Temporary protection for Ukrainian citizens in EU countries has been officially extended until March 4, 2028, providing basic rights to stay, work, and access social support. However, for those who have already found employment, adapted, and plan to build a long-term future in Europe, this status remains dependent on future decisions from Brussels. According to Wave (RBC.ua), transition programs from temporary protection to standard residence permits exist in 28 countries worldwide, and in most of them, they are available to Ukrainians. Moving to such a status removes dependence on the Temporary Protection Directive, increases stability, and opens a path to permanent residency or citizenship.
Why switch from temporary protection to a residence permit?
Temporary protection is an "emergency" mechanism: it grants the right to stay, work, and use basic services, but it does not guarantee a long-term future. Once the directive's validity is reviewed, the status may change. Obtaining a standard residence permit, by contrast, secures the right to reside for several years, regardless of the future of temporary protection. For Ukraine, this is especially relevant amidst the ongoing war: more and more citizens are seeking a more sustainable legal status. However, each country manages this transition through its own rules, with varying timeframes, grounds, and financial requirements.
Poland and Czech Republic: From CUKR to a Five-Year Permit
Poland has introduced a special temporary residence card, CUKR, for Ukrainians residing in the country with PESEL UKR status. Its main goal is to allow a transition to standard living conditions for a term of three years. A fixed minimum income for the card is not set; the key conditions are having an active PESEL UKR status on a specific date, continuous stay in the country for a set period, and updating personal details with local authorities. The Czech Republic, meanwhile, acts within the framework of the Lex Ukraine legislative update, issuing a special five-year residence permit to financially independent and economically active Ukrainians with open access to the labor market. Applicants must have lived under temporary protection for at least two years, have no debts or criminal records, renounce social benefits, and confirm their pre-tax annual income — the specific threshold is determined individually.
Ireland, Austria, and Slovenia: Different Transition Models
Ireland operates the Temporary Protection Transition Scheme, which allows a move from temporary protection to a Stamp 4 permission for two years with a possibility of further extension. Austria offers Ukrainians the Red-White-Red Card Plus, which grants the right to reside and unrestricted access to the labor market without being tied to a specific employer; key requirements include official employment or insured self-employment for at least 12 months over the last two years, as well as proof of German language proficiency at least at the A1 level. Slovenian authorities, in turn, allow the issuance of standard residence permits on general grounds: formal employment, study, business operations, or family reunification. There is no single fixed income threshold in Slovenia: financial requirements are calculated individually based on the ground, the minimum living standard, and the number of family members.
Germany, Spain, and Other EU Countries
Germany has not created a separate "Ukrainian" residence permit but allows for the legal change of Paragraph 24 (temporary protection) to a standard residence permit based on general legislation (AufenthG). The Spanish government has adopted special instructions for the State Secretariat for Migration, significantly simplifying the transition for Ukrainians to full residence permits. In the Netherlands, temporary protection grants the right to work, but for long-term living after the directive expires, changing status is necessary. Slovakia offers a relatively simple mechanism to transition from temporary asylum (Dočasné útočisko) to a standard residence permit (Prechodný pobyt). Lithuania allows submitting documents for a standard permit without leaving the country, while Estonian law permits changing status to a residence permit for work, business, or study. Portugal also provides Ukrainians with temporary protection (Proteção Temporária) the opportunity to apply for a full residence permit.
Greece and a General Conclusion: What to Keep in Mind
Greece has simplified the transition from temporary protection to a standard residence permit: Ukrainians residing in the country under temporary protection can submit documents for work, study, family reasons, and other grounds without leaving the state. At the same time, the duration of temporary protection in Greece has been extended until March 4, 2027, and the mere fact of having temporary protection does not mean automatic granting of a residence permit — each application is reviewed individually. The general conclusion for all 28 countries is the same: the transition to a residence permit requires compliance with national requirements regarding income, length of stay, language, or grounds for residency, while specific financial thresholds and lists of documents are often set individually. Therefore, before submitting an application, it is recommended that Ukrainians verify current conditions with the official migration authorities of the respective country.
