Can You Change Your Country of Temporary Protection in the EU: 2026 Rules

A woman from Kharkiv moved to Poland in 2022, got her PESEL UKR, and lived in Warsaw for two years. Then she found a job in Munich and decided to move. She officially cancelled her Polish protection, bought a ticket, and arrived in Bavaria. That’s when she found out the local Ausländerbehörde no longer issues §24 permits to people who already had temporary protection in another EU country - a rule that came into force in March 2025.

This isn’t an isolated situation. According to Eurostat data, 4.37 million Ukrainians held temporary protection across the EU as of April 2026. A large share of them have considered moving between EU countries, or have already done it. The rules here are far from obvious, and getting it wrong can mean months without official status, no benefits, and no health insurance.

Here’s everything you need to know: whether you can change countries, how to do it correctly in 2026, where doors are now closed, and what happens to everyone after March 2027.

The core rule: temporary protection in one country only¶

EU temporary protection is governed by Directive 2001/55/EC - adopted in 2001 and activated for the first time ever for Ukraine in March 2022. One of the directive’s fundamental principles: a person can hold temporary protection status in only one EU member state at a time.

This isn’t a bureaucratic formality - it’s the legal logic the whole system runs on. Temporary protection assigns responsibility for you to a specific country: it pays your allowance, gives you healthcare access, and grants the right to work and study. If you could hold protection in two countries simultaneously, both would be paying and neither would be accountable.

When you move and register for protection in a new country, your status in the previous one automatically ends. It doesn’t “transfer” or “migrate” with you - it simply stops. You submit a new application, go through a new registration, and receive status valid until the common end date for everyone: 4 March 2027.

Crucially: there is no formal “transfer” procedure between countries. No form, no request, no paperwork that lets you port your status from one country to another. Everything starts from scratch in the new country.

The European Commission’s FAQ on the Temporary Protection Directive makes this explicit:

Beneficiaries of temporary protection are entitled to take up employment and access the labour market and vocational training in a member state other than the one that granted them temporary protection status, provided they hold a valid residence permit issued by that other member state.

Even the right to work in a different EU country requires having already registered and received a residence permit there - it’s not an automatic extension of your existing status.

Why moving between countries was easier from 2022 to 2024¶

The original directive included a mechanism against “protection shopping” - choosing the most generous country. Article 11 gave member states the right to send a person back to the country where they first received protection if they moved without authorisation.

When the directive was activated for Ukraine in 2022, though, the EU Council decided not to apply Article 11 to Ukrainians. This was an unprecedented exception, never used in the directive’s 20-year history.

In practice, it meant: if you moved from Poland to Germany, Poland couldn’t demand you back. A de facto freedom of secondary movement formed across EU member states for Ukrainians. Poland in 2022-2023 became the first stop for hundreds of thousands of people - shared border, linguistic proximity, fast registration through PESEL UKR. Then many moved on to Germany, where Bürgergeld reached €563 per month, the healthcare system was more developed, and the labour market was bigger.

The European Council on Refugees and Exiles (ECRE) described this in their Policy Note on secondary movement:

The suspension of Article 11 created, for the first time in the history of the Temporary Protection Directive, a situation where beneficiaries could freely choose their member state of protection. This was unprecedented and reflected the exceptional nature of the Ukrainian displacement crisis.

That open window lasted roughly from 2022 through the end of 2024. Then the biggest host country - Germany - closed the door.

What changed in 2025: Germany’s and Poland’s new restrictions¶

Germany: new rules from March 2025¶

From 5 March 2025, a critical provision took effect in Germany: Ukrainians who already hold temporary protection in another EU country can no longer receive §24 AufenthG - the residence permit based on temporary protection. This closed the most popular route: Poland → Germany.

The official germany4ukraine.de portal states it plainly:

Persons who have already been granted temporary protection in another EU member state are no longer eligible for facilitated entry under §24 of the Residence Act in Germany.

In practice: if you currently have active temporary protection in Poland, Czech Republic, Austria, or any other EU country, and you want to move to Germany - you first need to officially cancel your protection in the previous country. Only after that will the Ausländerbehörde review a §24 application.

The catch: once you cancel your previous status, you’re technically without protection. And Germany doesn’t issue a new §24 the next day. So there’s a real legal gap (more on this in the next section).

Another change from the same date: Germany cut benefit levels for new arrivals. Before April 2025, an adult received €563/month (Bürgergeld); new arrivals after that date get €441 (Asylbewerberleistungsgesetz). For anyone who was planning the move primarily for higher benefits - the financial gap has shrunk considerably.

Poland: closed to secondary movers¶

Poland had already closed its doors to secondary arrivals earlier: if you already hold temporary protection in another EU country, you can’t get a Polish PESEL UKR.

On top of that, Poland ended its emergency “Special Act” for Ukrainians on 5 March 2026 - the crisis-era support framework from 2022. Temporary protection under the EU directive remains valid until 4 March 2027, but is now governed by general foreigners legislation. Poland introduced the CUKR card (karta CUKR) - a new three-year residence permit for Ukrainians replacing the emergency arrangement.

Czech Republic and France¶

Czech Republic requires you to actually live at your registered address. If you’re registered in Prague but living in Vienna, the Czech authorities can revoke your protection for absence. There are documented cases of this happening.

France doesn’t renew protection automatically - you need to appear in person at a prefecture about three weeks before expiry. If you’re physically in another country when that deadline hits, you lose your status.

How to actually move: a step-by-step process¶

If you’ve decided to change your country of temporary protection, here’s how to do it with minimum risk.

Step 1: Check whether the new country accepts you

Before doing anything - verify that the new country actually registers temporary protection for people who already have it elsewhere in the EU. As of June 2026: - Germany - won’t issue §24 if you have active status in another EU country (cancel first) - Poland - closed to secondary movers - Czech Republic, Austria, Netherlands, Belgium, Spain, France - generally yes, but conditions vary and you’ll need to check current requirements

Step 2: Don’t cancel your status in country A prematurely

Before officially withdrawing protection - organise your move: find an address in the new country, find out where and how to register, check appointment availability. Ideally: arrive, book your first appointment with migration authorities, confirm everything is feasible, and only then notify your previous country.

Step 3: Formally end your protection in country A

This typically involves: - A written notification to the migration authority (Ausländerbehörde in Germany, Urząd Wojewódzki in Poland, etc.) - Returning your residence documents and any cards - Repaying pro-rated benefits if you’ve already received payments covering future months

Step 4: Apply in country B

Standard documents needed for registration: - Valid Ukrainian passport - If no passport: any photo ID confirming Ukrainian citizenship - Proof of residence in Ukraine before 24 February 2022 (rental agreements, registry extracts, utility bills - if available) - For family members: marriage certificate or children’s birth certificates

On document translations

For registration itself, a passport is usually enough. But for social benefits, healthcare, and school enrolment - you’ll need certified translations of birth certificates, marriage certificates, and other documents. The format depends on the country: Germany requires a beglaubigte Übersetzung from a sworn translator, France requires a traduction assermentée from a French sworn translator, Austria and Czech Republic have similar requirements. Ukrainian translations, even notarially certified ones, are generally not accepted - you need a translator registered in the destination country.

The legal gap: the most dangerous moment of the move¶

Between cancelling protection in country A and receiving new status in country B, there’s a legal gap. During this period: - You have no official residence status in any EU country - You have no right to social benefits - You have no right to free healthcare (emergency care is the exception) - You’re technically in the Schengen area as a tourist (90 days visa-free), but without the right to work or receive benefits

This gap can last from a few days to several months, depending on how busy the migration authorities are in the new country.

How to minimise the risk:

1. Don’t cancel your status in country A until you’ve arrived in country B and submitted an application. Keep the confirmation of submission - even without a decision, proof that you applied is already a legal basis.

2. Ask whether country B issues a temporary document while your application is being reviewed. Most countries issue something like Germany’s Fiktionsbescheinigung - it confirms your application is pending. It’s not full status, but it provides some legal protection.

3. Don’t let your health insurance in country A lapse on the last day. If you can, arrange a small overlap: country A’s insurance ends a few days after you’ve physically left.

4. Understand the difference between “application submitted” and “status granted”. Benefits and rights only start with the official decision.

The EU Court of Justice ruling in the Krasiliva case (C-753/23, February 2025) added some flexibility: the court held that a member state cannot automatically reject a temporary protection application just because the person previously applied or held protection elsewhere. Each application must be assessed on its merits. But this ruling didn’t close the legal gap - it only clarified that parallel applications aren’t automatically illegal.

Country comparison: 2026 temporary protection conditions¶

Overall 2025-2026 trend: benefits are being cut across all major host countries. The shift is from welfare support toward integration - language, employment, self-sufficiency.

What happens after March 2027 - and why it matters now¶

Temporary protection has been extended to 4 March 2027 - the fifth extension, which the EU Council approved in July 2025. But the European Commission’s June 2025 proposal said clearly: this is the last collective extension. After 2027, everyone faces the immigration law of whichever country they’re in individually.

What this means in practice:

Poland has already introduced the CUKR card - a new three-year residence permit for Ukrainians replacing the emergency regime. Those with PESEL UKR need to verify their data by August 2026.

Netherlands has announced it won’t renew its temporary protection programme after 2027. Ukrainians there are transitioning to standard permits - work, family, or student.

Germany keeps pathways for transitioning from §24 to §18b (for those with a recognised diploma), §19c (IT professionals without a degree), or Blaue Karte for highly qualified specialists.

If you’re considering a country switch now - there’s a critical thing to factor in: after moving, the months you spent in your previous country don’t count toward permanent residence requirements in the new one. If you’ve been in Poland for three years and move to Germany in 2026, those years don’t count toward Niederlassungserlaubnis - you start from zero. With less than a year left before the 2027 deadline, that’s very little time to build up the residency history you’ll need.

Moving in 2026-2027 primarily for higher benefits may not pay off: benefits are being cut everywhere, and there’s almost no time left to settle in properly.

FAQ¶

Can you hold temporary protection in two EU countries at the same time?¶

No. Directive 2001/55/EC explicitly provides that protection is granted by only one member state at a time. If you apply and receive status in country B, your protection in country A automatically ends. Trying to maintain both statuses (for example, keeping a Czech registration while actually living in Germany) violates the conditions of your status and can result in cancellation in both countries.

Do months of temporary protection in one EU country count when moving to another?¶

For the duration of protection itself - yes, it runs until 4 March 2027 for everyone regardless of which country you’re in or how many times you’ve moved. But for permanent residence or citizenship requirements - no, months in Poland don’t count toward permanent residence in Germany, Czech Republic, or any other new country. Your residency clock starts from zero on the date of your new registration.

Do you need translated documents to register for temporary protection in a new country?¶

Registration itself typically only requires a passport. But to access social benefits, healthcare, and school enrolment you’ll need certified translations of birth certificates, marriage certificates, and other civil documents. The format depends on the country: Germany requires a beglaubigte Übersetzung, France a traduction assermentée, Austria and Czech Republic have similar requirements. Translations made in Ukraine, even with a notary stamp, are generally not accepted - you need a translator registered in the destination country.

What happens to social benefits during the move between EU countries?¶

Benefits in country A end on the date your status is officially cancelled. Benefits in country B only start once you receive your new status - so there’s a gap with no income coming in from either side. This gap can last anywhere from a few days to several months depending on how quickly the migration authorities process your application.

How long does temporary protection last after you move to a new EU country?¶

Until the EU-wide expiry date - 4 March 2027. Moving doesn’t reset or extend this deadline. If you registered in a new country in 2026, you have less than a year of protection left, regardless of how long you spent in your previous country.

Sources¶

1. Council Directive 2001/55/EC on temporary protection - full text of the directive
2. European Commission FAQ on the Temporary Protection Directive and Council Decision 2022/382
3. Germany4Ukraine.de: changes to entry and residence rules for Ukrainians
4. Eurostat: temporary protection data, April 2026
5. ECRE: analysis of secondary movement under the Temporary Protection Directive (2023)
6. Court of Justice of the EU, Case C-753/23 (Krasiliva), February 2025
7. EUAA: FAQ on temporary protection (Ukrainian language version)
8. EU Council: extension of temporary protection to 4 March 2027 (June 2025)