Poland

Country score (EU Average*)

90(72) Political Financing
69(57) Financial Disclosure
47(49) Conflict of Interest
35(59) Freedom of Information
52(63) Public Procurement
67(66) Anti Money Laundering
53(71) Asset Recovery

Country Facts

Income	High
GNI per capita (2011 PPP $)	24981.54
Population, total	37948016.00
Urban population (% of total)	60.53
Internet users (per 100 people)	73.30
Life expectancy at birth (years)	78.20
Mean years of schooling (years)	11.9
Global Competitiveness Index	4.6

Sources: World Bank, UNDP, WEF.

Political Financing

The Law on Political Parties (1997, amended 2008) and the Election Code of Poland 2011 are the main laws regulating the financing of political parties in Poland.

There are comprehensive limits on the private income of political parties. Donations are banned from foreign interests, corporations, trade unions and anonymous donors in addition to a number of other sources which are prohibited. There are also specific rules on how many can be raised and there are limits on the amount that can be donated.

There is public funding available for parties and is allocated in proportion to the number of votes received. Public funding can be used for campaign spending as well as other activities prescribed by the law. Subsidized access to the media is also available.

There are regulations on spending such as bans on vote buying and bans on state resources being used in favour or against a political party or candidate. There are also limits on how much a political party or candidate can spend.

Parties are required to provide reports annually. These are to include information in relation to the finances of election campaigns and in some cases must reveal the identity of donors. The reports must be made public. The reports are overseen by State Electoral Commission and auditors. Sanctions for breaches of the provisions of the law include fines, the loss of public funding, forfeiture, de-registration of the party, the loss of political rights as well as criminal law sanctions.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Bans and limits on private income	28	28	28	28	28	83
Public funding	38	38	38	38	38	75
Regulations on spending	0	0	0	0	0	100
Reporting, oversight and sanctions	83	92	92	92	92	100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Bans and limits on private income
Is there a ban on donations from foreign interests to political parties?	Yes. The political party may be transferred funds only by Polish citizens who are permanent place of residence in the territory of the Republic of Poland, subject to the provisions of art. 24 sec. 4 and 7, art. 28 para. 1 and the provisions of laws concerning elections to the Sejm of the Republic of Poland and to the Senate of the Republic of Poland Polish and elections to the European Parliament in the area of subject-based subsidies. (Law on Political Parties, 1997, amended 2016, Art 25(1) Article 25.1, ustawa o partiach politycznych 1997 (Law on Political Parties 1997, consolidated text 2023))
Is there a ban on donations from foreign interests to candidates?	Yes. For presidential candidates. The financial resources election committee of a candidate for President of the Republic can only come from the contributions of Polish citizens who have a permanent residence in the Polish Republic, the election funds of political parties and bank loans contracted for purposes related to elections.‌ (Election Code 2011, Art 132.4 Article 25.1, ustawa o partiach politycznych 1997 (Law on Political Parties 1997, consolidated text 2023))
Is there a ban on corporate donations to political parties?	Yes. 1. The political party may be transferred funds only by Polish citizens who are permanent place of residence in the territory of the Republic of Poland, subject to the provisions of art. 24 sec. 4 and 7, art. 28 para. 1 and the provisions of laws concerning elections to the Sejm of the Republic of Poland and to the Senate of the Republic of Poland Polish and elections to the European Parliament in the area of subject-based subsidies. Art 24(4) A political party may derive income from its assets originating only from: 1) interest paid on funds deposited in bank accounts and term deposits, 2) trading in Treasury bonds and Treasury bills, 3) sale of assets owned by it, 4) activities referred to in Article 27. Art 24(7) A political party may take out bank loans for purposes in line with its constitution. Art 28 relates to public funding. (Law on Political Parties, 1997, amended 2016, Art 25(1))
Is there a ban on corporate donations to candidates?	Yes. Financial resources of: 1) the election committee of an organization, 2) the voters election committee- shall only come from the contributions of Polish citizens with their permanent domicile in the Polish Republic, and bank loans taken out solely for purposes related to elections. § 4 The financial resources of the election committee for the candidate for President of the Republic can only come from the contributions of Polish citizens with permanent domicile in the Polish Republic, and the election funds of political parties and bank loans taken out for purposes related to elections (Election Code 2011 , Art 132)
Is there a ban on donations from corporations with government contracts to political parties?	Yes. 1. A political party may receive funds only from natural persons, (Law on Political Parties, 1997, amended 2016, Art 25(1))
Is there a ban on donations from corporations of partial government ownership to political parties?	Yes. 1. A political party may receive funds only from natural persons, (Law on Political Parties, 1997, amended 2016, Art 25(1))
Is there a ban on donations from corporations with government contracts to candidates?	Yes. Financial resources of: 1) the election committee of an organization, 2) the voters election committee - shall only come from the contributions of Polish citizens with their permanent domicile in the Polish Republic, and bank loans taken out solely for purposes related to elections. § 4 The financial resources of the election committee for the candidate for President of the Republic can only come from the contributions of Polish citizens with permanent domicile in the Polish Republic, and the election funds of political parties and bank loans taken out for purposes related to elections (Election Code 2011 , Art 132)
Is there a ban on donations from corporations of partial government ownership to candidates?	Yes. Financial resources of: 1) the election committee of an organization, 2) the voters election committee - shall only come from the contributions of Polish citizens with their permanent domicile in the Polish Republic, and bank loans taken out solely for purposes related to elections. § 4 The financial resources of the election committee for the candidate for President of the Republic can only come from the contributions of Polish citizens with permanent domicile in the Polish Republic, and the election funds of political parties and bank loans taken out for purposes related to elections (Election Code 2011 , Art 132)
Is there a ban on donations from Trade Unions to political parties?	Yes. 1. A political party may receive funds only from natural persons, (Law on Political Parties, 1997, amended 2016, Art 25(1))
Is there a ban on donations from Trade Unions to candidates?	Yes. Financial resources of: 1) the election committee of an organization, 2) the voters election committee - shall only come from the contributions of Polish citizens with their permanent domicile in the Polish Republic, and bank loans taken out solely for purposes related to elections. § 4 The financial resources of the election committee for the candidate for President of the Republic can only come from the contributions of Polish citizens with permanent domicile in the Polish Republic, and the election funds of political parties and bank loans taken out for purposes related to elections (Election Code 2011 , Art 132)
Is there a ban on anonymous donations to political parties?	Yes. The financial resources of the election committee for the candidate for President of the Republic can only come from the contributions of Polish citizens with permanent domicile in the Polish Republic (Election Code 2011 , Art 132)
Is there a ban on anonymous donations to candidates?	Yes. but with an specific limit Donations exceeding one minimum wage must be recorded including name and address of donor, indicating a de facto ban on donations over that amount. § 1 The [election] Committee is obliged to keep records of: 1) loans, including the name of the bank granting the loan and all the essential conditions for its recovery, in particular: the date of the loan, its amount, interest and other costs of its acquiring, guarantors, and the commitment to be repaid; 2) payment from one individual of a value exceeding the amount of the minimum wage, defined under the Act of 10 October 2002 on the minimum wage, as applicable on the day preceding the announcement of the date of elections, indicating the name, surname and place of residence of such person. According to the Electoral Code election campaigns are financed exclusively through the electoral committees, and not individual candidates. Anonymous donations to electoral committees are prohibited. (Art 140 Election Code 2011 Article 84 § 1, Election Code, 2011 (amended 2019))
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)?	Yes. Political Party Law 25 1. A political party may receive funds only from natural persons Election Code § 3 Financial resources of: 1) the election committee of an organization, 2) the voters election committee - shall only come from the contributions of Polish citizens with their permanent domicile in the Polish Republic, and bank loans taken out solely for purposes related to elections. (Law on Political Parties, 1997, amended 2016, Art 25(1) Art 132(1) Election Code 2011 )
Is there a ban on any other form of donation?	No. Absent from legal framework
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)?	Yes. The total sum of payments from a natural person to a political party, excluding membership fees amounting in any given year to not more than the minimum wage set in pursuance of separate regulations, prevailing on the day immediately preceding the date of payment, as well as payments to the Election Fund of a political party may not exceed in any given year 15 times the minimum wage set in pursuance of separate regulations, prevailing on the day immediately preceding the date of payment. (Law on Political Parties, 1997, amended 2016, Art 25(4))
Is there a limit on the amount a donor can contribute to a political party in relation to an election?	Yes. 134, § 2 The sum of contributions from a Polish citizen for the election committee may not exceed 15 times the minimum wage (Art 134(2) Election Code 2011)
Is there a limit on the amount a donor can contribute to a candidate?	Yes. There is a limit on the amount that can be contributed to electoral committees. the limit is 15 times the minimum wage (Art 134(2) Election Code 2011)
Public funding
Eligibility criteria for direct public funding to political parties	Yes. See sub-indicators
Eligibility criteria for direct public funding to political parties: Share of votes in previous election	Yes. 1. A political party which: 1) in an election to the Sejm, having independently formed an electoral committee, received nationwide at least 3% of validly cast votes on its district lists of candidates for deputies, or 2) in an election to the Sejm was a member of a coalition, whose district lists of candidates for deputies received nationwide at least 6% of validly cast votes, shall be entitled to receive for the duration of the term of office of the Sejm, in the manner and in accordance with the rules set out in this Act, a subsidy from the state budget for its activities envisaged by its constitution, hereinafter referred to as the “subsidy”. (Law on Political Parties, 1997, amended 2016, Art 28(1))
Eligibility criteria for direct public funding to political parties: Representation in elected body	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Participation in election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of candidates	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of votes in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other	No. Absent from legal framework
Allocation calculations for direct public funding to political parties	Yes. See sub-indicators
Allocation calculations for direct public funding to political parties: Proportional to votes received	Yes. The amount of the annual subsidy referred to in Article 28 for a given political party or an electoral coalition shall be determined on a gradual degression basis pro rata to the total number of valid votes cast on district lists of candidates for deputies of such a party or electoral coalition, with breakdown by the number of votes corresponding to individual percentage brackets, in accordance with the following formula: S = W 1 x M 1 + W 2 x M 2 + W 3 x M 3 + W 4 x M 4 + W 5 x M 5 where individual symbols mean: S - amount of annual subsidy, W 1-5 - numbers of votes calculated successively for each line of the following table, provided separately as a result of breaking down the total number of valid votes cast nationwide on district lists of candidates for deputies from a given political party or electoral coalition according to the percentage bracket, M 1-5 - amount in PLN for consecutive lines of the following table: (Law on Political Parties, 1997, amended 2016, Art 29(1))
Allocation calculations for direct public funding to political parties: Equal	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to seats received	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Flat rate by votes received	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties	Yes. See sub-indicators
Earmarking provisions for direct public funding to political parties: Campaign spending	Yes. Parties should generally use the funds for activities in line with its constitution and for charity. There is a limit on how much money can be transferred from the state subsidy to the electoral fund of the party. “A political party which is in receipt of the subsidy shall remit between 5% and 15% of the subsidy to the Expert Fund.” Article 24: "2.‌ A political party’s assets may only be used for purposes in line with its constitution or for charitable purposes.‌" Article 30: "3.‌ A political party which is in receipt of the subsidy shall remit between 5% and 15% of the subsidy to the Expert Fund.‌" (Law on Political Parties, 1997) (Law on Political Parties, 1997, amended 2016, Art 24(2) & 30(3))
Earmarking provisions for direct public funding to political parties: Ongoing party activities	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Intra-party institution	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Other	Yes. activities in line with the party constitution and charity Parties should generally use the funds for activities in line with its constitution and for charity. There is a limit on how much money can be transferred from the state subsidy to the electoral fund of the party. “A political party which is in receipt of the subsidy shall remit between 5% and 15% of the subsidy to the Expert Fund.” Article 24: "2.‌ A political party’s assets may only be used for purposes in line with its constitution or for charitable purposes.‌" Article 30: "3.‌ A political party which is in receipt of the subsidy shall remit between 5% and 15% of the subsidy to the Expert Fund.‌" (Law on Political Parties, 1997) (Law on Political Parties, 1997, amended 2016, Art 24(2) & 30(3))
Allocation criteria for free or subsidized access to media for political parties	Yes. See sub-indicators
Allocation criteria for free or subsidized access to media for political parties: Equal	Yes. Art 253.1 "1 Time devoted to the dissemination of election programs, referred to in art. 252 § 2 point 1 shall be divided equally between the eligible electoral committees on the basis of the information provided by the National Electoral Commission on electoral committees, which registered its list of candidates in at least half of the constituencies." (Election Code 2011, Art. 253)
Allocation criteria for free or subsidized access to media for political parties: Number of candidates	Yes. Art 253.2 "Time devoted to the dissemination of election programs, referred to in art. 252 § 2 item 2, is divided between eligible electoral committees in proportion to the number of registered lists of candidates, on the basis of the information about the lists, provided by the district electoral commission appropriate to the area covered by the regional program." (Election Code 2011, Art. 254)
Allocation criteria for free or subsidized access to media for political parties: Share of seats	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Other	No. Absent from legal framework
Are there provisions for free or subsidized access to media for candidates?	Yes. Article 252 § 1 "An election committee has the right to free broadcasting of electoral programs through public radio and television broadcasters: 1) nationwide - if they register their lists of candidates in at least half of the constituencies; 2) regional - if the registered list of candidates in at least one electoral district." § 2 "Total time broadcasting of election shall be: 1) in the national programs - 15 hours in Polish TV, including 3 hours of TV Polonia, and 30 hours of programs, in Polish Radio S.A, and affiliates, hereinafter referred to as "Polish Radio", including up to 5 hours in a program intended for the foreign distribution; 2) in the regional programs - 10 hours in Polish TV and 15 hours on the Polish Radio." Article 253 § 1 "Time devoted to the dissemination of election programs, referred to in art. 252 § 2 point 1 shall be divided equally between the eligible electoral committees on the basis of the information provided by the National Electoral Commission on electoral committees, which registered its list of candidates in at least half of the constituencies." § 2 "Time devoted to the dissemination of election programs, referred to in art. 252 § 2 item 2, is divided between eligible electoral committees in proportion to the number of registered lists of candidates, on the basis of the information about the lists, provided by the district electoral commission appropriate to the area covered by the regional program." (Election Code 2011, Art. 252 & Art. 253)
Are there provisions for any other form of indirect public funding?	Yes. The mayor immediately after the start of the election campaign will provide in the municipal area an adequate number of sites for free placement of official election notices and posters of all election committees and give a list of these places to the public in the customary manner and in the Public Information Bulletin. (Article 114, Election Code, 2011 (amended 2019))
Provisions for any other form of indirect public funding: Premises for campaign meetings	No. Absent from legal framework
Provisions for any other form of indirect public funding: Space for campaign materials	No. Absent from legal framework
Provisions for any other form of indirect public funding: Tax relief	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised transport	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost	No. Absent from legal framework
Provisions for any other form of indirect public funding: Other	No. Absent from legal framework
Is the provision of direct public funding to political parties related to gender equality among candidates?	No / Yes ? . There is an indirect link between the entitlement to direct public funding and a political party’s election committee meeting the requirement of gender parity on candidate lists. To receive subvention, a political party must have registered through its election committee lists of candidates for the Sejm that receive at least 3% of the valid votes cast (6% for coalition of parties). For this to be possible, it is required to have candidate lists with no less than 35% of candidates of each gender. Otherwise, such candidate lists will not be registered, the party’s election committee will not be able to effectively participate in the Sejm elections, and therefore will have no chance of obtaining this entitlement. (Article 28.1, ustawa o partiach politycznych 1997 (Law on Political Parties 1997, consolidated text 2023))
Are there provisions for other financial advantages to encourage gender equality in political parties?	No / Yes ? . There is an indirect link between the entitlement to direct public funding and a political party’s election committee meeting the requirement of gender parity on candidate lists. To receive subvention, a political party must have registered through its election committee lists of candidates for the Sejm that receive at least 3% of the valid votes cast (6% for coalition of parties). For this to be possible, it is required to have candidate lists with no less than 35% of candidates of each gender. Otherwise, such candidate lists will not be registered, the party’s election committee will not be able to effectively participate in the Sejm elections, and therefore will have no chance of obtaining this entitlement. (Article 28.1, ustawa o partiach politycznych 1997 (Law on Political Parties 1997, consolidated text 2023))
Regulations on spending
Is there a ban on vote buying?	Yes. Art. 497.3 "Whomever gives or receives financial or personal benefit in exchange for collecting or signing the declaration a list of candidates or candidate - is subject to a fine from 10,000 to 50,000 zlotys." (Election Code, 2011. Art. 497)
Are there bans on state resources being used in favour or against a political party or candidate?	Yes. Article 495 § 1 "Whomever, in connection with the elections: 1) places election posters and slogans on the walls of buildings, public transport stops, apartments, tables and columns boards, fences, lampposts, power equipment, telecommunications and others without the consent of the owner or manager of real estate, facility or equipment, 2) in the process of setting up their own announcement posts for the purpose of electoral campaigning violates the applicable provisions of law enforcement, 3) places election posters and slogans so that they can not be removed without damage, 4) places election posters and slogans with a surface area greater than 2m2, 5) distributes electoral advertisements in public programs or by way of non-public radio or television broadcasters; - is subject to a fine." (Election Code, 2011. Art. 495)
Are there limits on the amount a political party can spend?	Yes. Article 199 § 1 "In parliamentary elections, electoral committees must adhere to the following spending limits for election campaigning: 1) the spending limit is determined in the amount of 82 polish groszy per voter in the country included in the register of voters; 2) the spending limit for the committee calculated as follows: Unofficial translation for OSCE/ODIHR. 80 L = (w x k x m) / 460, where the symbols are defined as: L - spending limit, w - the number of voters in the country included in the register of voters k - the amount attributable to each voter in the country included in the register of voters referred to in paragraph 1 m - total number of deputies elected in all the constituencies in which the committee has submitted a list of candidates. § 2 National Electoral Commission, within 14 days of ordering of the election to the Sejm, shall make an announcement in the Official Journal of the Polish Republic, "Polish Monitor" and publish the information the Public Information Bulletin on the number of voters included in voter registries across the country current for the end of the quarter ending on the day before preceding the date of announcement of elections to the Sejm. " (Election Code, Art. 199)
Are there limits on the amount a candidate can spend?	Yes. Limits for election committees apply to candidates. Limit depends on the number of seats and registered voters in each district. (Election Code, Art. 199)
Reporting, oversight and sanctions
Do political parties have to report regularly on their finances?	Yes. annually - Article 38: "1.‌ A political party shall submit to the State Electoral Commission, by 31 March of each year at the latest, a report on the sources of raised funds, including bank loans and terms on which these were obtained and on spending out of the Election Fund in the previous calendar year, hereinafter referred to as the "report".‌" (Law on Political Parties, 1997, amended 2016, Art 38(1))
Do political parties have to report on their finances in relation to election campaigns?	Yes. § 1 Within 3 months from the date of the election, the financial representative shall submit to the competent electoral body, to which the elections committee submitted its notification of establishment, a report on revenues, expenditures and financial commitments of the committee, including bank loans and the basis on which they were obtained hereinafter referred to as "financial report." (Art 142(1) Election Code 2011)
Do candidates have to report on their campaign finances?	Yes. The financial agents of the election committees has to submit an elecion report after the elections. § 1 Within 3 months from the date of the election, the financial representative shall submit to the competent electoral body, to which the elections committee submitted its notification of establishment, a report on revenues, expenditures and financial commitments of the committee, including bank loans and the basis on which they were obtained hereinafter referred to as "financial report." (Art 142(1) Election Code 2011)
Is information in reports from political parties and/or candidates to be made public?	Yes. 4. The report together with the opinion and the report referred to in paragraph 3 shall be published by the State Electoral Commission in the Official Journal of the Republic of Poland "Monitor Polski" within 14 days of the date of filing thereof with the State Electoral Commission. (Law on Political Parties, 1997, amended 2016, Art 38(4))
Must reports from political parties and/or candidates reveal the identity of donors?	Yes. Donations exceeding one minimum wage must be recorded including name and address of donor. § 1 The Committee is obliged to keep records of: 2) payment from one individual of a value exceeding the amount of the minimum wage, defined under the Act of 10 October 2002 on the minimum wage, as applicable on the day preceding the announcement of the date of elections, indicating the name, surname and place of residence of such person. (Art 140(1)(2) Election Code 2011)
Institutions receiving financial reports from political parties and/or candidates
Institutions receiving financial reports from political parties and/or candidates: Electoral Management Board	Yes. 1. A political party shall submit to the State Electoral Commission, by 31 March of each year at the latest, a report (Law on Political Parties, 1997, amended 2016, Art 38(1))
Institutions receiving financial reports from political parties and/or candidates: Auditing agency	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Ministry	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Special institution	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Court	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Other	No. Absent from legal framework
Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Ministry	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Auditing agency	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body	Yes. 1. Within 4 months of the date of filing of the statement, the State Electoral Commission shall: 1) approve the statement without qualifications, 2) approve the statement, indicating shortcomings, 3) reject the statement. (Law on Political Parties, 1997, amended 2016, Art 34a(1))
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Other	No. Absent from legal framework
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court	Yes. Auditors are responsible for the validating the repots, the minister responsible for public financing has to specify the specimen of the report, and the parties have the right to lodge to the Supreme Court against the decision of the Commission - according to the law on political parties.The National Election Commission can ask for assistance from public authorities. 1. In the event that the State Electoral Commission rejects the statement, a political party shall have the right to lodge, within 7 days of the date of delivery of the decision about rejection of the statement, a complaint with the Supreme Court against the State Electoral Commission's decision rejecting the statement. (Law on Political Parties, 1997, amended 2016, Art 34b)
Institutions with a formal role in political finance oversight: Ministry	Yes. Auditors are responsible for the validating the repots, the minister responsible for public financing has to specify the specimen of the report, and the parties have the right to lodge to the Supreme Court against the decision of the Commission - according to the law on political parties.The National Election Commission can ask for assistance from public authorities. 4. When examining the statement, the State Electoral Commission may demand necessary assistance from public authorities. (Law on Political Parties, 1997, amended 2016, Art 34a(4))
Institutions with a formal role in political finance oversight: Auditing agency	Yes. Auditors are responsible for the validating the repots, the minister responsible for public financing has to specify the specimen of the report, and the parties have the right to lodge to the Supreme Court against the decision of the Commission - according to the law on political parties.The National Election Commission can ask for assistance from public authorities. 4. The statement shall be filed together with the appended opinion and report of the registered auditor appointed by the State Electoral Commission. Costs of preparing the opinion and the report shall be covered by the National Electoral Office. (Law on Political Parties, 1997, amended 2016, Art 34(4))
Institutions with a formal role in political finance oversight: EMB	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Institution for this purpose	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Other	Yes. Auditors are responsible for the validating the repots, the minister responsible for public financing has to specify the specimen of the report, and the parties have the right to lodge to the Supreme Court against the decision of the Commission - according to the law on political parties.The National Election Commission can ask for assistance from public authorities. 3. The minister responsible for public finances, having consulted the State Electoral Commission, shall specify, by way of a regulation, the specimen of the statement together with necessary guidance as to the manner of preparing same as well as the scope of data contained therein, such as to allow, in particular, reliable verification of data on the use of subsidy proceeds, including proceeds of the Expert Fund. (Law on Political Parties, 1997, amended 2016, Art 34(3))
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines	Yes. A person who 3) donates to a political party or receives on behalf of a political party funds or non-monetary contributions in contravention of the provisions of Article 25, shall be subject to a fine of from PLN 1000 to PLN 100 000. Other fines specified in the provisions following. (Law on Political Parties, 1997, amended 2016, Art 49c & Chapter 6a generally.)
Sanctions for political finance infractions: Loss of public funding	Yes. 1. A political party shall forfeit its entitlement to receive the subsidy for a year, if: 1) it fails to file the statement by the deadline specified in Article 34 (2) or 2) the statement is rejected by the State Electoral Commission or 3) the Supreme Court dismisses the complaint referred to in Article 34b (1). (Law on Political Parties, 1997, amended 2016, Art 34c(1))
Sanctions for political finance infractions: Penal/Criminal	Yes. A person who fails to fulfil or prevents the fulfilment of the obligation to prepare and submit the statement referred to in Article 34 (1) or provides untrue data therein, shall be subject to a fine, a penalty of restriction of liberty or imprisonment of a maximum of 2 years. (Law on Political Parties, 1997, amended 2016, Art 49d)
Sanctions for political finance infractions: Forfeiture	Yes. 1. A political party shall forfeit its entitlement to receive the subsidy for a year, if: 1) it fails to file the statement by the deadline specified in Article 34 (2) or 2) the statement is rejected by the State Electoral Commission or 3) the Supreme Court dismisses the complaint referred to in Article 34b (1). (Law on Political Parties, 1997, amended 2016, Art 34c(1))
Sanctions for political finance infractions: Deregistration of party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of elected office	No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of nomination of candidate	No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights	No. Absent from legal framework
Sanctions for political finance infractions: Other	No. Absent from legal framework

Legislation

Law on Political Parties, 1997, amended 2016 (Polish)	pdf
Election Code 2011 (English)	pdf

*Last update: 2017

Financial Disclosure

The Polish Limitations on Conducting Business Activity by Persons Performing Public Functions Act (1997, amended 2016) apply to the Head of State, Ministers, and Civil Servants. The Head of State and Civil Servants must disclose real estate, movable assets, cash, the property of or shares held in private or public companies, and any positions held in enterprises. The spouse’s assets must be included. Under the same law, Ministers are subject the disclosure of gifts and of positions held in private firms or administration. Meanwhile, the Act on Deputies and Senators (1996, amended 2016) obliges Members of Parliament to disclose real estate, movable assets, debts, income received from outside employment, gifts, and property of or shares held in private and public enterprises.

While the Head of State and Civil Servants make declarations annually, MPs must also update their financial statements ad hoc. Ministers only make declarations ad hoc. The Head of State and Civil Servants face disciplinary sanctions in case of non-filling. MPs are not paid their salary in case of late-filling. The Head of State, MPs, and Civil Servants face possible imprisonment for making false disclosure statements. No sanctions are specified for Ministers. Ministers and MPs make their declarations with the Registry of Benefits, the Head of State with the Supreme Court, and Civil Servants with their government unit. The Central Anticorruption Bureau is responsible for enforcing sanctions amongst Head of State, MPs, and Civil Servants. Only statements by Ministers and MPs are made publicly available.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Disclosure items	6	18	18	17	22	70
Filing frequency	31	38	38	38	38	88
Sanctions	33	33	33	33	17	67
Monitoring and Oversight	31	19	19	19	19	81
Public access to declarations	25	38	38	38	38	38
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	0	0	0	0	0	64
Ministers	29	50	50	50	38	68
Members of Parliament	39	37	37	37	38	79
Civil servants	34	29	29	29	29	64

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Disclosure items
Spouses and children included in disclosure	Yes. The Head of State, MPs, and civil servants are obligated to disclose joint property. Ministers and MPs must submit information on the financial interests and benefits of spouses in a Register of Benefits. The president, prime minister, speaker of the parliament and speaker of the senate must submit a declaration about any ongoing or planned commercial activities of their spouses. (Article 8, 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Income and Assets
Real estate	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Movable assets	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Cash	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Loans and Debts	Yes. Absent from legal framework. Loans and liabilities are not explicitly listed as a separate category in Article 10, but the obligation to disclose “property status” (majątek) is interpreted broadly in Polish jurisprudence and practice to include financial liabilities. This is consistent with how asset declarations are structured in practice. (Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Income from outside employment/assets	Yes. Absent from legal framework. Income is disclosed indirectly through: information on economic activity, functions in companies and benefits recorded in the Register of Benefits (Article 10 and 12, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Incompatibilities
Gifts received as a public official	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Ownership of state-owned enterprises (SOEs)	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Filing required upon leaving office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Filing required annually	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework.
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non- filing of the declaration results in disciplinary sanctions. (Article 13 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. If the person obliged to submit the declaration (asset declaration and declaration about the activity of the spouse), submits false information, he/she will be subject to imprisonment up to 5 years. In cases of lesser importance a person committing the act shall be liable to a fine, penalty of restricted liberty or deprivation of liberty of up to one year. (Article 14 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The depository body is the First President of the Supreme Court. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Enforcement body explicitly identified	Yes. The enforcement body is the Central Anticorruption Bureau. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Some agency assigned responsibility for verifying submission	Yes. The Central Anticorruption Bureau is responsible for submission verification and content verification. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Some agency assigned responsibility for verifying accuracy	Yes. The Central Anticorruption Bureau is responsible for submission verification and content verification. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Public access to declarations
Public availability	No. Information contained in asset declarations is confidential and is not publicly available. The information can be disclosed either upon consent of a submitting person, or in exceptional cases which are not specified in law. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Timing of information release specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Location(s) of access specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Cost of access specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Ministers
Disclosure items
Spouses and children included in disclosure	Yes. Real estate property owned individually or jointly with the spouse (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 68)
Income and Assets
Real estate	Yes. Real estate property owned individually or jointly with the spouse (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 68)
Movable assets	Yes. Movable property in excess of PLN 10,000 (2,300 euros) (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 69)
Cash	Yes. Cash accumulated in the national or in a foreign currency (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 68)
Loans and Debts	Yes. Financial liabilities in excess of PLN 10,000 (2,300 euros) (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 69)
Income from outside employment/assets	Yes. Other additional information on financial activities and the possible income derived thereof (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 70)
Incompatibilities
Gifts received as a public official	Yes. The declaration of interests/benefits should include information on the facts relating to the material support of the public activity conducted by the person submitting the information; information on donations received from domestic or foreign entities if the value of such a donation exceeds 50% of the lowest wage applicable for employees, as mentioned in Art. 6 item 3; information on domestic or foreign travel relating to the public function held, if the cost of such travel was not covered by the person submitting the information, their spouse, the institution employing them or a political party, association or foundation of which they are a member; other benefits obtained having a value exceeding that as indicated in point 3 not relating to the posts held or the work performed as described in point 1; (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Private firm ownership and/or stock holdings	No. Membership of the declarant in the management / supervision / audit body of a commercial entity and membership in a foundation pursuing a business activity, the income derived from these activities, stocks and shares owned in commercial entities and the income derived thereof, shareholdings in commercial entities in excess of 10% of the total shareholding, Ministers must disclose shares, stocks, participation in companies, and income derived from such holding (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 69 Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Ownership of state-owned enterprises (SOEs)	No. Securities, acquisitions of property sold by the State or another public entity No distinction exists in Polish law between private and state-owned companies for disclosure purposes. Any shares or participation, including in SOEs, must be declared (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 69 Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	No. Membership of the declarant in the management / supervision / audit body of a commercial entity and membership in a foundation pursuing a business activity, the income derived from these activities, stocks and shares owned in commercial entities and the income derived thereof, shareholdings in commercial entities in excess of 10% of the total shareholding, The declaration must include functions performed in commercial companies or cooperatives, including management or supervisory roles (GRECO FIFTH EVALUATION ROUND 2018 - Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies EVALUATION REPORT at pag 22 par. 69 Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	Yes. The declaration of interests/benefits should include information on all posts and tasks performed both in public administration as well as in private institutions, for which remuneration is collected including self-employment. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Absent from legal framework. Ministers are subject to dual regimes: Asset declarations (Article 10) → upon entry, annually, exit Register of Benefits (Article 12) → continuous + updates (Article 10 and 12, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Filing required upon leaving office	Yes. Absent from legal framework. Ministers are subject to dual regimes: Asset declarations (Article 10) → upon entry, annually, exit Register of Benefits (Article 12) → continuous + updates (Article 10 and 12, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Filing required annually	Yes. Absent from legal framework. Ministers are subject to dual regimes: Asset declarations (Article 10) → upon entry, annually, exit Register of Benefits (Article 12) → continuous + updates (Article 10 and 12, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Changes to the information submitted with the Registry of Benefits must be notified within 30 days of their occurrence. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Absent from legal framework. Sanctions exist but apply through: general disciplinary framework and criminal liability for false declarations (Article 13 and 14, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Absent from legal framework. Sanctions exist but apply through: general disciplinary framework and criminal liability for false declarations (Article 13 and 14, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Monitoring and Oversight
Depository body explicitly identified	Yes. Members of the Cabinet must submit a declaration for the Registry of Benefits with the State Elections Committee. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Enforcement body explicitly identified	No. Absent from legal framework.
Some agency assigned responsibility for verifying submission	No. Absent from legal framework.
Some agency assigned responsibility for verifying accuracy	No. Absent from legal framework.
Public access to declarations
Public availability	Yes. The Registry of Benefits is open to the public and published once a year. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Timing of information release specified	Yes. The State Elections Committee, in a separate publication, makes public the information contained therein. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Location(s) of access specified	Yes. The Register is maintained by the State Elections Committee. (Article 12 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Cost of access specified	No. Absent from legal framework.
Members of Parliament
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework. Although not framed as a general rule, joint marital property (community property) is included in declarations, meaning spouse assets are effectively covered (Article 35, Act on performance of mandate (1996))
Income and Assets
Real estate	Yes. The declaration should include information on cash resources, real estate, participation in civil partnerships or in commercial partnerships, stocks and shares in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their associations or a municipal legal person, that had been sold by tendering, as well as on conducted commercial activity and posts held in commercial companies (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Movable assets	Yes. The declaration should include movable assets worth more than PLN 10,000 (2,300 EUR) (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Cash	Yes. The declaration should include information on cash resources, real estate, participation in civil partnerships or in commercial partnerships, stocks and shares in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their associations or a municipal legal person, that had been sold by tendering, as well as on conducted commercial activity and posts held in commercial companies (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Loans and Debts	Yes. The declaration should include cash debts worth more than PLN 10,000 (2,300 EUR), including drawn credits and loans and the terms under which they have been granted (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Income from outside employment/assets	Yes. The declaration should include income acquired from employment or other wage-earning activity, with indication of the amounts acquired from each type (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Incompatibilities
Gifts received as a public official	Yes. The declaration of interests/benefits should include information on facts of financial support for public activity conducted by the reporting person; donation received from domestic or foreign entities, if its value exceeds 50% of the lowest remuneration of employees for work, in effect in December of the preceding year, specified by the Minister of Labor and Social Policy pursuant to the Labor Code; travel at home or abroad not associated with the performed public function, if its cost has not been covered by the reporting person or his spouse or institutions employing them or political parties, associations or foundations they are members of; other acquired interests worth more than indicated in subpara. 3, not associated with holding posts or performing activities or professional work, referred to in subpara. 1; (Article 35a of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Private firm ownership and/or stock holdings	Yes. The declaration should include information on cash resources, real estate, participation in civil partnerships or in commercial partnerships, stocks and shares in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their associations or a municipal legal person, that had been sold by tendering, as well as on conducted commercial activity and posts held in commercial companies (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Ownership of state-owned enterprises (SOEs)	Yes. The declaration should include information on cash resources, real estate, participation in civil partnerships or in commercial partnerships, stocks and shares in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their associations or a municipal legal person, that had been sold by tendering, as well as on conducted commercial activity and posts held in commercial companies (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. The declaration should include information on cash resources, real estate, participation in civil partnerships or in commercial partnerships, stocks and shares in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their associations or a municipal legal person, that had been sold by tendering, as well as on conducted commercial activity and posts held in commercial companies (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	Yes. The declaration of interests/benefits should include information on all posts and activities performed in public administration as well as in private institutions, from which remuneration is collected, and professional work performed on one’s own account. (Article 35a of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Filing required upon leaving office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Filing required annually	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. MPs are obliged to inform the Speaker of Sejm, or Speaker of the Senate, about his intention to take additional activities, with the exception of activities subject to copyright and related laws. All data filed with the Registry of Benefits that is subject to change should be reported to the Registry no later than 30 days from the date of their occurrence. (Article 33, 35a of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. In the case of late filing, MPs are not paid their salary. (Article 35(8) of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Providing false information or nondislosing information in the declaration of benefits results in criminal liability under Article 233 of the Penal Code, specifically imprisonment for up to 3 years. For breaching the rules of ethics, Deputies shall be liable according to the internal procedural rules of Sejm. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018) Article 233 of the Penal Code (1997, last amended in 2020) Article 8 of the Principles of Conduct for Deputies (1998))
Monitoring and Oversight
Depository body explicitly identified	Yes. The depository bodies are Speaker of Sejm for deputies, and Speaker of Senate for senators for property declarations and declarations of interest for the Registry of Benefits. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Enforcement body explicitly identified	Yes. Speaker of Sejm for deputies, and Speaker of Senate for senators. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Some agency assigned responsibility for verifying submission	Yes. Speaker of the Sejm for deputies and Speaker of the Senate are responsible for submission verification. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Some agency assigned responsibility for verifying accuracy	Yes. Central Anticorruption Bureau is responsible for content verification. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Public access to declarations
Public availability	Yes. Information contained in asset declarations and Registry of Benefits is open to the public. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Timing of information release specified	Yes. Once a year, Speakers of the Sejm and Senate shall make the data included in it publicly known, in a separate publication. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Location(s) of access specified	Yes. Information on deputies shall be maintained by the Speaker of the Sejm and on senators by the Speaker of the Senate. (Article 35 of the Act on the discharge of their duties by Sejm deputies and senators (1996, last amended in 2018))
Cost of access specified	No. Absent from legal framework.
Civil servants
Disclosure items
Spouses and children included in disclosure	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended in 2019))
Income and Assets
Real estate	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Movable assets	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Cash	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Loans and Debts	Yes. Absent from legal framework. Loans and liabilities are not explicitly listed as a separate category in Article 10, but the obligation to disclose “property status” (majątek) is interpreted broadly in Polish jurisprudence and practice to include financial liabilities. This is consistent with how asset declarations are structured in practice. (Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Income from outside employment/assets	Yes. Absent from legal framework. obligation to disclose economic activity and positions (Article 10, Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, as amended))
Incompatibilities
Gifts received as a public official	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Ownership of state-owned enterprises (SOEs)	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. The declaration should include information on any money, property or shares in commercial companies held as well as property acquired by that person or their spouse from the State Treasury, other state legal person, commune or inter-commune association which was sold by tender. The declaration should also include data concerning the conduction of commercial activity and the fulfilling of a function in companies or cooperatives. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Filing required upon leaving office	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Filing required annually	Yes. A property declaration is filed before taking office, annually thereafter, and on the day of discharge from office. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework.
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Non- filing of the declaration results in disciplinary sanctions. (Article 13 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. If the person obliged to submit the declaration (asset declaration and declaration about the activity of the spouse), submits false information, he/she will be subject to imprisonment up to 5 years. In cases of lesser importance a person committing the act shall be liable to a fine, penalty of restricted liberty or deprivation of liberty of up to one year. (Article 14 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The depository body is the First President of the Supreme Court. (Article 10 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Enforcement body explicitly identified	Yes. The enforcement body is the Central Anticorruption Bureau. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Some agency assigned responsibility for verifying submission	Yes. The Central Anticorruption Bureau is responsible for submission verification and content verification. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Some agency assigned responsibility for verifying accuracy	Yes. The Central Anticorruption Bureau is responsible for submission verification and content verification. (Article 2 of the Central Anti-Corruption Bureau Act (2006, last amended 2020))
Public access to declarations
Public availability	No. Information contained in asset declarations is confidential and is not publicly available. The information can be disclosed either upon consent of a submitting person, or in exceptional cases which are not specified in law. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Timing of information release specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Location(s) of access specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))
Cost of access specified	No. Information contained in asset declarations is confidential and is not publicly available. (Article 10.3 of the Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions (1997, last amended 2019))

Legislation

Act on the Discharge of Their Duties by Sejm Deputies and Senators of 1996_POL (Polish)	pdf
Central Anti-Corruption Bureau Act of 2006_POL (Polish)	pdf
Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 1997_POL (Polish)	pdf
Principles of Deputies' Ethics of 1998_POL (Polish)	pdf
Penal Code of 1997_POL (Polish)	pdf

*Last update: 2017

Conflict of Interest

The Polish Law on limitation of economic activity by persons performing public functions (1997, last amended in 2016) sets down that the Head of State, Ministers, Members of Parliament, and Civil Servants may not hold managerial or supervisory functions, hold over 10% of shares in public or private companies, or hold government contracts. Additionally, MPs may not accept gifts and the Principles of Deputies' Ethics (1998) prevents them from participating in decision-making where they have a private interest. Beyond this, the Guidelines for compliance with the rules of the civil service and on the ethics body civil service (2011) and the Act on Employees of State Offices (1982, last amended in 2016) include a general clause for Civil Servants to alleviate all conflicts of interests. They are also not allowed to accept gifts. Polish law makes no regulations as to post-employment of public officials.

In case of violations the Constitution (1997, last amended 2009) foresees a loss of mandate for Ministers and MPs. This also applies to the Head of State should the National Assembly vote in favor of removal with a two-thirds-majority. If Civil Servants violate restrictions on conflicts of interests, they face penalties ranging from reprimand to a removal from office. All the while, no monitoring or enforcement bodies exist for the Head of State and Ministers. The Rules and Deputies’ Affairs Committee functions as enforcement body for MPs. The Disciplinary Commission is tasked with this function for Civil Servants.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Restrictions	20	42	42	48	35	52
Sanctions	25	8	8	8	8	75
Monitoring and Oversight	25	25	25	25	25	12
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	0	3	3	3	3	39
Ministers	38	23	23	23	0	39
Members of Parliament	7	20	20	27	17	70
Civil servants	49	54	54	54	71	39

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.
Accepting gifts	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. The President of the Republic, in the period of holding their position or performing the functions referred to in those provisions, may not hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies. (Act on the Remuneration of Persons Holding Managerial Positions in the State (as of 2020), Art. 2 (1) Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 (5) and 10 (1))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. The President of the Republic, in the period of holding their position or performing the functions referred to in those provisions, may not be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1 and 4 (2))
Board member, advisor, or company officer of private firm	Yes. The President of the Republic, in the period of holding their position or performing the functions referred to in those provisions, may not: 1) be a member of management boards, supervisory boards or audit committees of commercial law companies or liquidators of such companies, as well as be shareholder's proxies referred to in Art. 11 (2) of the Act of 30 August 1996 on Commercialisation and Certain Rights of Employees (Journal of Laws of 2019, item 2181); 1a) be the receiver or deputy receiver in bankruptcy proceedings or supervisors or administrators in restructuring proceedings; 2) be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest; 3) be a member of management boards, supervisory boards or audit committees of cooperatives, except for supervisory boards of housing cooperatives; 4) be a member of management boards of foundations conducting economic activity; 5) hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies; 6) conduct business activity on one's own account or jointly with other persons, as well as manage such activity or be a representative or proxy in the conduct of such activity; this does not apply to manufacturing activity in agriculture in the field of plant and animal production, in the form and scope of a family farm, as well as performing the function of a member of the management board on the basis of a contract for the provision of management services referred to in Article 5(1)(1) of the Act of 9 June 2016 on the principles of shaping the remuneration of persons managing certain companies (Journal of Laws of 2019, item 1885). (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 and 26)
Post-employment	Yes. The President of the Republic may not be employed or perform other activities for the entrepreneur within one year of ceasing to hold a position or function, if they participated in the issuance of decisions in individual cases concerning this entrepreneur; this does not apply to administrative decisions on the assessment of local taxes and fees on the basis of separate regulations, with the exception of decisions regarding reliefs and exemptions in these taxes or fees. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Art. 7)
Simultaneously holding policy-making position and policy-executing position	Yes. The President of the Republic shall hold no other offices nor discharge any public functions, with the exception of those connected with the duties of his office. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 132)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	No. The most relevant provision stipulates that the President of the Republic is obliged to submit a declaration on the economic activity conducted by their spouse - before appointment to the post, as well as on the intention to undertake such activity or change its nature - during the performance of the function. Such declaration shall be submitted to the First President of the Supreme Court. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Art. 8 (1) (3))
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Generally, the Constitution establishes that the President of the Republic may be held accountable before the Tribunal of State for an infringement of the Constitution or statute, or for commission of an offence. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 145)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework.
Ministers
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.
Accepting gifts	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. Members of the Council of Ministers (i.e. Ministers), in the period of holding their position or performing the functions referred to in those provisions, may not hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 147 (1) Act on the Remuneration of Persons Holding Managerial Positions in the State (as of 2020), Art. 2 (2) Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 (5) and 10 (1))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. A member of the Council of Ministers shall not perform any activity inconsistent with his public duties. Ministers, in the period of holding their position or performing the functions referred to in those provisions, may not be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 150 Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1 and 4 (2))
Board member, advisor, or company officer of private firm	Yes. A member of the Council of Ministers shall not perform any activity inconsistent with his public duties. A Minister, in the period of holding their position or performing the functions referred to in those provisions, may not: 1) be a member of management boards, supervisory boards or audit committees of commercial law companies or liquidators of such companies, as well as be shareholder's proxies referred to in Art. 11 (2) of the Act of 30 August 1996 on Commercialisation and Certain Rights of Employees (Journal of Laws of 2019, item 2181); 1a) be the receiver or deputy receiver in bankruptcy proceedings or supervisors or administrators in restructuring proceedings; 2) be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest; 3) be a member of management boards, supervisory boards or audit committees of cooperatives, except for supervisory boards of housing cooperatives; 4) be a member of management boards of foundations conducting economic activity; 5) hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies; 6) conduct business activity on one's own account or jointly with other persons, as well as manage such activity or be a representative or proxy in the conduct of such activity; this does not apply to manufacturing activity in agriculture in the field of plant and animal production, in the form and scope of a family farm, as well as performing the function of a member of the management board on the basis of a contract for the provision of management services referred to in Article 5(1)(1) of the Act of 9 June 2016 on the principles of shaping the remuneration of persons managing certain companies (Journal of Laws of 2019, item 1885). (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 150 Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 and 26)
Post-employment	Yes. A Member of the Council of Ministers may not be employed or perform other activities for the entrepreneur within one year of ceasing to hold a position or function, if they participated in the issuance of decisions in individual cases concerning this entrepreneur; this does not apply to administrative decisions on the assessment of local taxes and fees on the basis of separate regulations, with the exception of decisions regarding reliefs and exemptions in these taxes or fees. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Art. 7)
Simultaneously holding policy-making position and policy-executing position	Yes. A member of the Council of Ministers shall not perform any activity inconsistent with his public duties. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 150)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework.
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework.
Members of Parliament
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.
Accepting gifts	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. Members of the Sejm or of the Senate (Deputies and Senators), in the period of holding their position or performing the functions referred to in those provisions, may not hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies. Additionally, Members and Senators must submit a declaration of their financial situation. The declaration of their financial situation must relate to their separate property and to their matrimonial property. The declaration contains, in particular, information on monetary resources, immovable property, participation in civil law partnerships or partnerships, shares and stocks in commercial companies, on property acquired from the State Treasury, another state legal person, local government units, their unions or a municipal legal person, which was subject to sale by way of a tender, as well as on business activities conducted and positions held in commercial companies (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 95 Act on the Remuneration of Persons Holding Managerial Positions in the State (as of 2020), Art. 2 (2) Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 (5) and 10 (1) Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (as of 2020), Art. 35 (1))
Ownership of state-owned enterprises (SOEs)	Yes. Deputies and senators may not hold a block of more than 10% of the shares in commercial law companies with the participation of state or municipal legal persons or undertakings in which such persons participate. Any shares in excess of that holding must be disposed of by the Member or Senator before the first sitting of the Sejm or Senate and, if they are not disposed of, they shall not exercise their rights (voting rights, dividend rights, rights to the distribution of assets and pre-emptive rights) for the duration of their mandate and for two years thereafter. (Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (as of 2020), Art. 34 (4))
Holding government contracts	Yes. Members of Parliament and Senators may not carry on a business activity for their own account or jointly with others involving the use of state or municipal property, or manage such an activity, or be a representative or agent in the conduct of such an activity. Members of Parliament and Senators may not be members of management or supervisory or auditing bodies or commercial proxies of undertakings involving state or municipal legal persons or undertakings in which such persons participate. The election or appointment of a Member or Senator to such authorities shall be null and void as a matter of law. If the election or appointment referred to in paragraph 2 took place before the Member began exercising his or her mandate, the Member or Senator shall be required to relinquish that office or function. If the office or function is not relinquished, the Member or Senator shall forfeit that office or function ipso jure three months after taking the oath referred to in Article 2. (Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (as of 2020), Art. 34 (1) (2) (3))
Board member, advisor, or company officer of private firm	Yes. A Member of Parliament in the period of holding their position or performing the functions referred to in those provisions, may not: 1) be a member of management boards, supervisory boards or audit committees of commercial law companies or liquidators of such companies, as well as be shareholder's proxies referred to in Art. 11 (2) of the Act of 30 August 1996 on Commercialisation and Certain Rights of Employees (Journal of Laws of 2019, item 2181); 1a) be the receiver or deputy receiver in bankruptcy proceedings or supervisors or administrators in restructuring proceedings; 2) be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest; 3) be a member of management boards, supervisory boards or audit committees of cooperatives, except for supervisory boards of housing cooperatives; 4) be a member of management boards of foundations conducting economic activity; 5) hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies; 6) conduct business activity on one's own account or jointly with other persons, as well as manage such activity or be a representative or proxy in the conduct of such activity; this does not apply to manufacturing activity in agriculture in the field of plant and animal production, in the form and scope of a family farm, as well as performing the function of a member of the management board on the basis of a contract for the provision of management services referred to in Article 5(1)(1) of the Act of 9 June 2016 on the principles of shaping the remuneration of persons managing certain companies (Journal of Laws of 2019, item 1885). (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 1, 4 and 26 Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (as of 2020), Art. 33 (1))
Post-employment	Yes. A Member of Parliament may not be employed or perform other activities for the entrepreneur within one year of ceasing to hold a position or function, if they participated in the issuance of decisions in individual cases concerning this entrepreneur; this does not apply to administrative decisions on the assessment of local taxes and fees on the basis of separate regulations, with the exception of decisions regarding reliefs and exemptions in these taxes or fees. Additionally, in case the Deputy or the Senator did not dispose of company shares within the appropriate timeframe, they shall not exercise their rights (voting rights, dividend rights, rights to the distribution of assets and pre-emptive rights) for the duration of their mandate and for two years thereafter. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arst. 7 and 34 (4))
Simultaneously holding policy-making position and policy-executing position	Yes. The mandate of a Deputy shall not be held jointly with the office of the President of the National Bank of Poland, the President of the Supreme Chamber of Control, the Commissioner for Citizens' Rights, the Commissioner for Children's Rights or their deputies, a member of the Council for Monetary Policy, a member of the National Council of Radio Broadcasting and Television, ambassador, or with employment in the Chancellery of the Sejm, Chancellery of the Senate, Chancellery of the President of the Republic, or with employment in government administration. Additionally, while exercising their mandate, deputies and senators may not perform work on the basis of an employment relationship: in the Chancellery of the Sejm, in the Chancellery of the Senate, in the Chancellery of the President of the Republic of Poland, in the Chancellery of the Constitutional Tribunal, in the Legal Service Office of the Constitutional Tribunal, in the Supreme Chamber of Control, in the Office of the Ombudsman, in the Office of the Ombudsman for Children, in the Office of the National Broadcasting Council in the National Election Office, in the State Labour Inspectorate, in government administration and local self-government administration - except for elected employment - and may not perform work as a judge, court assessor and prosecutor, administrative employee of a court and prosecutor's office, and may not perform professional military service. (Constitution of the Republic of Poland of 1997 (as of 2020), Art. 103 (1) Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (as of 2020), Art. 30 (1))
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework.
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. The Presidium of the Sejm, by resolution adopted after considering the opinion of the Committee on Rules of Procedure, Parliamentary Affairs and Immunity, may, for breach or non-performance of the obligations set forth in Articles 33 to 35 of the Act on the Exercise of the Mandate of Members of Parliament and Senators: 1) draw the Member's attention; 2) give the Member a warning; 3) give the Member a reprimand. (Principles of Deputies' Ethics of 1998 (as of 2020), Art. 8 Rules of Procedure of the Sejm of 1992 (as of 2020), Art. 21)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	Yes. Presidium of the Sejm. (Rules of Procedure of the Sejm of 1992 (as of 2020), Art. 21)
Civil servants
Restrictions
General restriction on conflict of interest	Yes. The principle of impartiality is expressed in particular in preventing suspicions of a conflict between public and private interests and in not taking up any work or activities that conflict with official duties. (Guidelines for Compliance with the Principles of Civil Service of 2011 (as of 2020), § 18)
Accepting gifts	No. Absent from legal framework.
Private firm ownership and/or stock holdings	Yes. Employees of state offices, including members of the civil service corps holding managerial positions, in the period of holding their position or performing their functions, may not hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 2 (1), 4 (5) and 10 (1))
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. Observing the principle of selflessness, a member of the civil service corps, in particular, resigns from additional employment or gainful occupation, if further performance of additional employment or gainful occupation may have a negative impact on matters carried out as part of official duties. Additionally, civil servants, in the period of holding their position or performing their functions, may not be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest. (Guidelines for Compliance with the Principles of Civil Service of 2011 (as of 2020), § 4 Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 2 (1) and 4 (2))
Board member, advisor, or company officer of private firm	Yes. A civil servant, in the period of holding their position or performing their functions, may not: 1) be a member of management boards, supervisory boards or audit committees of commercial law companies or liquidators of such companies, as well as be shareholder's proxies referred to in Art. 11 (2) of the Act of 30 August 1996 on Commercialisation and Certain Rights of Employees (Journal of Laws of 2019, item 2181); 1a) be the receiver or deputy receiver in bankruptcy proceedings or supervisors or administrators in restructuring proceedings; 2) be employed or perform other activities in commercial law companies which could give rise to suspicion of their partiality or interest; 3) be a member of management boards, supervisory boards or audit committees of cooperatives, except for supervisory boards of housing cooperatives; 4) be a member of management boards of foundations conducting economic activity; 5) hold in commercial law companies more than 10% of shares or shares representing more than 10% of the share capital - in each of these companies; 6) conduct business activity on one's own account or jointly with other persons, as well as manage such activity or be a representative or proxy in the conduct of such activity; this does not apply to manufacturing activity in agriculture in the field of plant and animal production, in the form and scope of a family farm, as well as performing the function of a member of the management board on the basis of a contract for the provision of management services referred to in Article 5(1)(1) of the Act of 9 June 2016 on the principles of shaping the remuneration of persons managing certain companies (Journal of Laws of 2019, item 1885). (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019 (as of 2020), Arts. 2 (1), 4 and 26)
Post-employment	Yes. Public officials may not be employed or perform other activities for the entrepreneur within one year of ceasing to hold a position or function, if they participated in the issuance of decisions in individual cases concerning this entrepreneur; this does not apply to administrative decisions on the assessment of local taxes and fees on the basis of separate regulations, with the exception of decisions regarding reliefs and exemptions in these taxes or fees. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Art. 7)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework.
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Whoever, being obliged to submit the statement referred to in Article 8 (1) or Article 10 (1), discloses untruth therein, shall be subject to the penalty of deprivation of liberty for up to 5 years. In the event of a lesser gravity, the perpetrator of the act referred to in section 1 shall be subject to a fine, the penalty of limitation of liberty or deprivation of liberty for up to one year. Whoever employs persons referred to in Art. 1 and in Art. 2 items 1-3 and 6-6b, contrary to the conditions specified in Art. 7, shall be subject to the penalty of arrest or a fine. (Act on Restrictions on Conduct of Business Activities by Persons Performing Public Functions of 2019, Arts. 14 and 15)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework.

Legislation

Constitution of the Republic of Poland of 1997 (Polish)	pdf
Act on Restricting the Conduct of Economic Activity by Persons Discharging Public Functions of 2019 (Polish)	pdf
Act on the Exercise of the Mandate of a Deputy and Senator of 1982 (Polish)	pdf
Principles of Deputies' Ethics of 1998 (Polish)	pdf
Rules of Procedure of the Sejm of 1992 (Polish)	pdf
Guidelines for Compliance with the Principles of Civil Service of 2011 (Polish)	pdf

*Last update: 2017

Freedom of Information

Poland's Constitution (1997) provides citizens with a fundamental right to access government information, while the Law on Access to Public Information (2001, amended 2016) lays out implementing measures. The FOI law applies to the executive, legislative, and judicial branches, as well as public bodies that perform public functions or hold dominant positions in the market.

Specific exemptions to disclosure are outlined in the aforementioned FOI law, Classified Information Protection Act (1999), and the Law on Data Protection (1997). No public interest test exists whereby exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

Appeals may be filed with public authorities and with the courts. There is no appeals process through an independent non-judicial mechanism, such as an information commissioner.

Fines and criminal sanctions may be imposed by the public prosecutor for violations of FOI provisions, but there are no oversight bodies tasked with managing implementation.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Scope and Coverage	93	93	93	93	93	69
Information access and release	71	71	71	71	71	42
Exceptions and Overrides	67	83	83	83	83	33
Sanctions for non-compliance	33	33	33	33	33	33
Monitoring and Oversight	0	17	17	17	17	0

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope and Coverage
Scope of disclosure
Principle of maximum disclosure, i.e., presumption in favor of disclosure	Yes. Any information about public affairs is public information within the meaning of the Act and subject to the availability of and reuse the principles and procedures set forth in this Act. (Article 1 of the Law on Access to Public Information, 2001, last amended 2020)
Proactive disclosure is specified	Yes. Making public information available takes place by means of announcing public information, including official documents, in the Public Information Bulletin. (Articles 7 and 8 of the Law on Access to Public Information, 2001, last amended 2020)
Coverage of public and private sectors
Executive branch	Yes. 1. To make the public information available is the obligation of the public authorities as well as other entities performing public functions, in particular: 1) bodies of public authority, 2) bodies of economic and professional local authorities, 3) entities representing the State Treasury in accordance with the separate provisions, 4) entities representing state legal persons or legal persons of local authorities and entities representing other state organisational units or organisation units of local authority, 5) entities representing other persons or organisational units, which perform public functions or dispose of public property as well as legal persons, in which the State Treasury, units of local authority or economic or professional local authority hold dominant position in the understanding of the provisions of competition and consumer protection. (Article 4 of the Law on Access to Public Information, 2001, last amended 2020)
Legislative branch	Yes. 1. To make the public information available is the obligation of the public authorities as well as other entities performing public functions, in particular: 1) bodies of public authority (Article 4 of the Law on Access to Public Information, 2001, last amended 2020)
Judicial branch	Yes. 1. To make the public information available is the obligation of the public authorities as well as other entities performing public functions, in particular: 1) bodies of public authority (Article 4 of the Law on Access to Public Information, 2001, last amended 2020)
Other public bodies	Yes. 1. To make the public information available is the obligation of the public authorities as well as other entities performing public functions, in particular: 1) bodies of public authority, 2) bodies of economic and professional local authorities, 3) entities representing the State Treasury in accordance with the separate provisions, 4) entities representing state legal persons or legal persons of local authorities and entities representing other state organisational units or organisation units of local authority, 5) entities representing other persons or organisational units, which perform public functions or dispose of public property as well as legal persons, in which the State Treasury, units of local authority or economic or professional local authority hold dominant position in the understanding of the provisions of competition and consumer protection. (Article 4 of the Law on Access to Public Information, 2001, last amended 2020)
Private sector	No. Absent from legal framework.
Access to specific documents (subject to reactive and/or proactive disclosure)
Draft legal instruments	Yes. Explicitly permit access to draft legal instruments. Legal acts are published on the websites of the bodies preparing draft legal instruments and on the Sejm’s website. (Articles 6 and 8 of the Law on Access to Public Information, 2001, last amended 2020)
Enacted legal instruments	Yes. Access to enacted legal instruments is explicitly permitted. (Article 6 of the Law on Access to Public Information, 2001, last amended 2020)
Annual budgets	Yes. Budgetary information is required to be made public. Public disclosure of the annual budget is required to be made public. (Article 6 of the Law on Access to Public Information, 2001, last amended 2020 Articles 33 and 34 of the Law on Public Finances, 2009, amended 2019)
Annual chart of accounts (actual expenditures)	Yes. Information regarding expenditures are required to be made public. Public disclosure of the annual budget is required to be made public. (Article 6 of the Law on Access to Public Information, 2001, last amended 2020 Articles 33 and 34 of the Law on Public Finances, 2009, amended 2019)
Annual reports of public entities and programs	Yes. Information regarding annual reports and programs is required to be made public. (Article 6 of the Law on Access to Public Information, 2001, last amended 2020)
Information access and release
Procedural access
Universal access (agencies, citizens and non-citizens)	Yes. 1. Each person is entitled, with the stipulation of Article 5, to the right of access to public information, hereinafter referred to as “the right to public information”. (Article 2 of the Law on Access to Public Information, 2001, last amended 2020)
Type of request is specified (written, electronic, oral)	Yes. Written requests can be made to obtain information not already made available via the Public Information Bulletin. Oral requests are allowed where the information requested can “be immediately made available.” (Article 10 of the Law on Access to Public Information, 2001, last amended 2020)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.)	No. Absent from legal framework.
Cost of access is specified (free, request fees, photocopying costs, other administrative costs)	Yes. While access to public information is generally free the requested government body may oblige payment covering the cost of making the information available. Fees can be mandated in specified cases and after notifying the petitioner of the necessity of payment. (Articles 7 & 15 of the Law on Access to Public Information, 2001, last amended 2020)
Deadlines for release of information
20-day response deadline	Yes. Information requested by petition must be provided within 14 days. (Article 13 of the Law on Access to Public Information, 2001, last amended 2020)
Agency granted right to extend response time	Yes. If the requested government body cannot provide the information within 14 days, it may take up to two-months to do so, provided that it gives a reason for the delay. (Article 13 of the Law on Access to Public Information, 2001, last amended 2020)
Maximum total response time of no more than 40 days	No. If the requested government body cannot provide the information within 14 days, it may take up to two-months to do so, provided that it gives a reason for the delay. (Article 13 of the Law on Access to Public Information, 2001, last amended 2020)
Exceptions and Overrides
Exemptions to disclosure
Existence of secrecy/states secrets law	Yes. Classified Information Protection Act, 1999 (Classified Information Protection Act, 1999, amended 2019)
Existence of personal privacy/data law	Yes. Personal Data Protection Act, 2018 (Personal Data Protection Act, 2019)
Specific exemptions to disclosure	Yes. The Law provides for a number of exceptions. Such exceptions include private data, business secrets, confidential information, and other statutorily protected secrets. These and other exceptions are further informed by provisions that address topics such as personal data and information that is categorized as “classified” according to certain regulations. (Article 5 of the Law on Access to Public Information, 2001, last amended 2020 Articles 1 and 6 of Personal Data Protection Act, 2019 Articles 20 and 21 of the Classified Information Protection Act, 1999, amended 2019)
Public Interest test: Specified exemptions to disclosure may be overridden (dismissed ex ante) in cases where disclosure of information benefits the public interest. (Also includes Balancing test: Where the public interest in maintaining the exemption outweighs the public interest in the disclosure of the information, then the information can be withheld. If the public interest in disclosing the information is equal to or greater than the public interest in maintaining the exemption, then the information must be disclosed)	No. Absent from legal framework.
Harm test: Specified exemptions to disclosure should apply only where there is a risk of substantial harm to the protected interest (i.e., exemptions are not absolute)	No. Absent from legal framework.
Appeals
Appeals allowed within public entities	Yes. The Code of Administrative Proceedings provides an administrative appeals mechanism for decisions denying access to information. (Article 16 of the Law on Access to Public Information, 2001, last amended 2020 Articles 127-140 of the Code of Administrative Proceedings, 1960, amended 2019)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	No. Absent from legal framework.
Judicial appeals mechanism	Yes. A petitioner can always seek redress – either in court or by administrative proceeding. Judicial review of decisions related to access to information where a decision of non-disclosure is based on the protection of personal data, the right to privacy, or a secret that is not a “state secret” or something similar. (Articles 21 and 22 of the Law on Access to Public Information, 2001, last amended 2020)
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	No. Absent from legal framework.
Fines are specified for violations of disclosure requirements	Yes. Fines are legislated where information obligated to be disclosed is not made available. This sanction is of penal character, and the fine shall be calculated in the amount of 10 times the average monthly salary. (Article 23 of the Law on Access to Public Information, 2001, last amended 2020 Article 154(6) of the Law on Proceedings in Administrative Courts, 2002, amended 2020)
Criminal sanctions are specified for violations of disclosure requirements	Yes. Criminal sanctions are up to one year in prison where information obligated to be disclosed is not made available. (Article 23 of the Law on Access to Public Information, 2001, last amended 2020 )
Monitoring and Oversight
Information officers must be appointed in public agencies	No. Absent from legal framework.
Public body that is responsible for applying sanctions	No. Absent from legal framework.
Public body that is responsible for public outreach (raising public awareness)	No. Absent from legal framework.
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	No. Absent from legal framework.
Ombudsman involvement in implementation is specified by law	No. Absent from legal framework.

Legislation

Constitution of the Republic of Poland of 1997_POL (Polish)	pdf
Law on Access to Public Information of 2001_POL (Polish)	pdf
Law on Public Finances of 2009_POL (Polish)	pdf
Law on Protection of Classified Information of 2010_POL (Polish)	pdf
Law on the Protection of Personal Data of 2018_POL (Polish)	pdf
Code of Administrative Proceedings of 1960_POL (Polish)	pdf
Law on Proceedings in Administrative Courts of 2002_POL (Polish)	pdf

*Last update: 2017

Public Procurement

The Polish public procurement system is regulated primarily by the Public Procurement Law. The public procurement body is the Public Procurement Office which is an independent organization.

The lowest minimum thresholds for conducting a public procurement tender are:

▪ EUR 30000 for goods, works and services

The minimum number of bidders is 5 for restricted procedures and 3 for negotiated procedures and competitive dialogue. The minimum submission period is 35 days for open procedures, 30 days for restricted procedures and negotiated procedures from dispatch date. If the tender is below the EU threshold, the period can be shortened to 7 days. The final beneficial owners do not have to be disclosed when placing a bid.

There is no case for preferential treatment. However, there are several options for bid exclusion: economic operators who were included in the preparation of the tender, failing to provide tender deposit in time, providing false information, failing to fulfilling conditions, conviction for bankruptcy, bribery, fraud, gross professional negligence, outstanding tax or social security contributions. Bids can be also excluded because of abnormally low bid prices.

In the bid evaluation phase, there are conflict of interest restrictions on the composition of the evaluation committee. There is also a requirement that some part of the evaluation committee be independent of the contracting authority.

There is a payable fee in case of an arbitration procedure, which is set out in a Presidential Decision, and court decisions are also publicly released.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2015	2016	2017	2020	2024
Scope	88	87	83	96	24
Information availability	25	25	62	88	44
Evaluation	81	81	69	62	88
Open competition	75	75	69	67	61
Institutional arrangements	21	21	21	29	43

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS - SUPPLIES)	PLN 130,000. The minimum contract value above which the PZP is applied is PLN 130,000 from 1 January 2024; EU thresholds apply in accordance with EU Directives 2014/24/EU, 2014/25/EU and 2009/81/EC; for central government authorities the EU goods/services threshold is EUR 143,000 (PLN 616,330); for other contracting authorities EUR 221,000 (PLN 930,960); exchange rate PLN/EUR set at 4.31 for 2024. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1); Notice of the President of UZP (2024 threshold announcement))
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	PLN 130,000. The minimum contract value is PLN 130,000; EU works threshold is EUR 5,538,000 (PLN 23,868,780) from 1 January 2024; above EU threshold, full EU procedures and OJEU publication are required; the PZP applies to all works contracts above PLN 130,000. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1); Notice of the President of UZP (2024 threshold announcement))
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	PLN 130,000. Same structure as goods: de minimis PLN 130,000 from 1 January 2024; EU service thresholds EUR 143,000/EUR 221,000 for central/sub-central authorities from 1 January 2024; light-touch regime for social services from EUR 750,000 = PLN 3,232,500. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1); Notice of the President of UZP (2024 threshold announcement))
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	PLN 130,000. Classical contracting authorities must follow formal national procedures from PLN 130,000; above EU thresholds, full EU procedures and OJEU publication apply. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1))
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES; SECTOR ORDERS)	PLN 1,909,330. Utilities (special sector) entities follow the EU utilities thresholds; from 1 January 2024: EUR 443,000 for supply and service contracts and EUR 5,538,000 for works; PLN equivalents calculated at 4.31 PLN/EUR. (Public Procurement Law of 2019, as amended in 2020, Art. 2(1) and 3(2); Notice of the President of UZP (2024 threshold announcement))
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	PLN 1,909,330. In the defence and security sector, the PZP applies to contracts above EU thresholds; the applicable EU thresholds for defence are set by Directive 2009/81/EC and updated by the UZP President's annual notice; from 1 January 2024, EUR 443,000 = PLN 1,909,330 for goods/services and EUR 5,538,000 for works. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(3); Notice of the President of UZP (2024 threshold announcement))
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS - SUPPLIES)	PLN 130,000. For goods, the de minimis is PLN 130,000; above the EU goods threshold (PLN 616,330 for central government), full EU procedures apply. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1))
What are the minimum application thresholds for the procurement type? (Product type WORKS)	PLN 130,000. For works, the de minimis is PLN 130,000; above the EU works threshold (PLN 23,868,780 from 1 January 2024), full EU procedures and OJEU publication are required. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1))
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	PLN 130,000. Same as goods; light-touch regime for social services from EUR 750,000 = PLN 3,232,500 from 1 January 2024. (Public Procurement Law of 2019, as amended in 2020, Arts. 2(1) and 3(1))
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. The contracting authority shall provide free, full, direct and unlimited online access to the procurement documentation from the date of publication of the contract notice; the text of the contract notice on the publication of which access is given must include: 1) the name and address of the contracting authority; 2) the indication of the website on which the procurement documents directly related to the contract are to be published; 3) a description of the subject matter and 4) the quantification of the basis of the contract. (Public Procurement Law of 2019, as amended in 2020, Arts. 133(1) and 134)
Are any of these documents published online at a central place?	Yes. https://bzp.uzp.gov.pl (Public Procurement Bulletin) and https://ezamowienia.gov.pl/mo-client-board/bzp/list (below EU thresholds); above EU thresholds: OJEU/TED is also required. (Public Procurement Law of 2019, as amended in 2020, Arts. 267 and 269)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system)	Yes. The contracting authority must document the course of the contract award procedure by electronic means; the documentation shall guarantee its integrity and shall include at least: 1) name and address of the contracting authority; 2) an indication of the subject and value of the procurement; 3) declarations of the circumstances justifying the application of the given procedure; 4) information about the contractors and their offers; 5) justification for the discretionary power to not provide information; the records must be kept for at least 4 years from the date of contract award. (Public Procurement Law of 2019, as amended in 2020, Arts. 71–74, 79 and 79)
Are contracts awarded within a framework agreement published (ie mini contracts)?	Yes. A contracting authority awarding a contract within a framework agreement is not required to publish a contract award notice for each individual call-off; however, the contracting entity is required to provide information on the award of a contract within a framework agreement on the cancellation of the framework agreement or on the award of the best tender upon a request from an economic operator who submitted a best tender. (Public Procurement Law of 2019, as amended in 2020, Arts. 255 and 380)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	No. There is no express mention about the mandatory nature of publicly disclosing information on subcontractors; for contracts above EU thresholds, contract award notices may contain subcontractor information; the contracting authority has the discretionary power to not provide information on subcontractors in the course of the award of a public contract; if these draft provisions make reference to subcontractors, such information is bound to be made public. (Public Procurement Law of 2019, as amended in 2020, Arts. 74(1), 79, 134(1) (h), 421(1) (b))
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column.	No percentage or value threshold exists above which subcontractor names must be publicly disclosed. (Public Procurement Law of 2019, as amended in 2020, Arts. 74(1), 79, 134)
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. The subject of the contract may not be described in a way that could hinder fair competition, in particular by indicating trade marks, patents, origins or specific production processes that characterise the products or services provided by a particular economic operator; such description is permitted only where it is not possible to describe the object of the contract in a sufficiently precise and comprehensible manner, and the reference must be accompanied by the words "or equivalent". (Public Procurement Law of 2019, as amended in 2020, Art. 99)
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No. The contracting authority shall prepare and conduct the procurement procedure in the manner ensuring maintenance of fair competition and equal treatment of contractors; there is no formal preferential treatment for SMEs, though the PPO encourages lot-division strategies. (Public Procurement Law of 2019, as amended in 2020, Art. 16)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	No. The contracting authority shall prepare and conduct the procurement procedure in a manner ensuring maintenance of fair competition and equal treatment of contractors, transparency and proportionality; no preference for local or national companies is permitted. (Public Procurement Law of 2019, as amended in 2020, Art. 16)
Is there a specific set of rules for green/sustainable procurement?	Yes. Environmental considerations are taken into account generally and as an integral part of the awarding criteria; the PZP allows contracting authorities to include environmental criteria in technical specifications, selection criteria, award criteria and contract performance clauses; (Public Procurement Law of 2019, as amended in 2020, Arts. 17, 63(1), 68, 96(1), 102(1)(h), 144(2), 433(2) and 400(1)(h))
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. Main grounds for exclusion include: 1) distortion of competition caused by a contractor's involvement in the preparation of a contract award procedure, which shall be eliminated otherwise than by excluding the contractor from participation; 2) criminal convictions for corruption, fraud, organised crime, money laundering or human trafficking; 3) a finding by a court or administrative authority of non-compliance with obligations; 4) bankruptcy; 5) payment of taxes or social security contributions; 6) legal prohibition to tender in public procurement proceedings; 7) grave professional misconduct; 8) declaration of false circumstances. (Public Procurement Law of 2019, as amended in 2020, Arts. 85(2) and 108)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	Yes. The contracting authority rejects a bid after the deadline for submitting bids if: the bid is subject to rejection in Art. 125 sec. 1; or the subject evidence, confirming the lack of grounds for exclusion, confirms the contractor does not comply with the contract; the contracting authority may also reject the bid if it was submitted at a price that is abnormally low in relation to the goods and services. (Public Procurement Law of 2019, as amended in 2020, Arts. 224 and 226)
Is scoring criteria published?	Yes. Procurement documents must contain at least a description of the bid evaluation criteria, the principles of applying those criteria and the bid evaluation methodology; contracting authorities must publish selection information including the total score for each candidate, together with a brief justification; contracting authorities shall also make the overall score for each contractor available on request. (Public Procurement Law of 2019, as amended in 2020, Arts. 134(1), 18 and 240(1))
Are decisions always made by a committee?	No. If the contract value is equal to or exceeds the EU thresholds, the head of the awarding entity must appoint a committee to conduct the contract award procedure; the head of the awarding entity may appoint a tender committee, but it is not mandatory; the tender committee is obligatory only for above-EU-threshold procedures. (Public Procurement Law of 2019, as amended in 2020, Arts. 53 and 54)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. The head of the contracting authority, a member of the tender committee and other persons involved in the preparation of the procedure or the award of the contract shall be excluded from performing these activities if, on their sole responsibility, a conflict of interest occurs when these persons: 1) are interested in a given contractor; 2) are personally related to or employed by a contractor; the procurement committee is subject to specific independence requirements. (Public Procurement Law of 2019, as amended in 2020, Art. 56)
Is some part of evaluation committee mandatorily independent of contracting authority?	Yes. Members of the tender committee are appointed and dismissed by the head of the awarding entity; the committee consists of no fewer than 3 members; members of the committee responsible for the technical and financial evaluation shall be independent of the contracting authority; one of the duties of the members of the tender committee, with the aim of ensuring the efficiency of its proceedings, is the supervision of the members of the tender committee for particular activities related to their own areas of specific responsibilities. (Public Procurement Law of 2019, as amended in 2020, Art. 55)
Are scoring results publicly available?	Yes. Published selection information includes individual scores and the overall score for each candidate; contracting authorities and utilities entities publish on the respective platforms; the overall score for the best tender is obtained on demand. (Public Procurement Law of 2019, as amended in 2020, Arts. 74 and 147)
Does the law specify under which conditions the tender can be cancelled?	Yes. The contracting authority shall cancel the contract award procedure if: 1) no request to participate in the procedure or any tender has been submitted; 2) all submitted requests to participate have been rejected; 3) the price of the best tender exceeds the amount the contracting authority intends to spend on financing the contract, unless the awarding entity may increase this amount to the price of the best tender; 4) in the cases referred to in Art. 248. (Public Procurement Law of 2019, as amended in 2020, Arts. 255–267 and 355)
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. Public Information Bulletin (below EU thresholds) and Publications Office of the European Union (above EU thresholds); national portal https://ezamowienia.gov.pl. (Public Procurement Law of 2019, as amended in 2020, Arts. 61(1), 86, 88(1), 267 and 269)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. Public Information Bulletin (below EU thresholds) and Publications Office of the European Union (above EU thresholds). (Public Procurement Law of 2019, as amended in 2020, Arts. 61(1), 86, 88(1), 267 and 269)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. Public Information Bulletin (below EU thresholds) and Publications Office of the European Union (above EU thresholds); negotiated procedures without prior publication do not require a prior notice but an award notice must be published. (Public Procurement Law of 2019, as amended in 2020, Arts. 61(1), 86, 88(1), 267 and 269)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	5. The minimum number of economic operators invited to submit bids in restricted procedures is 5; the contracting authority may limit the number of participants subject to rejection, provided that the number is sufficient to ensure competition and is not less than 5. (Public Procurement Law of 2019, as amended in 2020, Art. 148(1))
What is the minimum number of bidders for negotiated procedures?	2. In negotiated procedures with prior publication, the contracting authority may limit the number of economic operators invited to submit bids to participate in the procedure, subject to rejection, provided that the number is sufficient to ensure competition and is not less than 2. (Public Procurement Law of 2019, as amended in 2020, Arts. 189 and 210(3))
What is the minimum number of bidders for competitive dialogue procedures?	3. The contracting authority may limit the number of economic operators invited to the dialogue, whose bids have not been rejected, provided that this number is sufficient to ensure competition and is not less than 3. (Public Procurement Law of 2019, as amended in 2020, Art. 177(1))
Bidding period length
What are the minimum number of days for open procedures?	7. If the value of a contract falls below EU thresholds, the contracting authority shall set the date for submission of tenders, taking into account the complexity of the contract and the time needed to prepare them; however, in the case of supplies and services, this deadline shall be no less than 7 days from the date of publication of the notice; above EU thresholds, the minimum is 35 days (or 30 with e-submission, or 15 with prior publication notice). (Public Procurement Law of 2019, as amended in 2020, Arts. 138(1) and 283)
What are the minimum number of days for restricted procedures?	30. Deadline for submitting tenders taking into account the complexity of the contract and the time needed to prepare them; above EU thresholds, minimum 30 days; below EU thresholds minimum 7 days; urgent derogations apply in both cases. (Public Procurement Law of 2019, as amended in 2020, Arts. 161(1), 276 and 283)
What are the minimum number of days for competitive negotiated procedures?	7. If the value of a contract falls below EU thresholds, the contracting authority shall set the deadline for submitting tenders taking into account the complexity of the contract and the needs of the market; in the case of supplies and services, this deadline shall not be less than 7 days from the date of publication of the notice; above EU thresholds, the minimum is 30 days. (Public Procurement Law of 2019, as amended in 2020, Arts. 162(1), 275 and 283)
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. Main exceptions include: classic contracts and secondary contracts, or additional services under a concluded public contract, that the contracting authority is required to carry out on the basis of a procedure other than that specified in the Procurement Law; an obligation imposed on the contracting authority resulting from a generally applicable obligation, such as an international agreement concluded between the Republic of Poland and one or more countries that are members of the EU; in order to allow these obligations to be met, the Act establishes exceptions covering: defence and national security; intelligence services; quasi-in-house contracts (Teckal); public-public cooperation; R&D services; financial services; labour; legal services; acquisition of land or buildings. (Public Procurement Law of 2019, as amended in 2020, Arts. 9–14)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. The provisions of the Public Procurement Law apply to public awarding entities, which are: contracting authorities (defined broadly as public bodies and bodies governed by public law, including entities controlled by them) and entities other than contracting authorities, those specified in item 1; 3) legal persons other than those specified in point 1, not having an industrial or commercial character, if they were founded on the basis of, or with the goal of meeting a demand in the general interest and 4) points within the meaning of the executive act referred to in Art. 4 and 5 of the act. (Public Procurement Law of 2019, as amended in 2020, Arts. 4 and 5)
Does the law specify the main procedure types or procurement methods permitted?	Yes. The following procedures: 1) open tender; 2) restricted tender; 3) negotiated with publication; 4) negotiated without publication; 5) single-source procurement; 6) competitive dialogue; 7) innovation partnership; in a restricted tendering procedure and a restricted tendering procedure, and in other procedures, the awarding entity shall award a contract in the manner specified in the Public Procurement Law. (Public Procurement Law of 2019, as amended in 2020, Art. 129)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. The National Appeal Chamber ("Krajowa Izba Odwoławcza"/KIO) is a procurement arbitration body, with seats at multiple offices; it hears challenges to procurement procedures at first instance; its decisions may be appealed to the National Appeal Chamber of the National Appeal Chamber. (Public Procurement Law of 2019, as amended in 2020, Arts. 473, 505 and 513)
Is there a procurement regulatory body dedicated to public procurement?	Yes. The Public Procurement Office ("Urząd Zamówień Publicznych"/UZP) is a procurement regulatory body dedicated to public procurement; it is a central government administration body supervised by the Minister competent for the economy; it issues notices on EU thresholds, methodological guidance, monitors the system and maintains the e-zamowienia.gov.pl portal. (Public Procurement Law of 2019, as amended in 2020, Arts. 468–489)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)?	Yes. In the case of design competitions which shall be composed exclusively of persons having the qualifications enabling them to evaluate the design works; the tender committee shall elect its chairman from among its members; the chairman must, through the relevant authorities, appoint the chairman, must likewise hold the required authorisations; the Public Procurement Law stipulates that the tender committee is formed in accordance with the PPO Regulation and the Public Procurement Board's members. (Public Procurement Law of 2019, as amended in 2020, Arts. 335(4) and 468(2))
Is disclosure of final, beneficial owners required for placing a bid?	No. There is no mention in the PZP of beneficial ownership disclosure as a condition for submitting a bid; exclusion ground declarations capture certain integrity risks but do not specifically require beneficial ownership identification. (Public Procurement Law of 2019, as amended in 2020)
Complaints
Is there a fee for arbitration procedure?	Yes. the fee is set by Regulation of the Prime Minister of 15 March 2010, the fee for an appeal lodged in the proceedings before the KIO is, for supply contracts and services: 1) if the value of a contract falls below EU thresholds – PLN 7,500; 2) if the value of a contract is equal to or exceeds EU thresholds – PLN 15,000; for works contracts – PLN 10,000 and PLN 20,000 respectively. (Public Procurement Law of 2019, as amended in 2020, Arts. 516 (2)(1), 517(1)(2), 519 (1)(2); Regulation of the Prime Minister of 15 March 2010, as amended in 2018, § 1.1)
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. In the event of an appeal, the awarding entity may not conclude a contract until the Chamber renders the ruling after considering the appeal, or it makes another decision regarding the awarding entity; if a party may submit to the Chamber an application to revoke the prohibition to conclude a contract; the Chamber can also, in the course of proceedings, impose a temporary injunction associated with the need to protect all interests with regard to which there is a likelihood of injury occurring; the application for a stay must be submitted to the President of the Chamber; the Chamber shall announce its verdict after closing the hearing; if the complaint does not suspend the appeal proceedings before the Chamber, it will not suspend the announcement of the judgment. (Public Procurement Law of 2019, as amended in 2020, Arts. 473(1)(2), 577 and 578(1)(2))
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	15. The Chamber shall announce its verdict after closing the hearing; the KIO is required to hear the appeal within 15 days of its receipt; the proceedings include a public hearing; the Chamber shall announce its verdict and may publish it in the form of a summary; however, the Chamber may extend this period to 25 days where the subject-matter of a case is particularly complex. (Public Procurement Law of 2019, as amended in 2020, Arts. 544(1), 558 and 559)
Is there a requirement to publicly release arbitration court decisions ?	Yes. The Chamber shall announce its verdict after closing the hearing, and may publish it within 7 days from the date of announcement of the judgment; the statement of reasons for the decision includes an indication of the legal basis for the decision, includes a statement of justification of the findings of fact and a legal assessment of the contested procurement decision; decisions are publicly available at https://www.uzp.gov.pl/kio/wyroki-i-postanowienia-kio. (Public Procurement Law of 2019, as amended in 2020, Arts. 558 and 559)

Legislation

Public Procurement Law of 11 September 2019 (Polish)	pdf
Regulation of the Prime Minister of 15 March 2010 on the amount and method of collecting appeal fees and the types of costs in appeal proceedings and the manner of their settlement (Polish)	pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Risk-based approach						100
Sanctions for natural persons						71
Sanctions for legal persons						75
Pecuniary sanctions for obliged entities						60
Beneficial ownership of legal persons and legal arrangements						57
Supervision of obliged entities						0
Financial Intelligence Units (FIUs)						83
Mutual legal assistance (MLA) and International Cooperation						100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Risk-based approach
Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it.	Yes. The General Inspector prepares the national risk assessment in cooperation with the Financial Security Committee, cooperating units and obliged entities. On that basis, a national strategy with an action plan to reduce ML/TF risk is adopted. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 25(1),(3), 29(1), 31(1), 32(2))
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years.	Yes. The General Inspector must verify the national risk assessment and, where necessary, prepare it again at least every two years. This is stricter than a four-year review cycle. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 25(3))
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks.	Yes. The General Inspector is designated to prepare the national risk assessment, and the Financial Security Committee has an express role in giving opinions on it. The law therefore provides both an authority and a coordination mechanism. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 19(2)(1), 25(1), 29(3), 30(1))
Sanctions for natural persons
The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;	Yes. Polish law criminalises receiving, transferring, exporting, transferring ownership, converting, or taking other actions with criminal proceeds that can conceal their origin or help avoid detection or confiscation. (Penal Code, Art. 299(1))
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;	Yes. Polish law criminalises concealment and disguise by covering acts that can hinder establishing the criminal origin, location, detection, seizure, or confiscation of property derived from crime. (Penal Code, Art. 299(1))
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.	Yes. Polish law expressly criminalises receiving, possessing, and using property derived from criminal benefits. (Penal Code, Art. 299(1))
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence.	Yes. General rules on incitement, aiding and abetting, and attempt apply to money laundering offences. Preparation is also separately criminalised for money laundering. (Penal Code, Arts. 13(1), 18(2)-(3), 19(1), 22(1), 299(6a))
Money laundering offences are punishable by a maximum term of imprisonment of at least four years.	Yes. The base money laundering offence carries imprisonment from 6 months to 8 years, so the maximum term is at least four years. (Penal Code, Art. 299(1))
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences	No. The Penal Code does not expressly state that a prior or simultaneous conviction for the predicate offence is unnecessary. MONEYVAL also noted that Polish practice applies a high evidentiary standard to the predicate offence. (Penal Code, Art. 299(1); MONEYVAL Mutual Evaluation Report of Poland (2022), criterion 3.5 and paras. 233-234)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator;	No. Polish law does not clearly allow conviction on proof of criminal origin alone without precise identification of the predicate offence. MONEYVAL reported that prevailing court interpretation requires the predicate offence to be proven with exact legal qualification. (Penal Code, Art. 299(1); MONEYVAL Mutual Evaluation Report of Poland (2022), paras. 233-234)
Sanctions for legal persons
Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person.	No. The collective-entity regime is linked to listed predicate offences committed by a natural person and does not expressly create liability for breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 as such. The national rule does not directly match the indicator. (Act of 28 October 2002 on the Liability of Collective Entities for Punishable Offences, Arts. 3-5, 16(1))
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority.	Yes. A collective entity may be liable where an Article 16 offence, including Penal Code Article 299, was committed for its benefit and resulted from lack of due diligence in selection or supervision, or organisational failures. Liability also depends on the conditions in Article 4. (Act of 28 October 2002 on the Liability of Collective Entities for Punishable Offences, Arts. 3-5, 16(1)(1)(a))
Legal persons held liable are punishable by criminal or non-criminal fines.	Yes. A liable collective entity is subject to a monetary penalty of PLN 1,000 to PLN 5,000,000, capped at 3% of annual revenue. This is a binding non-criminal fine under the collective-entity statute. (Act of 28 October 2002 on the Liability of Collective Entities for Punishable Offences, Art. 7)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence.	Yes. A liable collective entity may be subject to confiscation and additional sanctions including bans on public financial support, international assistance, public procurement, and publication of the judgment. (Act of 28 October 2002 on the Liability of Collective Entities for Punishable Offences, Arts. 8-9)
Pecuniary sanctions for obliged entities
In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach.	Yes. Polish law provides administrative sanctions and measures for breaches of the national AML framework by obliged entities and responsible natural persons. Under the review methodology, sanctions under the national AML law implementing EU AML obligations count as compliant. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 147-153)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention).	Yes. Administrative pecuniary sanctions are available against obliged entities for serious, repeated or systematic breaches of the national AML regime. Under the review methodology, that is sufficient even though the Polish provisions are framed through national implementing law rather than the EU text itself. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 147-153)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed.	Yes. Supervisors may impose effective administrative measures and penalties under the Polish AML Act for breaches of AML/CFT obligations. Under the review methodology, sanctions for breach of the national implementing framework are as good as sanctions for breach of the EU rules themselves. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 147-153)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures.	No. Polish AML law provides administrative penalties and orders, but no explicit periodic penalty payment mechanism to compel compliance with supervisory measures was identified. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 150-151)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments.	No. The General Inspector must publish information on final administrative penalty decisions and related court review, but the law does not establish publication of all supervisory decisions as framed in the indicator and contains no periodic penalty payment regime. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 152(1))
Beneficial ownership of legal persons and legal arrangements
Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered.	No. Polish law establishes CRBR for Polish legal entities and for certain trusts, but it does not clearly extend the register to similar legal arrangements and does not expressly use the place-of-administration connecting factor in the indicator. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 55, 58)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation.	Yes. The register authority must take action to ensure correctness of CRBR data and may conduct clarifying proceedings and rectify entries. Read substantively, that framework enables it to require the information and supporting material necessary to identify and verify beneficial owners, even if the statute does not list every document type named in the indicator. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 57(2)(5), 60a, 61b)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number	No. A senior managing official is treated as beneficial owner only as a fallback and the register records the standard data listed in Art. 59. The law does not require a statement that no beneficial owner could be identified together with a justification. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 2(2)(1)(a), fifth indent; Art. 59(2))
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date.	Yes. The register authority must act to ensure the correctness and currency of CRBR data and may verify entries through clarifying proceedings. Together with the statutory updating obligation, this substantively satisfies the indicator’s requirement for verification on submission and thereafter, even without the same wording. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 57(2)(5), 60(1a), 61b)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them.	No. Obliged entities must report confirmed discrepancies, but cooperating units only may report them. The law does not impose a general mandatory discrepancy-reporting duty on competent authorities. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 61a(2)-(3))
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register.	Yes. Changes in beneficial ownership information must be updated in the register within the statutory time limit and entered without delay. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 60(1a), 63)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date.	No. The register authority may open proceedings and rectify data by decision, but no explicit power was found to conduct on-site inspections at business premises or registered offices. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 61b)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration.	No. The legislation provides access to information from the register but does not establish a certificate of proof of registration that can be withheld, refused or suspended. (Regulation of the Minister of Finance of 16 May 2018 on applications for access to information on beneficial owners and the provision of such information, §§ 3-4)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership.	Yes. Failure to file, update or provide accurate beneficial ownership information is punishable by administrative monetary sanctions, including against the beneficial owner who withholds the necessary information. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 57(2)(4), 153(1), 153(3))
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States.	No. The register is public, but Polish law does not expressly regulate the immediate, unfiltered access of the listed authorities to the interconnected EU central registers in the terms used by the indicator. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers.	Yes. CRBR information was publicly available free of charge in 2024. Free access is at least as favorable as a capped-fee regime for obliged entities, so the indicator is satisfied in substance. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67; Regulation of the Minister of Finance of 16 May 2018 on applications for access to information on beneficial owners and the provision of such information, §§ 2-4)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest.	Yes. Because CRBR information was publicly accessible in 2024, persons able to demonstrate a legitimate interest had access in substance, and access was available to a broader audience than the indicator minimum. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. Because CRBR information was publicly accessible in 2024, journalism and media actors connected with AML purposes had access in substance, even though Polish law did not need to create a special deemed-legitimate-interest category. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. Because CRBR information was publicly accessible in 2024, civil society organisations and academia connected with AML purposes had access in substance, even without an express deemed-legitimate-interest clause. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing;	Yes. Because CRBR information was publicly accessible in 2024, prospective counterparties seeking to avoid AML risk had access in substance, which is broader than the indicator minimum. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure;	Yes. Because CRBR information was publicly accessible in 2024, Member State public authorities in public procurement contexts could access it in substance, even without a separate category-specific rule. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. Where register information is publicly accessible, access does not depend on creating a category-specific identification trail for journalism or media applicants. Read in a transparency-oriented way, that is at least as favorable as the indicator minimum. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing.	Yes. Where register information is publicly accessible, access does not depend on creating a category-specific identification trail for civil society applicants. Read in a transparency-oriented way, that is at least as favorable as the indicator minimum. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67)
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days.	No. Polish law sets request channels and response times for register information, but it does not provide for a 3-year access certificate. (Regulation of the Minister of Finance of 16 May 2018 on applications for access to information on beneficial owners and the provision of such information, § 4(2))
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679.	No. No exhaustive statutory list of refusal grounds tied to a legitimate-interest access regime was identified. Polish law instead provides public-access rules for the register. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 67; Regulation of the Minister of Finance of 16 May 2018 on applications for access to information on beneficial owners and the provision of such information, §§ 2-4)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed.	No. Absent from legal framework
Supervision of obliged entities
Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113.	No. The AML Act appoints Polish AML supervisors for obliged entities, but it does not expressly require supervision to ensure compliance with Regulations (EU) 2024/1624 and (EU) 2023/1113 as such by 31.12.2024. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Art. 130)
Financial Intelligence Units (FIUs)
Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing.	Yes. Poland designates the General Inspector of Financial Information as a financial intelligence authority and expressly provides that it performs the tasks of an FIU within the meaning of Directive (EU) 2015/849. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 10(1)(2), 12(5))
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing.	Yes. The General Inspector receives suspicious transaction reports and may demand further information and documents needed to perform its statutory tasks, including analysis of suspected assets and transactions. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 12(1)(1), 74, 76(1))
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing.	Yes. The General Inspector must pass information and documents justifying suspicion of an offence to competent authorities and may transmit information ex officio to the authorities listed in the Act. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 12(1)(4), 106(1)-(1a))
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference.	No. The Act contains institutional safeguards for the General Inspector, including a fixed term and separate organisational support, but it does not clearly and explicitly state full operational independence and freedom from undue political, government or industry influence in the terms required by the indicator. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 11a-11g, 12(2))
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information.	Yes. The General Inspector may obtain and access information needed for its tasks from obliged entities, clearing houses, banks and public authorities, including protected information, financial information and analysis. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 12(1)(3), 13, 76(1), 104-105)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction.	Yes. Where money laundering or terrorist financing is suspected, the General Inspector may order an obliged entity to suspend a transaction or block an account for up to 96 hours. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 86(5), 87(1)-(2))
Mutual legal assistance (MLA) and International Cooperation
Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU.	Yes. When responding to a foreign FIU, the General Inspector may obtain information within its statutory powers for onward disclosure and must provide information to EU FIUs without delay upon request. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 110(1), 111(4), 111(6)(1))
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange.	Yes. The Act allows the General Inspector to exchange ML/TF-related information with foreign FIUs on request or spontaneously. Read substantively, that cooperation power is not limited by the type of predicate offence and can operate even where the predicate offence has not yet been identified. (Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, Arts. 110(1), 111(1)-(3))

Legislation

Law on Political Parties, 1997, amended 2016	missing file:
Election Code 2011	missing file:

*Last update: 2017

Asset Recovery

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Asset Offices						0
Confiscation						67
International cooperation						50

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Asset Offices
Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters.	No. Poland has specialised structures within the police and prosecution service dealing with asset recovery, but there is no single authority formally designated in law as an “asset recovery office” within the meaning of Council Decision 2007/845/JHA. (Code of Criminal Procedure; laws on the organisation of the prosecution service (no formal ARO designation).)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order.	No. The management of seized and confiscated assets follows general enforcement and state‑property rules; (Enforcement legislation and state property rules (no dedicated AMO).)
Confiscation
Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures)	Yes. The Code of Criminal Procedure provides for “zabezpieczenie majątkowe” (interim securing measures) over assets in order to secure future confiscation, procedural costs, (Code of Criminal Procedure, provisions on “zabezpieczenie majątkowe”)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation)	Yes. The Criminal Code obliges the court to order “forfeiture” (przepadek) (Criminal Code, Article 44 §1–2 (forfeiture of items derived directly from an offence and of instruments of the offence).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value)	Yes. Where the specific item derived from an offence cannot be confiscated, the court may order forfeiture of a pecuniary benefit obtained from the offence, (Criminal Code, Article 45 §1 (forfeiture of pecuniary benefit obtained from an offence, including in equivalent value).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation)	Yes. Forfeiture of pecuniary benefit can be ordered also where the benefit has been obtained by another person, including third parties, (Criminal Code, Article 45 §3–4 (forfeiture of pecuniary benefit obtained by another person, with protection of bona fide third parties).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation)	Yes. Extended forfeiture allows confiscation of property whose lawful origin is not demonstrated and which was acquired during a period of five years before the offence up to the time of the judgment, (Criminal Code, Article 45 §2 (extended forfeiture of benefit, presumption concerning property acquired in the five‑year period); Article 44a (forfeiture of an enterprise).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation)	No. The Polish system is centred on criminal confiscation linked to criminal liability; as at 31.12.2024, there is no general non‑conviction based confiscation regime covering all situations listed in Article 15 of Directive (EU) 2024/1260. (Criminal Code, Articles 44–45a; Code of Criminal Procedure (no general NCBC for these situations).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation)	No. As of the end of 2024 there is no autonomous confiscation‑only procedure without conviction that is tailored to the requirements of Directive (EU) 2024/1260; (Criminal Code, Articles 44–45a; Code of Criminal Procedure (no NCBC regime in the sense of Directive (EU) 2024/1260).)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth)	Yes. Extended forfeiture may be applied, inter alia, where the offence was committed within an organised criminal group or generated a financial benefit exceeding a statutory threshold, (Criminal Code, Article 45 §2 (extended forfeiture in cases of serious offences, including those committed in an organised criminal group or yielding high financial benefit).)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027)	No. Although asset recovery has been developed in legislation and policy documents, there is no statutory national asset recovery strategy with a mandatory five‑year update cycle as of 31.12.2024. (No explicit national asset recovery strategy provision in the Criminal Code, Code of Criminal Procedure)
International cooperation
To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters.	Yes. The Code of Criminal Procedure (Code of Criminal Procedure,)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information	No. International cooperation on assets operates via mutual legal assistance and operational networks, but no single ARO is formally designated with explicit information‑exchange duties as required by Council Decision 2007/845/JHA. (Legislation on judicial cooperation in criminal matters (no formal ARO designation or specific ARO‑to‑ARO duties).)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders.	No. Polish legislation on mutual legal assistance and confiscation does not contain an express provision on cost‑sharing (No explicit cost‑sharing clause in the Code of Criminal Procedure)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions	Yes. Poland may share confiscated assets with other states under Council of Europe confiscation conventions and EU (Implementation of Council of Europe conventions on confiscation (ETS No. 141, CETS No. 198) and EU)

Legislation

Law on Political Parties, 1997, amended 2016	missing file:
Election Code 2011	missing file:

*Last update: 2017

Poland

Country Facts

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