirements will result in the voivode leaving it unexamined without requesting the applicant to rectify any formal deficiencies [v]. 

 

[i] Article 106d(3), Article 203d(3) and Article 219d(3) of the Act of 12 December 2013 on Foreigners (Journal of Laws of 2025, item 1079, as amended);
[ii] Article 106d(6)(1), Article 203d(5)(1) and Article 219d(5)(1) of the Act of 12 December 2013 on Foreigners;
[iii] in this case, the provision of Article 64 § 2 of the Act of 14 June 1960 – Code of Administrative Procedure (Journal of Laws of 2025, item 1691) shall not apply;
[iv] save where an application for a temporary residence permit is made on behalf of the foreigner by a separated family member within the meaning of Article 3(2a) of the Act of 12 December 2013 on Foreigners or by a host entity within the meaning of Article 3(5b) of that Act;
[v] pursuant to Article 106c(5), Article 203c(5) and Article 219c(3) of the Act of 12 December 2013 on Foreigners.