COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Poland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Poland
Date: 2022-06-01
Institutions: European Commission, Secretariat-General
Subjects: EU aid, EU loan, Poland, coronavirus disease, economic and social cohesion, economic recovery, economic reform, epidemic, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.6.2022  SWD(2022) 161 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Poland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Poland {COM(2022) 268 final}  
 
 
Table of contents   

1.  EXECUTIVE SUMMARY 

2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER 

2 

5 

2.1.  Macroeconomic outlook and developments since the 2020 country report ..................... 5 

2.2.  Challenges related to sustainable growth, cohesion, resilience and policies for the next 
generation .......................................................................................................................................... 8 

2.3.  Challenges related to the green and digital transition ..................................................... 10 

3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN 

21 

3.1.  Overall strategy of the plan ................................................................................................ 21 

3.2. 

Implementation aspects of the plan ................................................................................... 23 

4.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

26 

4.1.  Comprehensive and adequately balanced response to the economic and social 
situation ............................................................................................................................................ 26 

4.2.  Link with country-specific recommendations and the European Semester .................. 34 

4.3.  Growth potential, job creation, economic, institutional and social resilience, European 
Pillar of Social Rights, mitigating the impact of the crisis, and social territorial cohesion and 
convergence ..................................................................................................................................... 41 

4.4.  The principle of ‘do no significant harm’ ......................................................................... 48 

4.5.  Green transition .................................................................................................................. 49 

4.6.  Digital transition ................................................................................................................. 53 

4.7.  Lasting impact of the plan .................................................................................................. 58 

4.8.  Milestones, targets, monitoring and implementation ...................................................... 61 

4.9.  Costing ................................................................................................................................. 63 

4.10.  Controls and audit .............................................................................................................. 65 

4.11.  Coherence ............................................................................................................................ 67 

ANNEX – CLIMATE AND DIGITAL TAGGING 

72 

1 

 
 
 
 
 
 
1.  EXECUTIVE SUMMARY 

The  implementation  of  the  recovery  and  resilience  plan  is  expected  to  contribute 
significantly to the recovery from the COVID-19 crisis. The COVID-19 pandemic pushed 
Poland’s  economy  into  a  broad-based  recession  in  2020.  After  nearly  three  decades  of 
uninterrupted economic  growth, Poland’s economy  contracted by  2.2% in 2020. The fall in 
GDP was milder than the EU average, however, as Poland’s low exposure to hard-hit sectors 
and  its  diversified  economic  structure  cushioned  the  impact  of  containment  measures  on 
economic  activity.  Real  GDP  then  recovered  strongly  in  2021  despite  recurring  COVID-19 
waves and supply chain  disruptions, swiftly putting Poland back to its pre-pandemic output 
path. According to the Euroepan Commission’s Spring 2022 Economic forecast, real GDP is 
expected to decelerate to 3.7% and 3.0% in 2022 and 2023, respectively. After falling to its all-
time low in 2020, the unemployment rate is expected to increase again to 3.9% in 2023, mainly 
driven  by  the  significant  inflow  of  displaced  persons  from  Ukraine,  which  will  increase 
Poland‘s labour force. In 2021, the government deficit declined to 1.9% of GDP. The general 
government  debt-to-GDP ratio is  expected to  decline from  57.1% of GDP in  2020 to  some 
49.8% of GDP over the forecast horizon. The plan fully uses the estimated grant allocation of 
EUR 23.9 billion and Poland has requested EUR 11.5 billion of loans under the Recovery and 
Resilience Facility. 

Poland’s challenges  relate  mainly  to shifting the economy towards higher value-added 
and lower emissions while improving the quality of key public services, such as education 
and  training,  health,  long-term  care  and  a  stable  and  a  predictable  regulatory 
environment.  The  recovery  and  resilience  plan  should  make  a  significant  contribution  to 
boosting  the  country’s  economic  rebound  and  contribute  to  a  green,  digital,  inclusive  and 
resilient future. Structured around the six pillars, the plan gives a focused response to several 
of Poland’s structural challenges.  

The  plan  is  expected  to  contribute  to  effectively  addressing  a  significant  subset  of  the 
structural  challenges  identified  in  the  country-specific  recommendations  of  2019  and 
2020.  The  plan’s  strong  focus  on  energy  transformation  and  the  decarbonisation  of  the 
economy, sustainable transport, digital  transition,  improving the labour market  relevance of 
vocational education and training and lifelong learning, improving accessibility and quality of 
early childhood education and care below the age of three as well as accessibility and quality 
of  healthcare,  innovation-enhancing  support,  addressing  labour  market  segmentation  and 
improving the investment climate can be considered a comprehensive and adequate response 
to the challenges Poland is facing. 

The  implementation  of  the  recovery  and  resilience  plan  is  expected  to  contribute 
significantly  to  economic  growth  and  job  creation  in  Poland,  while  strengthening 
economic,  social  and  institutional  resilience.  RRF  support  for  research  and  innovation  is 
expected to enhance research commercialisation activities and to facilitate innovation diffusion 
in the business sector, which is expected to lead to productivity growth in the medium to long 
term.  The  RRF  support  is  expected  to  provide  a  boost  to  aggregate  demand  in  the  short  to 
medium term, improving the cyclical position of the Polish economy, and thereby mitigating 
the adverse economic effects of the COVID-19 crisis. The plan also contains several measures 
contributing to increasing social resilience. They include measures for further development of 
childcare and long-term care, which are expected to improve the labour market participation of 
women. Additionally, extending the obligation for social security contributions to all civil law 
contracts is expected to further reduce the segmentation of the labour market and to provide 
better  social  protection  to  certain  workers.  Personal  income  tax  reductions  envisaged  for 

2 

 
 
taxpayers  reaching  the  statutory  retirement  age  and  deciding  to  continue  working  aim  at 
extending  careers  and  are  expected  to  help  decrease  income  inequalities  for  the  elderly. 
Resilience  of  the  labour  market  is  expected  to  be  strengthened  by  measures  improving  the 
quality and adequacy of the functioning of Public Employment Services and reaching out to 
and activating older workers or people from disadvantaged groups through up- and reskilling 
programmes. Measures to attract and integrate labour migrants as well as to promote flexible 
forms of employment are expected to further increase the resilience of the labour market.  

The  plan  is  expected  to  contribute  to  addressing  challenges  related  to  the  investment 
climate, notably with regard to the Polish judicial  system as well as decision- and law-
making processes. In particular, the plan contains measures aiming to reduce the regulatory 
burden and improve the quality of law-making by reducing the use of fast-tracking procedures 
and rendering mandatory the use of impact assessments and public consultations. Furthermore, 
dedicated measures aim to strengthen the independence and impartiality of courts, through the 
reform of the disciplinary regime applicable to judges. 

With  42.7%  of  its  allocation  dedicated  to  climate-related  measures,  Poland’s  recovery 
and resilience plan has  a strong focus  on climate  mitigation and adaptation as well as 
environmental restoration and contributes to achieving the 2030 and 2050 climate targets. 
Increasing  the  installed  capacity  of  onshore  wind  farms  and  photovoltaic  installations, 
investments  in  renewable  energy  production  –  in  particular  offshore  wind  farms  –  and 
renewable  and  low-carbon  hydrogen  capacity  combined  with  a  set  of  reforms  aimed  at 
facilitating investments in onshore wind should help Poland achieve its 2030 renewables target. 
A wide programme of replacing  coal-fired boilers combined  with  building  renovations will 
decrease  their  impact  on  greenhouse  gas  emissions  and  improve  air  quality.  In  transport,  a 
comprehensive package of reforms and investments will promote zero-emission mobility (both 
on roads and railways), multi-modality, road safety and sustainable public transport. The plan 
also includes reforms and investments aimed at water management in rural areas.  

All measures in the Polish plan pass the ex-ante assessment of the ‘do no significant harm’ 
principle.  Any  potential  harmful  environmental  and  climate  impact  is  addressed  through 
appropriate  assurances  that  the  applicable  criteria  are  to  be  respected.  For  some  measures 
contained  in  the  energy  or  transport  components,  which  are  sensitive  from  a  climate  and 
environmental point of view, Poland ensures that no significant harm to the environment be 
done through a binding commitment to comply with the relevant requirements of the “do no 
significant harm” technical guidance of the European Commission (2021/C 58/01). 

With  21.3%  of  its  allocation  dedicated  to  digital  measures,  the  plan  is  expected  to 
contribute significantly to the digital transformation of the Polish economy and society. 
The plan puts strong emphasis on connectivity, which aims to provide access to fast internet 
connection in white Next Generation Access (NGA) areas, where internet access of at least 30 
Mb/s  is  not  guaranteed,  and  foster  commercial  investments  in  modern  electronic 
communication  networks.  The  development  of  digital  skills  is  one  of  the  objectives  of  the 
Digital  Competence  Development  Programme  and  of  the  overarching  investment  in  basic 
digital skills of different groups of the population, including civil servants, teachers, citizens 
with insufficient basic digital knowledge and people excluded or at risk of exclusion. The new 
policy  for  the  digitalisation  of  education,  common  digital  standards  for  schools  and  the 
substantial investment in ICT equipment for schools and teachers aim to ensure equal access 
to digital education and to support the efficient integration of ICT in teaching and learning. The 
plan  also  focuses  on  improving  e-Government  services  and  cybersecurity  of  the  public 
administration and of the economy, on innovation, labour market,  agriculture, green energy 
and reduction of energy intensity, e-health and transport. 

3 

 
 
The plan is expected to have a lasting impact on Poland. The plan includes a package of 
measures  aimed  at  addressing  several  structural  challenges  identified  in  the  context  of  the 
European Semester. The measures in  the plan  also  are set  to  facilitate the green and digital 
transitions and strengthen the growth potential, job creation and economic and social resilience 
of  Poland.  The  measures  presented  in  this  respect  comprise  structural  changes  to  the 
administration or relevant institutions and policies. The lasting impact refers to policy areas 
where the estimated long-term impact on growth potential and employment is significant but 
also  in  areas  where  structural  changes  are  expected  to  improve  social  aspects  that  are  not 
necessarily quantifiable. More specifically, the plan includes relevant structural changes to the 
public administration and institutions. Notably, reforms to improve the investment climate and 
to encourage the uptake of digital solutions in the public sector are set to have a lasting impact. 
The digitalisation efforts across a wide range of public institutions and administration levels 
have the potential to structurally enhance efficiency and improve the quality of public services. 
The plan includes several measures to foster the green transition, having a lasting impact on 
many  aspects  of  the  economy,  including  environmental,  health,  and  competitiveness  ones. 
Several  policy  changes  are  envisaged  to  improve  the  business  environment  with  a  lasting 
impact on the country’s competitiveness and potential for increasing investment. In the area of 
health, the reform of the hospital supervision system will likely support cost-efficiency and the 
quality of services.  As far as labour market  and  education  are concerned, the plan includes 
measures that will have  a lasting positive impact by  increasing  labour market  participation, 
limiting labour market segmentation, improving the quality of early childhood education and 
care below the age of three, modernisation of vocational education and training, and providing 
up-skilling and reskilling opportunities. Finally, the reform to modernise and simplify public 
finance  management  will  strengthen  Poland’s  budgetary  framework  and  enhance  more 
efficient management of spending. 

The plan proposes a comprehensive and coherent set of milestones and targets that are 
clear,  realistic  and  with  a  sufficient level  of  ambition  to  achieve  the  objectives  of  each 
component. Indicators attributed to milestones and targets are relevant, acceptable and robust. 
Poland has set up a comprehensive implementation system with a leading role of the Ministry 
of  Funds  and  Regional  Policy.  Concretely,  the  Ministry  is  responsible  for  monitoring  the 
implementation of the plan, verification of achievement of milestones and targets, reporting to 
the European Commission, establishing procedures for the implementation of the audit, and for 
drawing up and submitting payment requests and management declarations to the European 
Commission.  The  plan  also  provides  adequate  information  on  coordination  and  reporting 
mechanisms  between  the  Ministry  and  other  actors  in  charge  of  the  implementation  of 
investments  and  reforms.  The  same  applies  to  the  information  concerning  the  assurance  of 
management verifications, in particular for the fulfilment of milestones and targets.  

Overall, sufficient information and supporting documents has been provided to conclude 
that the estimated total cost of the plan is reasonable and plausible, commensurate to the 
expected  national  economic  and  social  impact,  and  additional  to  other  funds.  The 
calculations and the methodology and assumptions made for the cost estimates of the various 
measures of the plan are clear and understandable. Poland has also provided a sufficient volume 
of  justification  and  evidence  to  underpin  the  reasonability  and  plausibility  of  those  cost 
estimates. These are most often built on the basis of the previous projects carried out for similar 
investments  in  the  past.  The  plan  does  include  some  operational  costs  which  cannot  be 
considered  as  recurring  because  their  nature  is  temporary  and  exclusively  limited  to  the 
achievement of the relevant investment or reform. As regards additionality, the plan provides 
information on other sources of EU financing where relevant and sufficient assurance that the 
same type of cost will not be financed from several sources of EU funding.  

4 

 
 
The  arrangements  proposed  in  the  recovery  and  resilience  plan  are  adequate  to 
contribute  to  prevent,  detect  and  correct  corruption,  fraud  and  conflicts  of  interests, 
provided  that  pending  issues  are  addressed  in  due  time,  through  specific  measures 
contained in the proposal  for the Council implementing decision.  The arrangements are 
expected  to  effectively  avoid  double  funding  and  help  lower  the  risks  as  regards  the 
effectiveness of the fight against corruption. 

The plan presents a coherent and comprehensive package of reforms  and investments 
mutually reinforcing each other with a strong reform drive. Synergies between measures 
in the plan and with other national policies are ensured within components (for instance in the 
areas of transport, energy and digitisation) as well as horizontally across several components 
(for  instance  by  improving  e-competences  in  the  digital  component  and  increasing  labour 
market relevance of vocational education and training, including upskilling with digital skills, 
in the education sub-component). 

No/insufficient info 
provided 

Satisfactory 

Satisfactory, but 
justification lacking 

Partially satisfactory 

Unsatisfactory 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

(10) 

(11) 

Balanced 
Response 

CSRs 

Growth, 
jobs… 

DNSH 

Green 
target 

Digital 
target 

Lasting 
impact 

M & T 

Costing 

Control 
Systems 

Cohere
nce 

A 

A 

A  

A 

A 

A 

A 

A 

B 

A 

A 

2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER 

2.1. Macroeconomic outlook and developments since the 2020 country report 

The  COVID-19  pandemic  had  a  significant  impact  on  the  Polish  economy,  but  the 
recovery was swift and robust. Before the pandemic, Poland was going through a period of 
strong economic growth. Real GDP expanded by 4.7% in 2019, driven by a robust performance 
of both domestic demand. Private consumption was thriving amid high consumer confidence 
and a buoyant labour market, which was recording all-time low unemployment rates and strong 
wage  dynamics.  The  COVID-19  pandemic  led  to  a  sudden  halt  of  GDP  growth  in  2020  as 
containment measures disrupted economic activity and foreign demand plunged. Following the 
introduction of government restrictions in March 2020, real GDP contracted by 3.8% in the 
first half of the year. Economic activity then rebounded strongly in the third quarter of 2020, 
growing by 7.3% q-o-q, but a surge in new infections and the reintroduction of containment 
measures during the last months of 2020 weighed on recovery. As a result, real GDP contracted 
by 2.2% in 2020, representing the first recession in Poland in nearly three decades. In 2021, 
despite recurrent  COVID-19 waves,  the economy  continued  a strong  growth  path,  reaching 
pre-crisis levels of GDP in Q2-2021. Booming private consumption was the main driver of the 
rebound, supported by high levels of accumulated savings and a strong labour market. All in 
all, real GDP expanded by 5.9% in 2021, putting Poland back to its pre-pandemic output path.  

All sectors of the economy have been affected by the crisis, but the services sector took 
the hardest hit. At the beginning of the pandemic, the lockdown impacted the economy as a 
whole. Industrial production fell by 25.1% in April 2020 in year-on-year terms, driven by an 
unprecedented drop in manufacturing, particularly in the car industry. Shop closures also led 
to  a  plunge  of  retail  sales,  which  decreased  by  11.8%  year-on-year  in  April  2020.  Yet,  as 
restrictions became more targeted and supply chain disruptions observed at the beginning of 

5 

 
 
 
 
the  pandemic  gradually  disappeared,  most  economic  sectors  saw  a  strong  and  sustained 
recovery from May 2020 onwards. Nevertheless, restrictions on activities that require face-to-
face interactions weighed on the recovery of the services sector. After the historical drop in 
confidence  and  turnover  during  the  first  wave  of  the  pandemic,  the  services  sector  only 
managed to partially recover the losses during the 2020 summer period. The recurrent waves 
of the pandemic further contained the recovery, resulting in a drop of almost  6.3% in gross 
value added in 2020 in services, vs. the -2.6% in the economy as a whole1. Still, the sector was 
aided by significant public support, mainly in the form of loans and grants to companies, which 
prevented a sharp and sudden rise in bankruptcies. 

The macroeconomic scenario contained in Poland’s Recovery and Resilience Plan expects 
a  rebound  of  economic  activity  in  2022-2023,  following  the  COVID-19-induced 
contraction in 2020. The macroeconomic scenario underpinning the plan had 31 March 2021 
as a cut-off date. Thus, the projections do not take into account economic developments for 
2021 and the beginning of 2022, including the real GDP growth publication for 2021, which 
stood at 5.9%. For 2022, the forecast projects real GDP growth at  4.3%, driven by a strong 
pick-up  in  private  consumption  and  investment,  which  is  expected  to  be  helped  by  public 
investments  financed  from  the  Recovery  and  Resilience  Facility  and  by  the  drawing  of 
Multiannual  Financial  Framework  (MFF)  funds.  Growth  is  then  expected  to  gradually 
moderate in 2023 and 2024 to around 3.7%-3.5%. The output gap is estimated to be closed by 
2022 with output above potential thereafter. According to the plan, inflation is set to return to 
the 2.5% corridor over the forecast horizon. 

Against  this  backdrop,  the  scenario  expects  unemployment  to  peak  in  2021  before 
gradually falling to 2.0% in 2024. Poland’s labour market was showing signs of overheating 
before the crisis, with unemployment reaching an all-time low at the beginning of 2020 and 
wage growth standing at 7.3% in 2019. The COVID pandemic had a limited impact on the 
labour  market,  mainly  due  to  sizeable  fiscal  support,  which  encouraged  cutting  worktime 
instead  of  jobs.  According  to  the  baseline  scenario  of  the  plan  (that  does  not  factor  in  the 
positive impact of the plan), unemployment is expected to gradually decrease to 2.0% in 2024. 
Structural challenges in the labour market remain, however, despite its good performance since 
the recovery took hold. These include a low labour market participation of some population 
groups,  segmentation  in  employment  protection,  differences  in  employment  rates  across 
regions, as well as labour and skill shortages. Although the employment rate increased to all-
time  highs,  women’s  participation  in  the  labour  market  remains  significantly  below  that  of 
men, as they generally bear a larger share of care responsibilities. Despite investments in online 
education,  the  COVID-19  pandemic  has  deepened  inequalities  in  education,  affecting  in 
particular  disadvantaged  students,  which  may  also  lead  to  increased  early  leaving  from 
education and training in the long run. Labour shortages continue to be a significant problem, 
as it limits the ability of the economy to restructure towards high-growth and highly productive 
sector. Income inequality in Poland remains around the EU average, while the share of people 
at  risk of poverty or social exclusion has been decreasing steadily in  recent  years, standing 
below the EU average in 2019.   

The pandemic had a strong negative impact on public finances. The budget deficit reached 
6.9% of GDP in  2020. By 2023  it is  set  to  decline to  4.4% of GDP, according to  the 2022 
Spring  Commission  forecast.  Discretionary  policy  measures  in  response  to  the  pandemic 

1  The  figure  for  economic  activity  in  services  refers  to  the  gross  value  added  in  wholesale  and  retail  trade, 
transport, accommodation and food service activities (NACE rev. 2 G-I) and arts, entertainment and recreation 
and other service activities (NACE rev. 2 R-U).  

6 

 
 
 
                                                           
amounted to 4.5% of GDP in 2020. For 2022, the baseline scenario of the plan (which does not 
take  the  impact  of  the  plan  into  consideration)  expects  a  deficit  of  4.2%  of  GDP,  which  is 
expected to decline to 2.5% of GDP by 2024. This does not take into consideration the impact 
of the measures included in the plan on public finances. After an increase in the debt-to-GDP 
ratio to 57.1% due to the combined effect of the macroeconomic downturn and fiscal package 
to counteract the crisis in 2020, the 2022 Spring Commission forecast projects the debt to reach 
49.8% of GDP in 2023.   

The  plan  specifies  a  number  of  risks  for  the  macroeconomic  scenario.  Downside  risks 
mainly relate to a stronger-than-expected rise in inflation stemming from supply constraints 
and  labour  shortages,  which  could  weigh  on  purchasing  power  and  private  consumption 
growth.  New  COVID-19  waves,  especially  given  Poland’s  relatively  low  vaccination  rate, 
could also hinder the recovery. On the other hand, a better-than-expected recovery of Poland’s 
main trading partners could boost growth, representing a significant upside risk. On balance, 
risks are tilted to the downside, but the outlook remains broadly uncertain.  

Table 1: Comparison of macroeconomic developments and forecasts 

2019 

2020 

2021 

2022 

2023 

2024 

COM  COM  COM  COM  RRP  COM  RRP  RRP 

4.7 

-2.2 

5.9 

3.7 

4.3 

2.1 

0.0 

3.3 

3.7 

0.0 

3.2 

5.2 

11.6 

2.8 

1.5 

3.4 

0.4 

4.1 

0.0 

3.0 

3.0 

7.3 

0.3 

3.9 

3.7 

2.6 

0.0 

2.5 

3.5 

2.5 

0.0 

2.0 

-0.7 

-6.9 

-1.9 

-4.0 

-4.2 

-4.4 

-3.2 

-2.5 

45.6 

57.1 

53.8 

50.8 

- 

49.8 

- 

- 

Real GDP  
(% change) 
Inflation  
(% change) 
Employment (15-74 
years, % change) 
Unemployment rate 
(%) 
GG net lending  
(% of GDP) 
Government debt  
(% of GDP) 

Source: Commission 2022 Spring Forecast; Recovery and Resilience Plan (RRP) 

The forecast underpinning the plan is different than the latest Commission’s forecast, but 
this is largely due to different cut-off dates2. The forecast underpinning the plan had as a cut-
off date the 31 March 2021. It has not been updated after the Plan was submitted in May 2021. 
At  the  same  time,  the  latest  European  Commission  projections  are  from  the  Spring  2022 
forecast, with a cut-off date of 29 April 2022. Consequently, differences between the forecast 
in the plan and the European Commission’s forecast mainly stem from different cut-off dates, 
which result in varying assumptions and data underpinning both forecasts.  

2 The forecast underpinning the plan had 31 March 2021 as a cut-off date, as it was not updated after the Plan was 
submitted in May 2021. In contrast, the European Commission projections are from the European Commission’s 
Spring 2022 forecast (cutoff date 29 April 2022). Differences from the  forecast underpinning the plan and the 
European  Commission’s  forecast  mainly  stem  from  economic  developments  between  both  cut-off  dates.  In 
particular, the forecast underpinning the plan does not account for the significant acceleration on inflation from 
mid-2021 onwards. It does not account for the better than expected performance of the Polish economy during 
the second half of 2021, either, nor for Russia’s unprovoked invasion of Ukraine. 

7 

 
 
 
 
 
                                                           
The  forecast  underpinning  the  plan  is  slightly  more  optimistic  than  the  European 
Commission’s forecast. The 2022 Commission Spring forecast expects real GDP growth to 
be below that of the RRP forecast. In particular, the Commission 2022 Spring forecast expects 
real GDP to grow by 3.7% and 3.0% in 2022 and 2023, respectively. This is less optimistic 
than the forecast underpinning the plan, which projects growth at 4.3% in 2022 and 3.7% in 
2023. The European Commission’s less optimistic forecast is largely due to the inclusion of 
the Russian invasion of Ukraine into the forecast, which significanly clouded the outlook for 
the Polish economy. In line with the Polish authorities, the Commission considers that domestic 
demand,  particularly  private  consumption,  will  be  the  main  growth  driver  over  the  forecast 
horizon. For net exports, the MoF projections expect a negative contribution of net exports to 
growth  in  2022,  before  remaining  broadly  stable  in  2023.  This  goes  against  the  European 
Commission’s forecast, which project a positive – albeit small – contribution of net exports to 
growth in 2022 and 2023. Regarding the labour market, the European Commission forecast 
projects the unemployment rate to increase in 2022 due to the significant inflow of displaced 
persons from Ukraine. For inflation, the Commission forecast foresees a substantially stronger 
acceleration  of  inflation  over  the  forecast  horizon.  For  the  general  government  deficit,  the 
Commission forecasts a better performance compared to the Plan for 2022, but worse for 2023, 
mainly due to the assumptions on cost of aid to displaced persons from Ukraine. Years beyond 
2023 are currently not  covered by the Commission forecast. The macroeconomic and fiscal 
outlook continue to be affected by high uncertainty related to the COVID-19 pandemic and 
Russia’s unprovoked invasion of Ukraine.  

The  macroeconomic  scenario  of  the plan is  overall  plausible. The  economic  scenario  is 
identical to the one contained in the 2021 budget, National Reform Programme, Stability and 
Convergence Programme and has been developed by the Ministry of Finance. The economic 
projections are broadly similar to those from other international institutions and independent 
government agencies.   

2.2. Challenges related to sustainable growth, cohesion, resilience and policies for the 

next generation 

Poland has made fast progress in catching up with the EU average in the years following 
EU accession, driven by a significant inflow of foreign direct investment and close access 
to the EU market. GDP per capita in Poland increased from 63% of the EU average in 2010 
to around 73% in 2019, in Purchasing Power Parity terms. This period of swift convergence 
was based on deeper integration of Poland’s economy into global value chains, mainly thanks 
to the relative competitiveness of Poland’s businesses, including lower labour costs compared 
to  the  EU  average.  However,  despite  considerable  progress  in  recent  years,  Poland  faces 
significant long-term structural challenges that can hinder the country’s potential to maintain a 
sustainable growth path, resilience and cohesion in the coming decades. 

An  overarching  challenge that  Poland  faces is  the  transition  towards  a  higher  value-
added economy. This includes increasing Poland’s research and innovation capacity in order 
to upgrade  its  growth  model  from  cost-competitiveness  towards  sustainability  and more 
advanced products and services in the medium to long term. Measures in this area should focus 
on 
transfer, 
strengthening the mechanisms  and  support  structures  for  the  transfer  of  research,  as  well 
as supporting  the commercialisation of  research  and  innovation,  which  includes  generally 
improving the R&D&I governance framework. Improving investment in innovation and R&D 

public-private 

cooperation 

knowledge 

improving 

and 

8 

 
 
 
 
 
 
through e.g. fiscal incentives, regulatory changes, increased Science, Technology, Engineering 
and Mathematics (STEM) education and public investment will be key to help Poland develop 
products and services that will allow its economy to move up the value-chain.  

structural  deficiencies 
The  pandemic  has  amplified the  need 
in Poland’s social services, labour market and education system. Social benefits should be 
better targeted to those in need. Challenges persist in the provision of social services, such as 
the underdeveloped childcare and long-term care services. These also hinder the labour market 
participation of various groups, in particular of women. Labour shortages have limited Poland's 
growth potential and ability to move up the value chain. 

tackling 

for 

Significant skills gaps as well  as a decrease of the working-age population contribute to 
the  labour  shortages.  To  address  the  declining  number  of  people  at  working  age,  it  is 
important to encourage labour migration and the integration of migrants, particularly the high-
skilled. As nearly half of the adult population lacks basic digital skills and the overall adults’ 
participation in learning is low, enhancing digital skills and efficient coordination of life-long 
learning policies is paramount. Increasing labour market participation of women, older people, 
persons with disabilities and their carers, those with lower qualifications, removing obstacles 
to more permanent forms of employment and improving the labour market relevance of skills is 
needed  for more resilience in  the  future.  Moreover,  the  frequent  use  of  non-standard  labour 
contracts (work contracts based on civil law) has led to labour market segmentation. While it 
has been limited in  recent  years, it is  important to  tackle the varying social protection. The 
pandemic  has  indicated  that  expanding  and  enhancing  flexible  working  arrangements 
(e.g. distance working and flexible working time schemes), notably under permanent types of 
employment,  may  also  help  support  groups  with  lower  activity  rates  to  find  permanent 
employment.  

The Polish healthcare system is inefficient and excessively relies on hospitals, based on 
the most costly type of care. Shifting towards primary and ambulatory care is of particular 
importance, as healthcare spending is expected to grow considerably in the medium to long 
term, increasing the burden on public finances. Some hospitals run substantial debts and with 
low occupancy rates, while many medical procedures currently performed in hospitals could 
be performed at lower levels  of care and at  lower  costs. Therefore,  a shift from  hospital to 
outpatient  care  is  important  and  should  be  underpinned  by  a  clear  vision  for  reform  and 
consolidation  of  the  hospital  sector.  The  primary  care  system  is    understaffed  and 
overstretching its services. Its potential remains untapped, thus overburdening higher levels of 
care. At the same time, the hospital system suffers from chronic underfunding, especially in 
terms  of  human  resources.  Due  to  unfavourable  conditions,  such  as  low  salaries,  medical 
professions are not popular, and a significant ‘brain drain’ can be observed. The shortage in 
human resources places Poland in the lowest ranks compared with other Member States, and 
makes it necessary to keep professionals working beyond their retirement ages (with 40% of 
medical  doctors  over  the  pensionable  age  in  some  specialisations).  Access  to  care  differs 
among regions. Although progressing, e-health services are underdeveloped and underused. 

Since ensuring a favourable business  and investment environment is  important for the 
economy,  especially  to  support the recovery  of  all  sectors,  Poland  should address  a 
number of challenges in this area. Fostering a stable and predictable regulatory framework, 
diminishing burdensome administrative requirements and procedures and frequent changes to 
key  laws  (in e.g. taxation,  social  security  contributions,  energy  policies),  improved  use  of 
experts, impact assessments and meaningful social partner consultations, and limiting the use 

9 

 
 
 
 
 
 
fast-track 

that  do  not 

legislative  procedures 

require  public  consultations will 
of 
help build a more resilient economy. Poland’s low private investment share to GDP compared 
to  the  EU  average  and  peer  countries  could  hinder  its  ability  to  transition  into  a  more 
knowledge-based  economy.  Ensuring equal 
treatment  of  economic  operators  by  an 
independent  judiciary  is  also  essential  for  a solid investment  climate. Safeguarding and 
upholding the rule of law is a cornerstone for making the Polish economy more resilient.  

Safeguarding  sound  public  finances  is  crucial  to  establishing  the  right  conditions  for 
mitigating the negative consequences of the pandemic and for making the economy more 
resilient in the future. Poland will face high expenditure pressures in the medium and long 
term as an effect of ageing of the population, an expected lower inflow of EU funds as Poland 
catches up with the EU, investments in the green transition and supporting the move towards a 
more  knowledge-based  growth  model. At  present, expenditure  management  in  Poland  has 
several weaknesses resulting from an outdated budget system and a frequent circumvention of 
fiscal rules. In view of limited expected tax collection gains, efficient and effective expenditure 
management will be key to ensuring fiscal sustainability. 

2.3. Challenges related to the green and digital transition 

An overarching objective of the Recovery and Resilience Facility is to support the twin 
green and digital transitions. The Polish economy is lagging in bringing emissions reductions 
and energy sector developments into line with EU targets and in reaping the benefits of the 
digital  transition,  as  measured  in  the  Commission’s  assessment  of  Poland’s  2020  National 
Energy and Climate Plan (NECP) and the 2021 Digital Economy and Society Index (DESI), 
respectively. To advance the green and digital transitions of society and of the economy, Poland 
needs  to  increase  its  ambitions  and  commit  to  long-term,  consistent  policies.  This  section 
recalls where Poland stands relative to the EU targets related to the green and digital transitions. 

Green dimension 

The recovery and resilience plan should contribute to the green transition and at least 
37% of the financial allocation needs to contribute to climate objectives. The measures in 
the  plan  shall  contribute  to  achieving  the  2050  climate  neutrality  objective,  and  the  2030 
climate and energy targets, taking into account Poland’s national energy and climate plan. They 
should  also  contribute  to  meeting  environmental  targets  for  waste,  pollution  control, 
sustainable mobility, biodiversity protection and restoration, marine and water resources, and 
support the transition to sustainable food systems and to a circular economy as appropriate, 
while ensuring that nobody is left behind.  

To transition towards a climate neutral economy, Poland needs a progressive approach 
to  decarbonisation  and  energy  transformation.  The  Polish  economy  is  very  energy-
intensive and highly dependent on fossil fuels. Around 72% of electricity is still generated in 
conventional  coal  power  plants.  Comprehensive  planning,  timely  investment  as  well  as  the 
adoption of ambitious measures to support the energy transformation in line with the Green 
Deal are therefore essential. Lack of action in this respect would affect the competitiveness of 
the Polish economy in the coming decades due to, inter alia, increased energy costs. In addition, 
the reliance on fossil fuels hampers air quality, generating health problems and the associated 
health care costs. To address the issue, Poland should invest more in renewable energy, zero- 
and  low-emissions  heating  and  cooling,  energy  efficiency  improvements  in  buildings, 
replacement  and  phasing  out  of  inefficient  and  coal-based  district  and  domestic  heating, 
supporting energy savings and tackling energy poverty, as well as promoting zero- and low-

10 

 
 
 
 
emissions, smart and safe mobility and sustainable public transport. Moreover, more effort is 
needed in supporting investment in low-carbon innovation as well as energy- and resource-
efficiency  in  industry  sectors.  Enhancing  energy  system  integration  across  electricity  and 
heating, industry and transport sectors is also necessary. 

Transition towards a low-carbon economy 

Poland  is  still  one  of  the  most  energy-intensive  economies  in  the  EU,  despite 
improvements  over  the  last  years.  The  greenhouse  gas  emissions  intensity  of  the  Polish 
economy  is  one  of  the  highest  in  the  EU  due  to  the  coal-based  power  generation  and  the 
economy’s reliance on heavy manufacturing. Air quality stands among the lowest in the Union, 
posing major environmental and health concerns. Poland’s 2020 NECP shows that significant 
additional measures will have to be implemented to achieve the national 2030 greenhouse gas 
emissions reductions target – for sectors not covered by the EU Emissions Trading System – 
of 7% below 2005 levels. 

A  comprehensive  and  just  transition  to  a  climate-neutral  economy  calls  for  a  clear 
strategy to reduce Poland’s coal dependency. Coal-based fuels play a key role in electricity 
and heat generation, industry, transport and agriculture sectors. Industry accounted for 22% of 
the national emissions in 2017. This sector has a considerable potential to reduce emissions 
through, for example, the electrification of industrial processes and improvements in energy- 
and  resource-efficiency. Significant efforts  are  necessary  to  address  emissions  from  the 
transport sector, accounting for 15% of emissions in 2017 and increasing year on year primarily 
in road transport. This includes shifting towards zero- and low-emission mobility and notably 
shifting from roads to rail and other modes of sustainable transport. Poland should also consider 
decarbonising  the  agricultural  sector  which  accounted  for  around  10%  of  emissions  in 
2017. Finally, Poland should increase the share of renewables in energy production. 

Increasing the share of alternative zero or low-emission energy sources 

While the share of renewable energy has increased over the past years, Poland should 
accelerate  the  deployment  of  renewable  energy  in  order  to  contribute  to  the 
decarbonisation of the economy in line with the 2050 targets. Pursuant to the Renewable 
Energy Progress Report3, in 2018 Poland was identified as one of the few Member States that 
was at a severe risk of failing their 2020 renewable energy target. While the 2020 target has 
been met, further accelerated progress is needed in line with the Union’s new climate targets. 

To achieve climate neutrality Poland will need to significantly step up its ambitions by 
increasing energy production from renewable energy sources. Not only is the current 2030 
target  considered  unambitious  compared  to  the  applicable benchmark but  the  measures 
included in Poland’s 2020 National Energy and Climate Plan are considered insufficient even 
to achieve that target. The national contribution to the 2030 EU renewable energy target is 2-4 
percentage points below the share of 25% by 2030 based on the formula in Annex II of the 
Governance  Regulation. As  established  in  the  Commission’s  assessment  of  Poland’s  2020 
National  Energy  and  Climate  Plan 
(NECP), the  planned  policies  and  measures 
will not allow Poland  to  achieve  the  planned  renewable  electricity  consumption  of  32%  by 
2030. 

3 Renewable Energy Progress Report, COM(2020) 952 final 

11 

 
 
 
 
                                                           
Additional  measures  need  to  be  put  in  place to  incentivise  renewables. This  includes 
supporting large-scale installations, such as offshore wind where a dedicated support scheme 
is needed. To stimulate investments in onshore wind farms, the regulatory environment should 
be  improved  by  relaxing  distance restrictions  on  the  onshore  wind  installations that  were 
introduced in 2016. Further measures, notably a clear long-term auctioning plan, and support 
to facilitate the production of renewable gases (e.g. biomethane) and their injection into the gas 
networks should be explored, while an increase of renewables in heating should be coupled 
with the modernisation of the district heating network and building renovations. With regard 
to electricity  infrastructure,  the  integration  of  renewables  requires  the  strengthening  and 
expansion  of  transmission  and  distribution  lines  across  the  national  territory and  the 
development  of  storage  capacity.  Other  important  measures  include  the  setting  up  of  an 
enabling framework for renewable self-consumption and energy communities, and promoting 
market-based direct power purchase agreements (PPAs).  

Reducing energy consumption 

The poor energy efficiency of buildings is one of the key challenges in Poland impacting 
the level of energy consumption and air quality. Public and residential buildings often 
have  low  technical  standards  and  approximately  70%  of houses  are  poorly  insulated4. 
Poland’s  progress  towards  the  2020  indicative  national  energy  efficiency  targets  was 
considered  insufficient  for  primary  energy  consumption  and  for  final  energy  consumption. 
Although  the  level  of  ambition  has  been  increased  compared  to  the  2020  target,  Poland’s 
planned national contribution to the 2030 energy efficiency target is modest5.  

Air  pollution  is  a  major  environmental  challenge  across  Poland,  with  several  regions 
severely affected (e.g. Małopolska and Silesia). This pollution comes to a large extent from 
individual heating sources in residential buildings and from road congestion in urban areas. 
Around 3 million inefficient and polluting boilers need a replacement.  

District heating networks are often inefficient and heat generation is mainly coal-based 
(about 78%) with a limited coverage, especially in small and medium-sized towns. As 42% 
of  Polish  households  are  connected  to  district  heating  systems,  Poland  should  address  this 
challenge by phasing out coal-based heat sources and replacing them with less carbon-intensive 
sources. These investments should be combined with more connections of houses to district 
heating networks and with a reduction of heat demand by better insulating houses and other 
buildings. 

4 Castellazzi, L., Zangheri, P., Paci, D., Economidou, M., Labanca, N., Ribeiro Serrenho, T., Zancanella, P. and 
Broc, J., Assessment of second long-term renovation strategies under the Energy Efficiency Directive, EUR 29605 
ISBN  978-92-79-98727-4, 
EN,  Publications  Office  of 
doi:10.2760/973672, JRC114200; and  Zangheri,  P. et al.,  Progress of the Member States in implementing the 
Energy Performance of Building Directive, Publications Office of the European Union, Luxembourg, 2021, EUR 
30469, ISBN 978-92-76-25200-9, doi:10.2760/914310, JRC122347. See also European Commission SWD(2021) 
365 final/2 

the  European  Union,  Luxembourg,  2019, 

5 Economidou, M., Ringel, M., Valentova, M., Zancanella, P., Tsemekidi Tzeiranak, S., Zangheri, P., Paci, D., 
Ribeiro Serrenho, T., Palermo, V. and Bertoldi, P., National Energy and Climate Plans for 2021-2030 under the 
EU Energy Union, EUR 30487 EN, Publications Office of the European Union, Luxembourg, 2020, ISBN 978-
92-76-27013-3,  doi:10.2760/678371,  JRC122862.  See  also  Tsemekidi-Tzeiranaki,  S.,  Paci,  D.,  Cuniberti,  B., 
Economidou, M. and Bertoldi, P., Analysis of the Annual Reports 2020 under the Energy Efficiency Directive, 
EUR  30517  EN,  Publications  Office  of  the  European  Union,  Luxembourg,  2020,  ISBN  978-92-76-27416-2, 
doi:10.2760/180952, JRC122742 

12 

 
 
                                                           
Poland’s investment support schemes should be streamlined and better targeted, notably 
with respect to low-income households. Effective investment support should be coupled with 
a  proper  monitoring  and  control  of  existing  rules  and  standards,  e.g.  related  to  emission 
standards for local heaters and quality standards for fuels. The table below gives an overview 
of  Poland’s  objectives,  targets,  and  contributions  under  Regulation  (EU)  2018/1999  of  the 
European Parliament and of the Council of 11 December 2018 on the Governance of the Energy 
Union and Climate Action. 

Reduction of human impact on the environment 

The effects of climate change in Poland, in particular the sustained increase in average 
temperature and the growing intensity and frequency of extreme weather events, puts 
pressure  on  natural  resources,  the  economy  and  social  wellbeing.  Adapting  to  climate 
change and making the economy more resilient to its impacts both in the short- and long-term 
remains  a  major  challenge  for  Poland.  Urban  and  infrastructure  development  should  be 
adjusted for the expected impacts of climate change such as heat waves or floods. Similarly, 
agricultural  practices  and  rural  land  management  should  avoid  exacerbating  the  already 
prevailing impacts of climate change such as drought. 

Rural areas face challenges in the delivery of sustainable water and sanitation services. 
The prioritisation of investments needs to be improved to maximise the environmental benefits 
and cost-efficiency of projects. Water resources are increasingly scarce, also as a consequence 
of  climate  change.  The  retention  of  water  in  agricultural  areas  is  low,  in  particular  due  to 
existing,  inadequate  drainage  systems,  which  increase  the  water  outflow  and  aggravate  the 
consequences of droughts. Raising awareness of climate change impacts on the availability of 
water for agriculture should also be prioritised. 

The problems related to the presence of pollutants and hazardous waste accumulated in 
the past in a way that endangers human life or health are still present. The presence of 
hazardous  waste  in  the  environment  can  result  in  emissions  to  surface  and  groundwater, 
emissions to air, as well as pollution of land surfaces, and ultimately a risk to human health or 
life. In addition, remnants of the Baltic Sea seabed war remain a major challenge and pose a 
threat to the implementation of energy, marine and environmental projects. 

Finally, to support the green transition and avoid potential bottlenecks in achieving it, 
there is a need to enhance the development of relevant skills and to foster climate literacy. 
If  not  systematically  addressed,  Poland’s  relatively  low  proportion  of  graduates  in  Science, 
Technology,  Engineering  and  Mathematics  (STEM)  skills,  the  lack  of  education  in  ‘green’ 
skills and the generally low participation of the adult population in learning could undermine 
efforts in transforming the economy and society towards climate-neutrality. 

The  table  below  gives  an  overview  of  Poland’s  objectives,  targets  and  contributions  under 
Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 
2018 on the Governance of the Energy Union and Climate Action. 

13 

 
 
 
Table 2: Overview of Poland's energy and climate objectives, targets and contributions 

National targets and 
contributions  

Latest 
available 
data 

2020 

2030 

Assessment of 
2030 ambition 
level 

Binding target for greenhouse gas 
emissions compared to 2005 
under the Effort Sharing 
Regulation (%) 

National target/contribution for 
renewable energy: share of energy 
from renewable sources in gross 
final consumption of energy (%) 

21% 

14%  

-7%  

As in ESR 

11.3% 

15% 

21%-
23% 

Unambitious 
(25% is the 
result of the RES 
formula) 

National contribution for energy efficiency: 

Primary energy consumption 
(Mtoe) 

Final energy consumption (Mtoe) 

100.9 
Mtoe 

71.8 
Mtoe 

96.4 
Mtoe 

91.3 
Mtoe 

71.6 
Mtoe 

67.1 
Mtoe 

Modest 

Modest 

Level of electricity 
interconnectivity (%) 

4% 

4% 

8.7% 

N.A. 

Source: Assessment of the final national energy and climate plan of Poland, SWD 2020 920 final 

Sustainable transport 

The GHG emissions from transport in Poland have increased by 219% over the period 
1990-2019. This trend is largely driven by an increase in road transport traffic, and leads to 
significant  air  quality,  congestion  and  safety  issues.  It  is  thus  key  to  step  up  measures  to 
decarbonise road transport and promote clean modes of transport not based on fossil fuels. 

A comprehensive set of measures is needed to address transport-related emissions, urban 
congestion, and quality and coverage of public transport services. Even though some Polish 
cities  have  adopted  sustainable  urban  mobility  plans,  they  are  not  properly  implemented. 
Despite substantial investments in urban mobility, half of the inhabitants of urbanised areas 
have no direct access to public transport (average distance to public transport is 2 km), which 
hampers  its  use  and  lowers  the  mobility  of  many  inhabitants.  Between  2008  and  2018,  the 
length of regional and sub-urban bus lines in Poland decreased by more than 50%. As a result, 
around 65% of the rural population is devoid of public transportation. 

The modernisation of railway lines in Poland to TEN-T standards is still lagging behind. 
This  is  linked  to  the  unsatisfactory  technical  condition  of  rail  infrastructure,  capacity 
bottlenecks  and  lengthy  track  works  which  has  an  adverse  impact  especially  on  rail  freight 
competitiveness.  Passenger  rail  is  not  an  attractive  alternative  to  private  cars  due  to  a  low 
frequency of operations and an insufficient integration with other transport modes. Addressing 

14 

 
 
 
 
 
 
 
 
 
interoperability  is  particularly  important  for  long-distance  and  cross-border  freight  rail 
traffic. The focus of infrastructure investments in Poland should be on the completion of key 
sections and nodes of the rail TEN-T Core Network, especially rail Core Network Corridors. 
In  the  same  vein,  linking  rail  better  with  other  transport  modes  and  hubs  and  addressing 
accessibility  issues  would  contribute  to  modal  shift  and  support  environmental  priorities. 
Poland also lacks a comprehensive institutional set-up for the management of its approach to 
intermodal  transport,  including  its  governance,  and  does  not take  into  account functional 
interdependencies between investments in different transport modes. The swifter deployment 
of the European Rail Traffic Management System (ERTMS) is needed for increased safety and 
capacity, reduced maintenance costs for infrastructure, higher performance and creation of a 
seamless rail transport. 

The capacity and quality of road infrastructure in Poland have improved over the recent 
years,  contributing  to  significant  growth  in  road  transport,  but  also  to  an  associated 
increase in greenhouse gas emissions. Measures to stimulate the shift towards zero-emission 
mobility, sustainable public transport, and alternative fuels are needed. Access to charging of 
electro  vehicles  and  hydrogen  infrastructure  needs  to  be  developed,  being  one  of  the  main 
catalysers for the zero-emission mobility. 

Poland  has  improved  its  road  safety  in  recent  years,  but  still  reports  50%  more  road 
fatalities than the EU average. To enhance road safety, Poland should focus on enforcement, 
education campaigns, and the infrastructure protecting vulnerable road users. 

Poland  should  explore  its  potential  in  clean  hydrogen,  as  it  is  expected  to  play  an 
important role in replacing fossil-based hydrogen or fossil fuels, in particular in transport 
and industrial applications. The development of zero-emission hydrogen rolling stock would 
also offer a viable option complementing railway electrification in Poland. 

Digital dimension 

The recovery and resilience plan should contribute to Poland’s digital transition and at 
least 20% of the financial allocation needs to contribute to digital objectives. The measures 
in the plan should, inter alia, contribute to the digital transformation of the economic and social 
sectors  (including  public  administration,  public  services,  primary  and  secondary  school 
education, and the justice and health systems). The objective of the measures in the plan should 
be  to  improve  not  only  the  competitiveness,  but  also  the  resilience,  agility  and  security  of 
companies and public actors, while ensuring inclusiveness. 

Poland faces a number of challenges that slow down the digital transformation and its 
potential towards a higher value-added economy. Poland ranks 24th amongst EU Member 
States  in  the  Digital  Economy  and  Society  Index  (DESI)  2021. An integrated  and 
strategic approach to  connectivity,  RD&I,  digital  skills  and  the  broader  digitalisation  of  the 
economy is still needed to keep up with digital technological developments, reap the economic 
benefits of digitalisation and narrow digital gaps in education and society. 

Connectivity 

of 

terms 

broadband 

connectivity, 

In 
in 
meeting its targets. Although the coverage of networks capable of providing 30 Mbps speed 
or  higher  for  all  citizens  was  intended  to  be  achieved  by  2020,  this  has  not  been 
accomplished. While Poland continues to have the highest mobile broadband take-up in the EU 
and very competitive prices, fast internet is not yet available for all households (in 2020, 77% 
of households had access to fixed broadband) and many rural areas are not connected to fixed 

difficulties 

Poland 

faces 

15 

 
 
broadband at all. Although many legislative and administrative initiatives were taken to create 
a  better  basis  for  broadband  investments  (especially  the  'Mega-law'  which  implements  the 
Broadband  Cost Reduction  Directive  rules),  there  are  still  barriers  hampering  the  ultra-fast 
broadband roll-out, such as the uneven application of laws by local authorities, reluctance of 
the owners of power, sewage, and water networks to give access to power poles, and water and 
sewage infrastructure, obstacles in accessing buildings.  

Connectivity should be ensured to prevent a further deepening of the urban/rural divide 
and to enable the use of digital technologies. Priority should be given to ensuring access to 
Next  Generation  Access  broadband  infrastructure,  especially  in  rural  areas,  as  well  as  to 
strengthening  Broadband  Competence  Offices  at  national  and  regional  level. An  effective 
deployment of the 5G networks may be helpful in assuring reliable and fast connectivity in 
rural  and  remote  areas. However,  Poland  has  still  not  assigned  any  frequencies  in  the  5G 
pioneer  bands,  namely  the  700  MHz  and  3.6  GHz  bands,  keeping  the  total  harmonised  5G 
spectrum assignation at 0%. In order to accelerate the 5G network deployment, Poland should 
swiftly assign radio frequencies in the 700 MHz and 3.6 GHz bands on objective, transparent, 
pro-competitive,  non-discriminatory  and  proportionate  criteria,  in  accordance  with  the 
European Electronic Communications Code. 

Digital Skills   

Poland still faces significant challenges in improving basic digital literacy and advanced 
skills of the population. In 2019, only 44% of the adult population had at least basic digital 
skills. In 2020, ICT specialists represented a lower proportion of the workforce (3.4%) against 
the EU average (4.3%)  and women  constituted  only 15% of  ICT specialists. The education 
offered at post-graduate level in advanced digital skills is to be improved, as both the proportion 
of  master’s  programmes  and  the  proportion  of  places  offered  to  students,  with  contents  on 
cybersecurity, high-performance computing or data science are lower in Poland than the EU 
average. Only the proportion of masters in artificial intelligence is higher in Poland than in the 
EU6. These challenges create serious bottlenecks for developing a digital economy and society, 
as well as innovation and competitiveness, which is demonstrated by increasing skills gaps in 
the labour market. Public investments in life-long learning and upskilling are needed, given 
that  investments  by  Polish  enterprises  for upskilling  their workforce are comparatively 
low. Nevertheless, Polish enterprises have recently started investing more in ICT training for 
their employees, and 18% of them offered specialised ICT training to their employees in 2020, 
resulting in a significant increase from the previous year (13%). Poland has also continued the 
implementation  of national 
initiatives  on  digital  competencies,  but  neither  a  new 
comprehensive  digital  competences  strategy  nor  a  focused  digital  strategy  for  schools  have 
been  adopted  so  far. Despite  significant  efforts, various  elements  that  are  needed  to  ensure 
economy- and society-wide digital skills development are either not addressed in an integrated 
manner  or  lack  sufficient  ambition.  Particular  attention is  needed  to  ensure equal  access 
to quality education and  training, including  IT tools  and  equipment,  effective integration of 

6 Righi, R., Lopez Cobo, M., Alaveras, G., Samoili, S., Cardona, M., Vazquez-Prada Baillet, M., Ziemba, L.W. 
and  De  Prato,  G.,  Academic  Offer  of  Advanced  Digital  Skills  in  2019-20.  International  Comparison,2020 
JRC121680; Gomez Losada, A., Lopez Cobo, M., Samoili, S., Alaveras, G., Vazquez-Prada Baillet, M., Cardona, 
M., Righi, R., Ziemba, L.W. and De Prato, G., Estimation of supply and demand of tertiary education places in 
advanced digital profiles in the EU, 2020JRC121683 

16 

 
 
                                                           
ICT to enhance teaching and learning at all levels, as well as the development of the digital 
pedagogy competences of teachers. 

Digitalisation and innovation of SMEs   

Despite  efforts  undertaken  by  Poland  to  improve  the  level  of  digitisation  of 
businesses, companies  - particularly  small  enterprises  -  show  a  slow  uptake  of  digital 
technologies. Only 23.7%  of  Polish  companies  are  innovative,  against an  EU  average  of 
50.3%7. 52% of Polish SMEs have at least a basic level of digital intensity, which is slightly 
below the EU average of 60%. Compared to last year, Polish businesses slowly continue to 
take advantage of the opportunities offered by digital technologies. They are participating in 
online  commerce,  with  13%  of  SMEs  selling  online  and  5%  selling  across  border  to  other 
EU countries. However, only 10% of small enterprises are highly digitalised, compared to 50% 
of large companies. The share of high-tech exports has stagnated in recent years and skills gaps 
have  further  increased  the  challenges  faced  by  businesses for  improving  their  innovation 
capacity,  which  threatens  the  sustainability  of Poland’s  growth  model. Only around  10% of 
Polish  enterprises offer distance-working  arrangements,  which 
insufficient 
digitalisation and ability to adapt to new conditions. Advanced technologies are slowly gaining 
popularity  among  Polish  enterprises  with  15%  of  them  using  cloud solutions and  18% 
integrating AI technology in their operations. However, the number of AI firms over GDP in 
Poland  (0.58  firms  per  €  bn  GDP)  lies  below  the  EU  average  (0.71)  (JRC  AI  TES  Dataset 
20208). Meanwhile, only 14% of Polish enterprises actively use social media while 29% use 
electronic information-sharing. E-invoices and big data are not yet widely popular. Despite a 
high  share  of  graduates  in  science,  engineering  and  computing  (20.1%),  which  is in  line 
with the EU average, businesses have difficulties in hiring specialists, and in particular small 
businesses have limited access to specialised ICT training. 

indicates 

E-government and digital public administration 

Poland performs  below  EU  average in  the area of digital  public  services. The  level  of 
online interaction between public authorities and the general public shows only 49% of online 
users actively using e-government services (EU average 64%). On the availability of digital 
public services, Poland also scores below the EU average: only 65 out of 100 on digital public 
services for citizens, compared to the EU average of 75, and 67 out of 100 on digital services 
for businesses (EU average of 84). At the same time, positive developments can be seen with 
regard  to  open  data  maturity,  where  Poland  classifies  well  above  the  EU  average.  The 
development of e-services is an essential part of the digital transformation of the economy and 
public administration, at all levels of governance. Efforts are needed to support the use of ICT 
and the development of e-government. To modernise the public administration, including the 
civil  service,  investments  are  needed  in  product  testing  laboratories,  digitalisation  of  IT 
systems,  and deployment  of human resources and training programmes.  Only 28.6% of the 
municipalities  have  digitalised  studies,  plans  and  maps,  which  indicates  the  need  for 
investments in the digital capacity at local and regional level. 

7  2018  Community 
20210115-2 

Innovation  Survey,  https://ec.europa.eu/eurostat/web/products-eurostat-news/-/ddn-

8  Vazquez-Prada  Baillet,  M.,  Samoili,  S.,  Righi,  R.,  Cardona,  M.,  Lopez  Cobo,  M.  and  De  Prato,  G.,  Tecno-
Economic Segment, European Commission, 2020, JRC120287. https://data.jrc.ec.europa.eu/collection/id-0126 

17 

 
 
 
                                                           
 
Digital innovation 

To  capitalise  on  the  digital  transformation  and  reinforce  economic  resilience,  Poland 
needs  significant  reforms  and investments beyond digital  equipment  and  tools. The 
innovation capacity of the Polish  economy is under structural threat due to a weak R&D&I 
performance,  including  its  governance.  Structural  improvements  to  the  entire  innovation 
ecosystem are needed to facilitate  the  uptake  of  (digital)  technology  in  businesses, building 
on increased  access  to  internet  and  networks by businesses  and  households,  and  hence  to 
support productivity growth. This requires efforts e.g. to improve public-private cooperation 
and  support  structures  for  knowledge  transfer  between  science  and  businesses  (including 
through strengthening Technology Transfer Offices in universities with improved governance 
mechanisms),  support  for  (international)  R&D  projects,  and  more  broadly  improving  the 
coordination of innovation policies. 

Note: EU aggregate corresponds to EU27, based on 2021 DESI report 

Box 1: Progress towards the Sustainable Development Goals 

Sustainable Development Goals and the four dimensions underpinning the Annual 
Sustainable Growth Strategy 

The objectives of the Sustainable Development Goals are integrated  into the European 
Semester since the 2020 cycle. This provides a strong commitment towards sustainability in 
the coordination of economic and employment policies in the EU. In that respect, this section 
outlines  Poland’s  performance  with  respect  to  SDGs  with  particular  relevance  for  the  four 
dimensions underpinning the 2021 Annual Sustainable Growth Strategy and of relevance to 
the recovery and resilience plans (green transition, fairness, digital transition and productivity, 

18 

 
 
 
 
 
 
and macroeconomic stability), indicating possible areas where investments and reforms in line 
with the objectives of the Facility could further accelerate the progress on the SDGs. 

Green Transition 

Between  2014  and  2019  Poland  made  significant  progress  across  several  indicators 
underpinning SDG 7 (‘Affordable and clean energy’) and SDG 13 (‘Climate action’) but 
additional reforms and investments will be necessary to close the gap with the EU average 
in  a  number  of  those  areas.  While  the  greenhouse  gas  emissions  intensity  of  energy 
consumption decreased from 92 in 2014 (vs 2000 benchmark = 100) to 86 in 2019, this was 
still  significantly  above  the  EU  average  for  that  year  (82.7).  The  pace  of  improvements  in 
intensity was also not sufficient to offset an absolute growth in GHG emissions between 2013 
and 2018, arguably linked to strong economic growth. Most worryingly, Poland has been very 
slow  in  increasing  the  share  of  renewable  energy  consumption  in  gross  final  energy 
consumption which increased from 11.6% in 2014 to 12.2% in 2019, while for the EU average 
these  numbers  stood  at  17.5%  and  19.7%,  respectively.  Another  worrying  element  is  that 
emissions from transport in Poland have increased by 219% over the 1990-2019 period, largely 
due to road transport increase, and a continued decline in the share of public transport in total 
passenger transport. On a positive note, the share of the population unable to keep their home 
adequately warm more than halved between 2014 and 2019 and the air quality significantly 
improved. Nonetheless, for the latter indicator Poland needs additional efforts to narrow the 
gap with the EU average.  

Fairness 

Poland  has  made  progress  towards  achieving  SDGs  in  the  area  of  fairness,  although 
challenges remain. Between 2014 and 2019, under SDG 1 (no poverty) the share of people at 
risk of social exclusion decreased from 24.7% down to 18.2%, which is below the EU average 
of 20.9%. At the same time, in-work at-risk-of-poverty (9.7%) remains above the EU average 

19 

 
 
 
(9.0%).  A  positive  trend  is  visible  on  good  health  and  well-being  (SDG  3),  but  additional 
progress is required to move closer to the EU average on most indicators for this SDG.  For 
example, the self-reported unmet need for medical care decreased from 7.8% to 4.2% while the 
EU average is 1.7%. Poland performed relatively better than the EU average in most indicators 
measuring the reduction of inequalities (SDG 10). For instance, the adjusted gross disposable 
income of households per capita increased from 70% to 74% of the EU average. However, the 
decrease of the urban-rural gap for risk of poverty of social exclusion (from 13.4% to 11.1%) 
has only moderately contributed to closing the worrying gap with the EU average (1.1%). As 
regards gender equality (SDG 5), Poland made limited progress. It underperformed compared 
to the EU average for a majority of targets, such as the gender gap for tertiary education which 
went up from 18.8% to 19.9% between 2015 and 2020, well above the EU average of 10.8%. 

Digital transition and productivity 

Poland is underperforming compared to the EU average in most targets related to the 
digital  transition  and  productivity  dimension  reported  under  SDG  8  (Sustainable 
economic  growth)  and  SDG  9  (Industry,  innovation  and  infrastructure).  While  gross 
domestic expenditure on R&D has increased between 2014 and 2019 from 0.94% to 1.32% of 
GDP, it remains significantly below the EU average (2.11% in 2014 and 2.2% of GDP in 2019 
respectively).  The  number  of  patent  applications  to  the  European  Patent  Office  (EPO)  has 
decreased between 2014 and 2019 from 15 to 13 applications per million inhabitants. This is 
significantly below the EU average where during the same period the number of applications 
increased from 141 to 147 per million inhabitants. The Polish transport infrastructure exhibits 
connectivity  gaps,  especially  in  rail  TEN-T,  and  poor  environmental  and  safety  standards. 
Significant  investment  needs  are  identified  to  develop  a  sustainable  multimodal  mobility, 
including TEN-T and cross-border links. Road safety is a key issue: in terms of road fatalities 
per million inhabitants, Poland (75 in 2017) is significantly above the EU average (49 in 2017). 
Compared to 2010 the situation has considerably improved, but Poland is still clearly lagging 
behind the EU average. At the same time, Poland made significant progress towards increasing 
the  share  of  households  covered  by  a  high-speed  internet  connection  in  the  last  5  years, 
increasing 6 times its original value and surpassing the EU average by more than 5 percentage 
points. 

Macroeconomic stability  

Between  2014  and  2019,  Poland  has  made  significant  progress  across  most  indicators 
underpinning SDG 8 (‘Decent Work and Economic Growth’). Real GDP per capita growth 
averaged 3.6% per year between 2010 and 2019, gradually closing the GDP to the EU average 
and signalling steady progress in Poland’s convergence process. The share of young people 
neither in employment nor education and training has been decreasing steadily, from 15.5% of 
the total 15–29-year-old population in 2014 to 12% in 2019. The share of people in work at 
risk of poverty has also declined somewhat over the same period. Prior to the pandemic, public 
debt stayed below the Maastricht threshold of 60% of GDP, and even after the crisis remained 
slightly below, being significantly lower than the EU average. Still, several macroeconomic 
challenges  remain,  which  ask  for  well-targeted  reforms  and  investments.  First,  the  share  of 
investment  to  GDP has  declined significantly in  recent  years, hampering  Poland’s potential 
growth and ability to move up the value-chain in the medium term. Second, although labour 
market  developments  have  been  largely  favourable  since  2014,  with  the  employment  rate 
reaching 73% in 2019, pervasive labour shortages have been limiting investment activity and 
growth in Poland’s businesses, particularly SMEs.  

20 

 
 
 
3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN 

3.1. Overall strategy of the plan  

The  recovery  and  resilience  plan  of  Poland  is  a  comprehensive  response  to  the 
consequences  of  the  COVID-19  crisis,  as  well  as  a  response  to  the  main  challenges 
identified  and  systemic  weaknesses  of  the  Polish  economy.  The  plan  aims  to  rebuild  the 
growth  potential  of  the  Polish  economy,  to  enhance  its  competitiveness  and  to  increase  the 
standard of living of its citizens. The plan pursues the following objectives:  

  strengthening of innovative economic development to increase productivity, taking into 

account the green and digital transformation, 

  development of green and smart mobility, 
  enhancing  social  capital  and  upgrading  quality  of  life,  in  particular  by  ensuring  the 
improvement of citizens' health and higher quality of vocational education and skills 
adapted to the needs of the modern economy. 

The  Polish  recovery  and  resilience  plan  comprises  six  components  with  the  overarching 
objectives  of increasing  economic development  and productivity, supporting the digital  and 
green transitions and enhancing the quality of life. These components address challenges in the 
following areas: 

A. 

Resilience and competitiveness of the economy – where the aim is to build a crisis-
resilient economy, increase productivity and create quality jobs through: 

1.  Reducing the impact of COVID-19 and the subsequent crisis for businesses 
2.  Strengthening the innovation capacity and the cooperation between enterprises 
and  research  institutes  in  key  areas  for  the  development  of  the  economy 
(digitization and greening) 

3.  Improving skills development, the vocational education and training system and 

lifelong learning to better match needs of the modern economy  

4.  Increasing the labour market participation, the efficiency and crisis resilience of 

the labour market 

B. 

Green energy and energy intensity reduction – which is focused on the shift towards 
supporting renewables and generation of alternative fuels and energy efficiency to 
reduce the negative environmental impact and to ensure competitiveness and energy 
security coupled with greening of the economy through: 

1.  Improving the energy efficiency of the economy 
2.  Increasing  the  use  of  renewable  energy  sources  and  the  development  of 

alternative generation sources 

3.  Adapting to climate change and reducing its negative environmental impact 

C. 

Digital transformation – which is aimed at investing in modern technologies in the 
public sector, society, education and in the economy as a whole through: 

1.  Improving access to high-speed internet 
2.  Developing  and  consolidating  e-services,  creating  the  conditions  for  the 
development  of  digital  technologies  for  the  economy  and  improving 
communication between public institutions, citizens and business 

3.  Boosting digital skills and the digitalisation of education 

21 

 
 
 
 
4.  Increasing  cyberspace  security,  ensuring  and  digitising  safe  data  processing 

infrastructure 

D. 

Efficiency,  accessibility  and  quality  of  the  health  system  –  which  focuses  on 
ensuring a smooth functioning and modernisation of the healthcare system through: 

1.  Improving the efficiency of the health system, especially in the hospital sector, 
its accessibility and quality of health services, including by making more use of 
digital solutions  

2.  Developing  healthcare  staff  and  strengthening  the  capacity  of  medical 
universities  and  health  care  providers  involved  in  the  training  of  medical 
personnel  

3.  Supporting scientific research and the pharmaceutical sector to strengthen the 

resilience of the health system  

E. 

Green,  smart  mobility  –  which  aims  to  develop  a  sustainable,  safe  and  resilient 
transport system meeting the needs of the economy and society through:  

1.  Increasing  the  share  of  zero-  and  low-emission  transport  and  reducing  the 

negative environmental impact of transport 

2.  Enhancing  transport  accessibility  and  digitalisation  as  well  as  its  safety  and 

security 

F. 

Quality of institutions and conditions for the implementation of the plan – which 
aims  to  improve  the  investment  climate  and  put  in  place  the  framework  for 
implementing the plan through:  

1.  Strengthening the independence and impartiality of courts and remedying the 
situation of judges affected by the decisions of the Disciplinary Chamber of the 
Polish Supreme Court 

2.  Enhancing consultation  of social partners and the use of impact assessments, 

and reducing the use of fast-track procedures in the law-making process 

3.  Ensuring the proper consultation of social partners and stakeholders, as well as 
the application of the Arachne risk-scoring tool in  the implementation  of the 
plan  

The cost estimations of the measures are presented in the table below. 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table 3: Components and associated costs 

Component 

Costs (EUR million) 

Grants 

Loans 

Total (EUR 
million) 

A.  Resilience and competitiveness of the 

4,455 

245 

4,700 

economy 

B.  Green energy and energy intensity 

5,696 

8,172 

13,868 

reduction 

C.  Digital transformation 

D.  Efficiency, accessibility and quality of the 

health system 

E.  Green, smart mobility 

F.  Improving the quality of institutions and the 
conditions for the implementation of the 
RRP 

2,797 

4,092 

6,817 

0 

2,100 

289.5 

700 

0 

4,897 

4,381.5 

7,517 

0 

Total 

23,857 

11,506.5 

35,363.5 

3.2. Implementation aspects of the plan  

Consistency with other programmes 

The  plan  outlines  the  consistency  with  other  relevant  programmes.  The  main  strategy 
document at the national level to which the RRP refers is the Strategy for Responsible 
Development (with a 2030 perspective) adopted by the government on 14 February 2017. 
The  Strategy  focuses  on  jobs  and  growth,  with  the  main  objective  of  increasing  social, 
economic,  environmental  and  territorial  cohesion,  which  is  in  line  with  the  challenges  and 
priorities identified in the framework of the European Semester. The plan is also consistent 
with the National Energy and Climate Plan 2021-2030 submitted to the European Commission 
on 30 December 2019 and Poland’s Energy Policy strategy for 2040 (PEP2040), adopted by 
the government on 2 February 2021. The RRP also draws on several sectoral strategies adopted 
by  the  government  in  recent  years  in  the  areas  of  regional  development,  digitalisation, 
cybersecurity, sustainable agriculture, infrastructure, human and social capital.  

The  plan  is  designed  to  be  complementary  to  the  Union  Funds  both  in  the  current 
programming  period  (2014  –  2020)  as  well  as  in  the  new  programming  period  (2021-
2027). As the Partnership Agreement (PA) and the Programmes are still pending finalisation 
and approval, the plan explains the main synergies at a strategic level (between priority areas 
of  the  Cohesion  Policy  funding  and  RRP  components),  which  are  elaborated  in  individual 
components  by  indicating  areas  where  funding  from  other  sources  is  envisaged.  The  plan 
recognises  the  importance  of  synergies  with  Cohesion  policy  programmes  and  stresses  that 
complementarities and potential overlaps will be systematically and continuously assessed at 
different  levels  of  implementation  (including  at  strategic,  programme  and  project  levels)  to 
avoid double funding. 

Poland is the largest net recipient of Cohesion funds in the EU and, since its accession in 
2004,  the  country  has  developed  an  efficient  administrative  capacity  in  this  respect. 

23 

 
 
 
Poland’s absorption capacity as regards EU funding is much above the EU average. Despite 
significant achievements in addressing structural problems, investment needs in Poland are still 
much  higher  than  available  funds,  in  particular  regarding  infrastructure,  innovation,  digital 
economy, human capital and health care. Moreover, the green transition poses an immediate 
and very costly challenge for the economy.  

Administrative organisation of the RRP    

The Ministry of Development Funds and Regional Policy, which is also in charge of the 
programming of the Cohesion policy, coordinates the preparation and implementation of 
the  plan.  Other  ministries  that  are  actively  involved  in  the  process  include  the  Ministry  of 
Economic Development, Labour and Technology, which coordinates the European Semester, 
the  Ministry  of  Finance,  the  Ministry  of  Climate  and  Environment,  the  Ministry  of 
Infrastructure, the Ministry of Health, and the Chancellery of the Prime Minister. Moreover, 
the  plan  has  been  prepared  in  in  consultation  with  local  governments,  social  and  economic 
partners and NGOs.  

To ensure effective implementation, the same implementing structure will be used for the 
RRP  as  for  the  Partnership  Agreement.  The  use  of  the  institutional  system  of  Cohesion 
policy  for  the  programming  and  implementation  of  measures  under  the  RRP  is  expected  to 
enable synergies between the programmes and to avoid double-funding for the same initiatives. 
The  institutions  involved  in  the  programming,  implementation,  monitoring  and  control  of 
Cohesion  policy  actions  have  the  administrative  capacity  and  the  institutional  experience 
necessary to carry out RRP-related tasks. To ensure the correct implementation of the plan, 
Poland  will  set  up  a  Monitoring  Committee  composed  of  representatives  of  the  institutions 
involved in the implementation of the plan, as well as a wide representation of stakeholders 
including trade unions, employers’ and non-governmental organizations.  

The  Technical  Support  Instrument  (TSI)  provides  expertise  in  building  capacities  to 
implement  the  plan  in  a  number  of  areas.  In  particular,  this  concerns  support  for  the 
implementation of green, digital and public administration RRP measures. For instance, TSI is 
providing  support  for  the  implementation  of  the  programme  for  the  development  of  digital 
competences,  and  for  boosting  the  competitiveness  of  the  railway  sector  to  promote  green 
mobility and socio-economic convergence. In addition, TSI continues to support the reform of 
the budgetary system (measure A1.1 Reform of the fiscal framework), in particular by assisting 
in setting out new budget classification. During the implementation of the plan, sectoral support 
for the design, implementation and evaluation of research and innovation policy reforms will 
be available via the Horizon Policy Support Facility. 

Gender equality and equal opportunities for all 

With  regard  to  gender  equality  and  equal  opportunities  for  all,  Poland  indicates  that 
horizontal principles guide all initiatives under the plan, in line with the European Pillar 
of Social Rights. Poland describes the impact of the COVID-19 crisis on various groups and 
the challenges related to gender equality and equal opportunities for all, in particular in view 
of labour market needs. The plan contains specific measures to address equality challenges, for 
instance by increasing the quality and availability of childcare facilities to facilitate the labour 
market participation of women. Poland has indicated that a pre-screening of different projects 
was made with equality criteria in mind, and that certain projects that were proposed were not 
included in the plan as they did not meet accessibility criteria for persons with disabilities or 
were otherwise not compliant with equality principles. Poland stresses that the principles of 
gender equality and equal opportunities for all will be taken into account at every stage of the 

24 

 
 
management  and  implementation  of  the  plan.  Finally,  the  monitoring  committee  tasked  to 
supervise  the  effective  implementation  of  the  plan  will  notably  include  representatives  of 
bodies representing the civil society and promoting fundamental rights and non-discrimination. 

Stakeholder consultation 

Poland  carried  out  stakeholder  consultations  through  different  platforms  prior  to  the 
submission of its RRP. The public consultation process was based on the provisions of the 
Development  Policy Act of 6 December 2006.  The public consultation of the RRP was 
launched on 26 February 2021 and lasted until 2 April 2021. In total, 5 275 contributions 
were made in a dedicated form on the government website. In addition, comments were voiced 
during  three  debates  organised  by  the  government  and  five  public  hearings  led  by  social 
partners and other organisations. The draft RRP was also discussed by the Joint Government 
and  Local  Government  Commission  (pol.  Komisja  Wspólna  Rządu 
i  Samorządu 
Terytorialnego). During the work of this commission, local governments submitted over 520 
comments. In the framework of the Social Dialogue Council, the government also consulted 
social partners on the RRP. As a result of the stakeholders' consultations, changes were made 
to all components of the draft RRP. In particular, the planned reform of spatial planning was 
amended, and the investments in  offshore wind farms and in  the digitalisation of education 
were enhanced, and investments in green urban transition were added 

Security self-assessment  

The RRP does not contain a security self-assessment for investments in digital capacities 
and connectivity, in accordance with Article 18(4) point (g) of Regulation (EU) 2021/241. 
Poland does not identify any security issues nor does it provide any detail on how potential 
security risks could  be  addressed in  order to  comply with  relevant  Union and national  law. 
However, Poland has indicated throughout the plan that projects related to digital technologies 
will  be  carried  out  in  accordance  with  high  cybersecurity  standards,  in  line  with  the  Polish 
Cybersecurity Strategy 2019-2024, adopted by the Council of Ministers on 22 October 2019. 
The  main  objective  of  the  Strategy  is  to  increase  the  level  of  cyber-resilience  and  data 
protection  in  the  public,  private  and  military  sector.  Furthermore,  the  RRP  indicates  that 
connectivity measures will be implemented in line with national and European legislation, and 
in accordance with the EU Connectivity toolbox. 

Cross-border and multi-country projects 

The plan envisages the involvement of Poland in the multi-country project Common Data 
Infrastructure  and  Services  in  the  area  of  data  processing.  This  multi-country  project  is 
expected to be implemented as a potential  Important Project of Common European Interest 
(IPCEI) on Next Generation Cloud and Edge Infrastructure and Services. The European project 
aims at developing and industrially deploying for the first time highly innovative, ultra-secure 
and energy-efficient cloud and edge solutions that enterprises, public administrations and end-
users are demanding for making sustainable businesses and delivering better public services to 
citizens. 

Communication strategy 

The  communication  on  the  Polish  RRP  will  be  carried  out  in  coherence  and 
complementarity  with  the  communication  on  other  EU  Cohesion  policy  support 
instruments.  This  will  allow  for  a  comprehensive  and  complementary  presentation  of  EU 
support to Poland. The government’s communication activities will focus on the results of key 
investment  projects  and  structural  reforms.  Any  added  value  of  EU  support  to  reforms  and 

25 

 
 
investments will be underlined. Communication activities are coordinated and carried out by 
the Ministry of Development Funds and Regional Policy, in cooperation with other ministries 
and  actors  involved  in  the  implementation  of  the  RRP,  as  well  as  social,  economic,  non-
governmental organisations and beneficiaries. Beneficiaries of the RRP will also be obliged to 
communicate about their projects to achieve synergies in this respect. The aim will be to ensure 
a high level of awareness of the country’s development activities with the help of the European 
Funds and the role it plays in the EU. Various communication tools and channels will be used 
for the specified target groups. Coordination between EU and national authorities should be 
pursued  to  maximise  the  impact  and  effectiveness  of  communications.  Communication 
activities on RRP will be subject to continuous assessment and monitoring by the authorities. 

State aid 

State aid and competition rules fully apply to the measures funded by the Recovery and 
Resilience Facility. Union funds channelled through the authorities of Member States, like the 
RRF funds, become State resources and can constitute State aid if all the other criteria of Article 
107(1) TFEU are met. When this is the case and State aid is present, these measures must be 
notified and approved by the Commission before Member States can grant the aid, unless those 
measures are covered by an existing aid scheme or comply with the applicable conditions of a 
block exemption regulation, in particular the General Block Exemption Regulation (GBER) 
declaring certain categories of aid compatible with the internal market in application of Articles 
107 and 108 TFEU. When State aid is present and it requires notification, it is the duty of the 
Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance  with  Article  108(3) TFEU.  In this respect,  the State aid  analysis  carried out  by 
Poland in the recovery and resilience plan cannot be deemed a State aid notification. As far as 
Poland considers that a specific measure contained in the recovery and resilience plan entails 
de minimis aid or aid exempted from the notification requirement, it is the responsibility of 
Poland to ensure full compliance with the applicable rules. In addition to complying with EU’s 
State  aid  rules,  measures  taken  under  this  framework  should  be  compatible  with  the  EU’s 
international obligations, in particular under World Trade Organization rules. 

4.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

4.1. Comprehensive  and  adequately  balanced  response  to  the  economic  and  social 

situation 

Poland’s recovery and resilience plan provides a comprehensive and balanced response 
to the consequences of the COVID-19 pandemic, while tackling various structural socio-
economic challenges (as detailed in section 4.3 of this document). As such, it makes an explicit 
reference to the six pillars of the Recovery and Resilience Facility pursuant to Article 3 of the 
Recovery and Resilience Facility Regulation. In accordance with Article 4 of that Regulation, 
the objective of the recovery and resilience plan is to promote economic, social and territorial 
cohesion  by  increasing  resilience,  crisis  preparedness,  adaptability  and  growth  potential, 
mitigating the social and economic consequences of the crisis, in particular for women (and 
thereby achieving the objectives of the European Pillar of Social Rights). The plan also aims 
at supporting the green transition, contributing to the Union’s climate objectives, and digital 
transformation. Thereby, interventions envisaged in the recovery and resilience plan support 
the  EU’s  objectives  of  increasing  socio-economic  convergence,  restoring  and  promoting 
sustainable growth and integration of EU economies, as well as the creation of quality jobs, the 
strategic autonomy of the Union and an open economy generating European added value. 

26 

 
 
 
Green transition 

The  Polish  recovery  and  resilience  plan  identifies  key  challenges  of  Poland  related  to 
climate  and  environment.  It  emphasises  that  Poland’s  economy  is  heavily  based  on  solid 
fossil fuels as well as oil and petroleum products and while their share in the energy mix has 
been  steadily  declining  it  was  around  72  %  in  2019.  The  installed  capacity  in  the  national 
electricity system at the end of 2019 was close to 46.8 GW gross, of which almost 36.7 GW 
are conventional  power plants, mostly based on hard coal  and lignite. Rising prices of CO2 
allowances contribute to rising energy prices, which together with a high energy intensity of 
the economy and a low level of energy efficiency of buildings lead to the risk of increased 
energy poverty and a noticeable rise in the prices of products and services, as well as a negative 
impact on the competitiveness of the economy. Against this background, the energy transition 
towards a climate-neutral economy is a key challenge for Poland. 

Poland’s recovery and resilience plan is strongly oriented towards the green transition. 
This is reflected in the high share of climate-related investments in the overall plan (estimated 
at 42.7%). Major investments will be directed towards developing offshore wind on the Baltic 
Sea; the renovation of buildings combined with replacing coal-fired heaters; the construction 
of new buildings of more ambitious standard than Nearly-Zero Energy Buildings; developing 
hydrogen infrastructure and technologies; investing in efficient district heating systems; clean 
urban projects, sustainable water management in rural areas and sustainable public transport.  

The  sustainability  focus  of  the  plan  is  reinforced  by  the  inclusion  of  a  number  of  key 
reforms. These reforms  will notably include the  removal of barriers to  the development  of 
onshore wind, a comprehensive set of measures aimed at phasing out coal in individual heating, 
and  a  regulatory  framework  to  support  the  development  of  hydrogen  technologies  and 
alternative fuels. To provide investors with greater predictability and allow for longer advance 
planning a plan of auctions will be published. The new database of heat sources in buildings 
will increase the reliability and completeness of information about building stock.  

Reforms to promote clean modes of transport, sustainable urban mobility and substantial 
investments  shall  contribute  to  decarbonisation,  digitalisation  and  safety  of  transport. 
The reforms include higher incentives for the development and implementation of sustainable 
urban mobility plans, incentives for promoting zero-emission vehicles and reducing the use of 
polluting  vehicles  in  line  with  “polluter  pays”  principle,  road  safety  measures  (e.g. 
enforcement, elimination of blackspots, investments), and incentives for clean vehicles. The 
investments are focused on railways, zero-emission rolling stock for both urban and inter-urban 
transport,  investment  in  public  transport,  digitalisation  of  road  (ITS)  and  railways  transport 
(ERTMS). 

The recovery and resilience plan is expected to contribute to the long-term resilience of 
ecosystems to climate change. Increasing the availability of water and sewerage infrastructure 
in rural areas with the biggest deficits should contribute to improving the quality of life of the 
population  living  there.  The  reforms  and  investments  will  create  a  framework  for  a  more 
efficient management of water resources and increase the landscape’s water retention capacity 
in rural areas. Investments improving water retention within agricultural or forest land should 
improve the water balance and increase the availability of water for agriculture and forestry.  

These reforms and investments are expected to significantly contribute to the 2030 and 
2050 climate objectives. Although the plan does not quantify this impact, measures included 
in  the  plan  can  be  reasonably  expected  to  accelerate  Poland’s  transition  towards  greater 
sustainability.   

27 

 
 
Digital transformation 

Despite positive developments in recent years, Poland still lags behind the EU average on 
digital indicators ranking 24th out of 27 EU Member States in the Digital Economy and 
Society Index (DESI) 2021. The country continues to perform weakly in integration of digital 
technology and use of internet services, which remain the most challenging areas. The human 
capital dimension is still underdeveloped, with only 44% of the population having at least basic 
digital skills. Noteworthy is also the lack of female ICT specialists (only 0.9%). However, in 
connectivity  Poland  ranks  among  the  best  performers  in  the  EU,  thanks  to  the  significant 
progress on the fixed very high-capacity networks coverage (60% compared to 29% one year 
earlier). 

The Polish recovery and resilience plan assigns to digital challenges 21.3% of the overall 
RRF allocation and presents a good mix of interventions to make progress with better 
digital administration and e-services, ranging from infrastructure, skills of public sector 
employees, efficiency of administrative processes, and an improved analytical  capacity 
for decision-making. The outlined actions aim at ensuring access to high-speed internet for 
citizens,  boosting  the  digital  efficiency  of  the  public  sector,  the  economy  and  society,  and 
improving the security of digital services. This should be achieved through investments in the 
broadband  network,  particularly  to  cover  white  next-generation-access  (NGA)  areas,  by 
strengthening the use of digital processes in the administration and by improving digital skills 
across all sectors of society. With regard to the interaction between public institutions, citizens 
and businesses, the creation of user-friendly information systems should reduce the time and 
financial costs of communicating with the state and improve a wide range of public services. 
The cyber-resilience of the public administration is also improved. 

The reforms and investments are expected to reduce digital exclusion through upskilling 
and  reskilling  of  e-competences  and  increasing  opportunities  for  teleworking  and 
learning.  Increasing  digital  skills  of  the  population  is  a  key  element  for  digitalising  the 
economy. The Polish RRP takes a holistic and strategic approach to the acquisition of digital 
competences of the wider population and to the digitalisation of education and training. The 
proposed  measures  contribute  significantly  to  the  creation  of  a  broader  digital  learning 
ecosystem and aim at an efficient coordination of the development of digital competences at 
national and local level. The investments in digital infrastructure and equipment for general 
and vocational schools, together with boosting the skills of teachers, should create the basis for 
the  development  of  digital  and  information  skills  in  the  society.  Improved  access  to 
technologies  and  e-competence  training  for  a  wide  group  of  citizens  should  connect  the 
digitally  excluded,  in  particular  inactive  people,  and  help  their  re-integration  into  an 
increasingly digital society.  

Digital investments are expected to contribute to the ambition to modernise Poland across 
all components of the recovery and resilience plan. The roll-out of three new central digital 
services, including decision-making support tools for doctors based on AI algorithms, and the 
launch  of  a  central  repository  of  medical  data  are  likely  to  contribute  to  the  efficiency  and 
accessibility of healthcare services for all citizens. In the area of energy, the development of 
smart grids will allow for a better integration of renewables into the Polish electricity system, 
while  battery  storage  systems  are  expected  to  contribute  to  ensuring  the  local  stability  of 
supply, contributing thus to strategic energy independence as well as cleaner air in Poland. In 
the  transport  sector,  the  plan  includes  measures  improving  the  efficiency  of  road  and  rail 
transport through digitalisation via  ITS, ERTMS, and remote and traffic  control systems.  It 
also includes incentives to deploy single e-ticketing for railway passengers. Finally, several 
measures include support for the digital transition in the agriculture and agri-food sectors, in 

28 

 
 
particular by encouraging the uptake of Agriculture 4.0 solutions, which is expected to increase 
the efficiency and sustainability of the sector. 

Smart,  sustainable  and  inclusive  growth,  including  economic  cohesion,  jobs,  productivity, 
competitiveness, research, development and innovation, and a well-functioning single market 
with strong SMEs 

The plan presents targeted policy actions across various relevant policy areas related to 
smart, sustainable and inclusive growth. Smart growth will be promoted particularly through 
actions targeting innovation and digitalisation as well as through improvements in the business 
environment,  educational  outcomes  and  labour  market  relevance  of  skills.  As  regards 
sustainable growth, the plan’s key investment initiatives are expected to contribute inter alia 
to a cleaner energy mix, industrial decarbonisation and greening of public transport.  

The plan is expected to help tackle challenges in the labour market. The pandemic had a 
limited impact on the Polish labour market, mainly thanks to sizeable policy support, which 
prevented a rise in unemployment and bankruptcies. Still, job losses occurred mainly in the 
services sectors, particularly in the hospitality and food sector, affecting a significant share of 
the low-skilled workforce. The plan is expected to support the labour market by rolling out 
investments into green construction sector activities (both new constructions and renovations), 
renewables, nature protection, sustainable transport and digital  infrastructure. The plan  also 
includes various measures to incentivise an increase in labour market participation of various 
groups, as well as efforts to align education (in particular vocational education and training) 
with modern labour market needs. This will be particularly relevant for tackling labour and 
skill shortages, which are currently limiting the ability of the Polish economy to restructure 
towards more productive and higher growth sectors. Furthermore, the plan includes measures 
that are expected to increase the competitiveness and resilience of the sectors most affected by 
the crisis, especially the HoReCa and culture sectors, in particular by investing in re-skilling 
and up-skilling for employees in these sectors.  

Research and Innovation reforms and investments will contribute to strengthening the 
competitiveness  of  the  Polish  economy  in  the  medium  to  long  run.  The  level  of  R&D 
expenditure,  despite  an  increase  in  recent  years  relative  to  GDP  (up  to  1.32  %  in  2019),  is 
below  the  EU  average  (2.19  %  in  2019).  The  plan  rightly  identifies  Poland’s  structural 
challenges and the need for innovation-driven growth. Higher investment into R&D alongside 
other intangible assets could contribute to resilience against unfavourable economic shocks. 
Reforms  and  investments  focus  on  strengthening  the  links  between  industry  and  research 
organisations  and  education  facilities,  as  well  as  supporting  pilot  projects  to  facilitate  the 
development of breakthrough technologies in advanced stages of R & D projects. To accelerate 
the  process  of  robotisation  and  automation,  in  addition  to  supporting  investments,  the  plan 
foresees fiscal incentives for the industry.  

A series of reforms and investments are expected to contribute to strengthening Poland’s 
competitiveness  through  more  research  and  innovation  and  an  improved  business 
environment. The plan identifies the productivity-related challenges for Poland and the need 
for innovation-driven growth, while aiming at closing the gap vis-à-vis the EU average in terms 
of  living  standards.  Support  for  cooperation  between  science  and  industry  will  improve 
research commercialisation and ensure a better implementation of innovative solutions as well 
as support the development and dissemination of innovations in the agri-food sector. The set-
up of Sectoral Skills Centres is also expected to contribute to better links between vocational 
education and training and the economy and improved dissemination of innovative solutions. 
Several  investments  linked  to  decarbonisation  efforts  (such  as  the  development  of  offshore 

29 

 
 
wind farms and unlocking the potential of onshore wind, hydrogen technologies and alternative 
fuels, and energy storage facilities) are expected to strengthen the competitiveness of the Polish 
industry  and  to  support  the  required  green  transition.  Improvements  in  the  business 
environment through the lowering of administrative burdens are expected to boost investment. 
Furthermore, the proposed reforms to enhance the use of public consultations in policymaking 
and reduce the use of fast-track procedures in law-making are expected to lead to a better and 
more stable regulatory framework, which may also improve the investment climate. Finally, 
measures aiming to strenghten the independence and impartiality of courts, and to remedy the 
situation  of  judges  affected  by  decisions  of  the  Disciplinary  Chamber,  are  also  expected  to 
contribute to improving the investment climate.  

The reforms in the plan are expected to contribute to a well-functioning Single Market 
with strong SMEs. The Polish Recovery and Resilience Plan includes a number of measures 
targeted at SMEs which are expected to have a lasting impact on the Polish economy where 
SMEs  account  for  more  than  42%  of  total  employment.  SMEs  in  the  agri-food  sector  will 
particularly benefit from investments to enhance their competitiveness and give a push to the 
green and digital transition in their activities. SMEs in the HoReCa, culture and tourism sectors 
are  set  to  benefit  from  investments  in  reskilling,  which  can  lead  to  increased  productivity 
growth and competitiveness in the medium term. SMEs and mid-caps can also benefit from 
financial  support  from  the  Recovery  and  Resilience  Facility  to  innovate  and  produce  low-
emission mobility and alternative energy solutions. Indirectly, SMEs will also benefit from a 
strong demand impulse triggered by other investments as well as improved infrastructure. For 
example, the investments to increase access to high-speed internet are expected to improve the 
competitiveness  of  SMEs  and  support  innovation,  particularly  in  remote  areas.  Overall,  the 
plan is  expected to  contribute to  achieving the objectives of the new  Industrial Strategy  for 
making the EU industry more competitive globally, enhance strategic autonomy and fostering 
the twin transition9. 

Social and territorial cohesion 

The  plan  addresses  the  marked  social  and  territorial  cohesion  challenges  primarily 
through  measures  in  the  areas  of  digitalisation  of  education,  skills  development  and 
healthcare services, as well as social housing. Investments to provide students and teachers 
with ICT equipment and support for the development of digital skills are expected to create 
opportunities for pupils from  disadvantaged regions and persons at  risk of social exclusion. 
Other digitalisation measures are also likely to improve social and territorial cohesion, such as 
investments in the development of network infrastructure to cover ‘white spots’ in broadband 
access  and  the  development  of  5G  technology  in  market  failure  areas,  as  well  as  measures 
aiming at increasing the availability of digital public services. The creation of a network of 
sectoral skills centres and of regional coordination teams for vocational training and lifelong 
learning are expected to support upskilling and reskilling in the regions, in close cooperation 
with  all  local  and  regional  stakeholders  in  education  and  the  labour  market,  to  maximise 
benefits for labour market participation. A new network of local digital leaders will support 
each municipality (‘gmina’) in the digitalisation efforts and will also contribute to social and 
territorial  cohesion  and  digital  inclusion.  Relevant  measures  in  the  area  of  health  include 
steering and financing the restructuring of hospitals, including regional hospitals, in accordance 
with  their  specific  needs.  The  development  of  e-health  solutions,  including  launching  three 
central digital services, is also expected to lead to increased accessibility of health services. 

9  COM(2020)  102  final,  https://ec.europa.eu/info/sites/info/files/communication-eu-industrial-strategy-march-
2020_en.pdf 

30 

 
 
                                                           
Finally, social cohesion is set to be enhanced by the spatial planning reform in municipalities, 
which, among others, introduces the requirement to land-developers to build social services for 
citizens. Moreover, measures to extend social security coverage of non-standard contracts are 
likely to address the segmentation of the labour market and to ensure a better social protection 
for certain workers. Poor access to affordable housing will be addressed by investment support 
to the development of housing for low- and average-income households. 

Measures  in  the  energy  and  sustainable  transport  components  are  also  expected  to 
contribute to social and territorial cohesion. Investments in sustainable urban transport are 
expected to accelerate the green transition of cities by implementing sustainable urban mobility 
plans and developing zero-emission public transport in cities and at regional level. Measures 
aimed  at  increasing  the  availability  of  water  and  sewerage  infrastructure  in  rural  areas  are 
expected to improve the quality of life in those regions. The plan includes measures focused 
on strengthening the resilience of rural areas to crises, including by increasing the potential of 
sustainable water management in rural areas that should reduce effects of recurrent excess or 
water  scarcity,  prevent  floods  in  agricultural  areas  and  increase  water  retention  levels. 
Investments in the agriculture sector further contribute to territorial cohesion, in particular due 
to investments that diversify and shorten the supply chain of agricultural and food products and 
build the resilience of the entities in the chain. Furthermore, investments in risk mitigation and 
the restoration of large-scale brownfield sites will enable relaunching economic activities in 
the concerned areas. Investments in low and zero-emission rolling stock for bus connections in 
areas with poor transport accessibility are expected to help connect remote regions to centres 
of  economic  activity,  which  is  also  expected  to  benefit  labour  market  participation  across 
regions. Finally, the renovation and improvement of the energy efficiency of family homes and 
public buildings will contribute to addressing energy poverty among households with limited 
incomes.  

Health, and economic, social and institutional resilience, with the aim of, inter alia, increasing 
crisis preparedness and crisis reaction capacity 

The recovery and resilience plan identifies the structural and post-pandemic challenges 
for  the  Polish  health  system  and  outlines  a  comprehensive  reform  and  accompanying 
investments for the health sector. The plan includes a detailed stocktaking of challenges, both 
in terms of recovery from the Covid-19 health crisis and of increasing the long-term resilience 
of the health system. Measures aim at improving access to healthcare and disease prevention, 
the availability of resources in the health system, progress in the digitisation of health care, and 
addressing  staff  shortages,  as  well  as  addressing  shortcomings  in  health  infrastructure  and 
pharmaceuticals  combined  with  support  for  research  and  innovation  activities.  The  plan 
provides for a significant health sector reform, addressing the entire spectrum of the pyramid 
of care, including primary, ambulatory and hospital care. Poland’s main objective in this area 
is to increase the effectiveness, accessibility and quality of the health system. To this end, large 
investments to support the reform of the hospital sector are envisaged, with lasting effects on 
care  provision  (including  community-based  long-term  care  and  investment  in  rehabilitation 
facilities), quality of outcomes, and the financial sustainability of hospitals. Complementary 
funding  from  other  sources  should  guarantee  necessary  investments  in  primary  care.  The 
investments are also expected to help increase the supply of qualified staff and digitalisation 
of healthcare services. In addition to addressing current structural challenges, these measures 
are also expected to increase the capacity of the sector to respond adequately to future crisis 
situations. 

The Polish plan aims at enhancing the economy’s resilience and crisis response capacity 
with investments in green solutions, education and skills, digitalisation and innovation in 

31 

 
 
companies.  The  investment  in  decarbonisation,  such  as  the  development  of  offshore  wind 
farms or hydrogen technologies, will contribute to creation of new jobs and facilitate the energy 
transition  towards  a  green  and  more  competitive  economy.  Increasing  digital  skills  and 
investment in digital competences through, inter alia, digitalisation of education, will result in 
a better match with post-pandemic labour market requirements and employers' expectations. 
The  competitiveness  of  Polish  companies  will  be  strengthened  with  measures  accelerating 
robotisation  and  facilitation  of  deployment  and  diffusion  of  breakthrough  technologies  and 
innovative solutions,  in  particular in  the areas of circular economy  and  unmanned aviation. 
These measures are expected to adjust Poland’s economy to post-pandemic challenges, making 
it more competitive and resilient.  

Poland  has  committed  to  introduce  various  measures  contributing  to  increasing  social 
resilience. Measures envisaged for further development of childcare and long-term care are 
expected  to  improve  the  labour  market  participation  of  women  (learning  and  well-being  of 
children below the age of 3), as well as access to long-term care services as a consequence of 
policy initiatives coming from a strategic review of long-term care policies, as well as targeted 
measures in the health sector. Measures improving the quality and adequacy of the functioning 
of labour market institutions, in particular Public Employment Services, reaching out to and 
activating  older  workers  or  people  from  disadvantaged  groups  through  up-  and  reskilling 
programmes, and attracting and integrating labour migrants as well as promoting flexible forms 
of employment and methods of providing services are likely to build resilience of the labour 
market.  Moreover,  extending the obligation  for social security  contributions  to  all civil  law 
contracts is expected to further reduce the segmentation of the labour market and to provide 
better  social  protection  to  certain  groups  of  employed.  Personal  income  tax  reductions 
envisaged for taxpayers reaching the statutory retirement age and deciding to continue working 
aim at extending careers and are expected to help decrease income inequalities for the elderly. 
Finally, significant support is being directed to farmers, which is expected to enhance territorial 
cohesion and reduce inequalities in rural areas. 

Poland’s  institutions  and  public  sector  are  expected  to  be  enhanced  due  to  measures 
reducing  certain  administrative  barriers,  improving  the  law-making  process  and 
strenghtening the independence of the judiciary. Digitalisation processes envisaged for the 
public  sector,  including  digital  identity,  digital  signature,  structured  electronic  invoice,  up-
graded and new e-services, are to bring durable results and diminish the administrative burden. 
A reform package speeding-up and simplifying administrative decisions, will increase business 
confidence,  particularly  for  SMEs.  Enhancing  the  role  of  public  consultations  in  the  law-
making process is likely to increase the stability of the regulatory framework and contribute to 
mitigating uncertainty for consumers and businesses. Strengthening the independence of the 
judiciary is expected to contribute to a more friendly and predictable investment climate.  

Policies for the next generation, children and the youth, such as education and skills  

Among the socio-economic challenges for the next generation, reforms and investments 
included  in  the  plan  focus  predominantly  on  education  and  skills.  The  plan  presents  a 
number  of  measures  with  a  direct  impact  on  children  and  young  people.  Reforms  and 
investments to improve the availability and quality of childcare aim at improving the education 
and care of children from a young age. An increase in the capacity of childcare facilities is 
expected to improve the rate of attendance of children up to the age of three, while quality and 
educational standards are expected to be set through a dedicated reform. 

Targeted investments will provide pupils and teachers with modernised ICT equipment 
and accelerate the improvement of digital skills among educators, teachers and pupils. 

32 

 
 
This financial support will be underpinned by a reform aiming at improved digitalisation of 
education in a strategic and comprehensive way, including enhancing teaching, learning and 
assessment.  Investments  in  access  to  ICT  equipment  and  connectivity  for  schools  and 
households with children, as well as improving digital skills of teachers and students are likely 
to improve equal access to digital education, as well as its quality.  

Finally,  the  plan  is  expected  to  improve  the  matching  of  skills  and  qualifications  with 
labour market requirements in the modern economy. Reforms to improve the coordination 
of policies in the regions in the area of vocational education and training and lifelong learning, 
as well as reforms and investments to set up 120 sectoral skills centres throughout the country 
are expected to improve labour market outcomes of education and training at all levels  and 
provide better labour market opportunities. With specific attention for digital and green skills 
and the provision of targeted upskilling and reskilling opportunities, these measures are set to 
prepare adults, young people, and next generations for the modern economy. 

*** 

Taking into consideration all reforms and investments envisaged by Poland, its Recovery and 
Resilience plan represents, to a high extent a comprehensive and adequately balanced response 
to  the  economic  and  social  situation,  thereby  contributing  appropriately  to  all  six  pillars 
referred to in Article 3 of the RRF Regulation, taking the specific challenges and the financial 
allocation  of  Poland  into  account.  This  would  warrant  a  rating  of  A  under  the  assessment 
criterion 2.1 in Annex V to the RRF Regulation. 

33 

 
 
 
 
Table 4: Coverage of the six pillars of the Facility by the Polish recovery and resilience 
plan components 

Green 
transition 

Digital 
transformation 

Smart, 
sustainable 
& 
inclusive 
growth 

Social and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutional 
resilience 

Policies for 
the next 
generation 

○ 

● 

A - Resilience and 
competitiveness of 
the economy 

B - Green energy 
and energy intensity 
reduction 

C - Digital 
transformation 

D - Efficiency, 
accessibility and 
quality of the health 
system 

E – Green, smart 
mobility 

● 

F – Improving the 
quality of 
institutions and the 
conditions for the 
implementation of 
the RRP 

○ 

○ 

○ 

○ 

● 

○ 

○ 

○ 

○ 

○ 

● 

○ 

○ 

○ 

○ 

○ 

● 

○ 

Key:  “●”  investments  and  reforms  of  the  component  significantly  contribute  to  the  pillar;  “○”  the 
component partially contributes to the pillar 

4.2. Link with country-specific recommendations and the European Semester 

The  plan  contributes  to  effectively  addressing  a  significant  subset  of  the  structural 
challenges identified in the country-specific recommendations (CSRs) of 2019 and 2020. 
The plan focuses on measures that follow recommendations linked to the COVID-19 pandemic 
response, notably by targeting a reinforcement of the health system and providing support to 
economic sectors heavily affected by the economic downturn. The plan also places a strong 
emphasis  on  reforms  and  investments  aligned  with  the  EU  green  and  digital  agendas.  In 
addition, the plan addresses - albeit to a lesser extent - long-term challenges linked to the labour 
market and the sustainability of public finances. 

Poland’s  recovery  and  resilience  plan  presents  a  mapping  of  CSR  challenges  onto  the 
Plan’s six components. A dedicated chapter of the plan presents a comprehensive overview 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of correspondence between the 2019 and 2020 CSRs and the reforms and investments included 
in  the plan. Where  relevant,  the overview includes supplementary information on measures 
taken outside the RRP, notably support to companies provided during the pandemic crisis as 
part of the Anti-Crisis Shield and the Financial Shield by the Polish Development Fund. The 
overview thereby illustrates a high degree of CSR coverage achieved by Poland’s RRP.  

Table  5:  Mapping  of  country  challenges 
recommendations and the Polish recovery and resilience plan components 

identified 

in  2019-20  country-specific 

Country challenges 
(as identified in Section 2) 

Associated 
CSR (2019-
2020) and 
European 
Semester 
recommenda
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y
t
i
l
i
b
o
m

t
r
a
m

s

,

n
e
e
r
G
–
E

t
n
e
n
o
p
m
o
C

○ 

Transition towards a higher 
value-added economy 

Tackling structural deficiencies 
in Poland’s social 
services, labour market and 
education system 

Ensuring a favourable business 
and investment environment 

Safeguarding sound public 
finances 

Green transition 

Digital transition 

2019.3.1, 
2019.3.2, 
2020.2.4a, 
2020.3.3 
2019.2.2a, 
2019.2.2b, 
2019.2.2c, 
2019.2.3, 
2019.3.2, 
2020.1.3, 
2020.2.1, 
2020.2.2, 
2020.2.3 
2019.3.1, 
2019.3.3, 
2020.2.4b, 
2020.3.1, 
2020.4.1, 
2020.4.2 
2019.1.2, 
2019.2.1, 
2020.3.2a 

2019.3.2, 
2020.3.3 

2019.3.2, 
2020.2.3, 
2020.2.4a, 
2020.2.4b, 
2020.3.3 

● 

○ 

● 

○ 

● 

● 

○ 

○ 

○ 

○ 

● 

○ 

● 

● 

○ 

○ 

Key:  “●”  investments  and  reforms  of  the  component  significantly  address  the  challenge;  “○”  the 
component partially addresses the challenge 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The plan addresses the country-specific recommendations on the efficiency of spending 
(CSR 2019.1). This is done through a reform of the budget system and by broadening the scope 
of the general expenditure rule with potential to increase the efficiency of public spending. 

The  plan  partially  addresses  CSRs  in  the  area  of  labour  market  and  education  (CSR 
2019.2). The plan includes some measures to improve the adequacy of future pension benefits 
and the sustainability of the pension system, as recommended in the CSR. This is to be achieved 
through tax incentives for those who reach the statutory retirement age but choose to continue 
their  working  life.  The  CSR  on  labour  market  participation  is  only  partially  addressed 
concerning the need to compensate for the adverse effects of the low statutory retirement age 
and  demographic  trends.  Rather  than  raising  employment  incentives  for  all  age  groups,  the 
main  measures  in  the  plan  include  the  promotion  of  more  remote  and  flexible  work 
arrangements, a reform of public employment services, as well as investments in childcare and 
a setting up quality educational standards for childcare. The plan does not include a reform on 
special pension regimes, which would be conducive to fostering mobility of the labour force. 
The CSR on issues in the long-term care system is partially addressed in the plan by, inter alia, 
a strategic review of the long-term care system, supporting the transformation of certain district 
hospitals  and  district  hospitals’  units  into  long-term  care  facilities.  The  CSR  to  address 
increasing  labour  market  segmentation  is  addressed  by  covering  all  civil-law  contracts  by 
social security contributions and by conducting a study on the single labour contract that might 
by  followed  by  legislative  changes.  These  measures  have  the  potential  to  tackle  the 
segmentation  of  the  labour  market  and  to  increase  social  protection  of  certain  workers. 
Investments setting up sectoral skills centres underpinned by a clear legal framework intend to 
foster  quality  vocational  education  and  training  and  adult  learning  and  address  the  relevant 
CSR. These measures are expected to stimulate the development of skills relevant to the labour 
market. While the educational inequalities deepened due to COVID-19, the low attractiveness 
of the teaching profession or the quality of education, in particular of higher education, are not 
directly  addressed  by  the  plan,  the  schooling  system  is  expected  to  benefit  from  measures 
supporting its digitalisation. 

Investments,  combined  with  the  necessary  reforms,  in  road  safety,  clean  vehicles, 
sustainable urban mobility and railways will promote the sustainability of transport, in 
particular its decarbonisation, digitalisation and safety (CSR 2019.3). It will be important 
to  ensure  fair  and  transparent  criteria  for  the  allocation  of  RRF  funds  across  sectors  and 
municipalities to ensure regional disparities are not further exacerbated.  

The research and innovation measures proposed in the plan partially address the CSRs 
in  the  area  of  research  and  innovation  (CSR  2019.3).  Investment  in  the  acquisition  of 
research  infrastructure  by  research  institutes  aims  at  facilitating  research  commercialisation 
and at fostering closer cooperative links with the business sector. Innovation diffusion in the 
business sector, as well as support for the development of breakthrough technologies and health 
R&I activities may contribute to an increase in Poland’s innovative capacity and performance. 

Poland  has  implemented  measures  to  address  the  pandemic  in  line  with  the  relevant 
recommendation  (CSR  2020.1).  In  response  to  the  COVID-19  pandemic  and  related 
economic downturn, Poland has adopted budgetary measures to strengthen the capacity of its 
health system,  contain the pandemic and provide relief to those individuals and sectors that 
have been particularly  affected. At the same time, the plan includes measures that can help 
achieving prudent medium-term fiscal positions and ensuring debt sustainability, notably the 
reform of the budget system and the broadening of the scope of the stabilising expenditure rule. 
Investments in hospitals, health sector staffing, medical research, and e-health are likely to help 
improve  the  resilience,  accessibility  and  effectiveness  of  the  health  system.  Strong  reform 

36 

 
 
commitment, especially in primary care and the hospital sector, is needed to bring sustainable 
results. Other parts of the healthcare system with challenges addressed in the CSR and crucial 
to  improving  prevention,  access  and  the  system  resilience  (such  as  primary  care),  will  be 
supported by other sources of investment financing, including the Cohesion Policy Funds. 

The plan is ambitious in mitigating the employment impact of the COVID-19 crisis, while 
it does not include measures to better target social spending. (CSR 2020.2). The legislative 
efforts towards the introduction of flexible and short time working arrangements in the labour 
code are expected to increase job attractiveness, especially for those leaving in remote areas, 
while  the  investments  in  equipping  employees  to  work  remotely  are  expected  to  partially 
strengthen the legislative efforts by advising on the digitalisation process of micro, small and 
medium-sized enterprises, introducing training on remote work, and purchasing IT services to 
enable  online  work  and  communication.  At  the  same  time,  the  plan  does  not  include  any 
measures to better target social spending, leaving this challenge unaddressed 

The plan presents a balanced and promising response to recommendations to improve 
digital  skills  and  promote  the  digital  transformation  of  companies  and  public 
administration (CSR 2020.2). The plan promotes the development of basic digital skills for 
various  population  groups  such  as  teachers,  civil  servants,  citizens  with  insufficient  basic 
digital knowledge and people excluded or at risk of exclusion. This will be supported by the 
creation of the Digital Competence Development Programme by the relevant centre of experts 
and  a  network  of  local  digital  coordinators.  As  for  the  digital  transformation  of  the  public 
administration,  a  series  of  projects  and  legislative  changes  are  expected  to  promote 
digitalisation of administrative processes, which in turn will boost digitalisation of companies. 
These projects include the development of a digital identity for citizens and businesses, digital 
signatures,  structured  electronic  invoices,  up-graded  and  new  e-services,  and  public  data 
sharing platforms and IT systems. This has potential to considerably improve the quality of 
public  services  in  Poland  and  their  coordination  by  the  government,  given  difficulties  in 
communication  and  coordination  between  different  government  levels  as  well  as  with  end-
users, such as citizens and businesses. 

The  Plan  provides  a  limited  response  to  increase  access  to  finance  and  liquidity  for 
companies (CSR 2020.3). The plan includes investments to support reskilling in companies, 
as  well  as  projects  related  to  modernising  their  equipment  and  infrastructure.  This  could 
enhance the resilience and competitiveness of Polish companies in the medium term. At the 
same  time,  the  Plan  lacks  concrete  reforms  to  tackle  bottlenecks  in  access  to  finance  and 
liquidity for companies, which may hinder the recovery of some companies. The application 
rate by SMEs for bank loans has decreased in 2019, while the rejection rate has increased in 
the  same  period.  This  could  limit  investment  and  innovation  levels,  which  are  already  low 
compared to the EU average. 

Some measures have been introduced to boost private investment (CSR 2020.3). The plan 
includes  some  measures  to  reduce  administrative  burden  to  businesses,  in  particular  by 
reducing administrative requirements, streamlining procedures and legislation, and enhancing 
the transparency of procedures and legal requirements. The reform to ensure a better and more 
stable  regulatory  framework  by  enhancing  the  use  of  public  consultations  and  impact 
assessments is also set to improve business sentiment, thus boosting private investment. The 
plan includes a financial instrument to support SMEs and mid-caps in producing low-emission 
mobility and alternative energy solutions. Finally, SMEs and small producers in the agri-food 
sector  are  set  to  benefit  from  a  reform  to  combat  unfair  trade  practices,  which  could  also 
enhance private investment levels.  

37 

 
 
Poland’s plan can be regarded as a determined and effective response to the challenges 
posed by the green and digital transition (CSRs 2019.3 and 2020.3). A comprehensive set 
of reforms and investments in energy, transport and water management supports addressing 
the CSR to focus investment-related economic policy on innovation, transport, notably on its 
sustainability, digital  and energy infrastructure,  healthcare and cleaner energy, and to  focus 
investment on the green and digital transitions, in particular digital broadband infrastructure, 
clean and efficient energy production and use and sustainable transport, which will contribute 
to the gradual decarbonisation of the economy, including in coal regions. The plan is expected 
to  contribute  to  a  significant  increase  in  the  installed  capacity  of  onshore  wind  farms  and 
photovoltaic installations. Several significant reforms and investm.ents to enable a clean and 
efficient production and use of energy, such as reforms supporting the development of offshore 
wind farms and of hydrogen technologies along with accompanying investments and a reform 
unlocking the potential of investments in onshore wind farms, are envisaged. The plan also 
includes  measures  aimed  at  the  transition  towards  a  low-carbon  economy  such  as  reforms 
regarding the prohibition of coal-fired boilers and the sustainable mobility via clean vehicles, 
low-emission urban zones and modal shift towards railways. 

Significant investments in the plan aim to expand fixed and mobile digital infrastructure 
(CSR 2020.3). Although the digitalisation of the Polish society is fast-paced, there is still a 
consistent urban-rural divide in digital infrastructure. The so-called white NGA areas, where 
internet  access  of  at  least  30  Mb/s  is  not  guaranteed,  risk  to  be  left  behind  not  only  when 
competing for businesses and economic development, but also in various social dimensions. 
The  planned  investments  in  digital  infrastructure  are  expected  to  support  the  economic 
recovery and help close Poland’s gap with other countries in the coverage of very high-capacity 
networks. While the 4G coverage is almost 100%, the country’s readiness to 5G is still 0% 
(DESI 2021), with no frequencies spectrum assigned to 5G pioneer bands. The relevance of 
reforms eliminating barriers to the implementation of 5G networks and investments offering 
financial support to telecom operators for 5G deployment in market failure areas is therefore 
paramount. 

The Polish recovery and resilience plan contributes to addressing the recommendations 
to improve the process of law-making (CSR 2019.3) and safeguard the independence of 
the  judiciary,  ameliorating  the  investment  climate  (CSR  2020.4).  In  particular,  the  plan 
seeks to improve the regulatory environment by including a reform limiting the use of fast-
track legislative procedures and making mandatory the use of impact assessments and public 
consultations. Furthermore, the proposal includes the establishment of a committee consisting 
of main stakeholders and social partners, which will monitor the effective implementation of 
the RRP. A reform of the disciplinary regime applicable to judges and a reform remedying the 
situation of judges affected by the decisions of the Disciplinary Chamber of the Supreme Court 
are included in the plan, in order to better safeguard the independence and impartiality of the 
judiciary. As a result of these reforms, it is expected that any cases relating to judges will be 
adjudicated  by  a  court  complying  with  the  requirements  of  EU  law  on  independence  and 
impartiality, while all judges affected by the past Disciplinary Chamber rulings will have the 
right to have these rulings reviewed by an independent and impartial court. These measures 
aim  at  raising  the  standard  of  judicial  protection,  thereby  contributing  to  improving  the 
investment climate.  

Response to the economic and social situation 

Poland  entered  the  pandemic  crisis  on  a  robust  macroeconomic  footing,  having 
previously  enjoyed nearly  three decades of uninterrupted economic growth. Real  GDP 
grew  by  4.7%  in  2019,  mainly  supported  by  robust  private  consumption  growth.  Strong 

38 

 
 
international competitiveness helped Poland keep gaining shares in key export markets, with 
exports raising by 7% on average over the 2014-2019 period. The labour market was showing 
signs of overheating, as unemployment reached historical lows and wage inflation exceeded 
7.3%  in  2019.  Overall,  Poland’s  economy  was  going  through  a  period  of  good  economic 
performance, signalling a successful convergence process to the rest of the EU. At the same 
time, emerging structural weaknesses in education, innovation, and governance were starting 
to cloud the economic outlook. Low levels of private investment and productivity gaps in SMEs 
could lead to lower rates of potential growth in the medium term, as well as limit the ability of 
the  Polish  economy  to  move  up  the  value  chain  and  produce  more  advance  products  and 
services. 

After a 2.2% decline in 2020 real output, the Polish economy has posted a strong recovery 
which has only been partly constrained by persisting pandemic-related restrictions. The 
fall in GDP was milder than the EU average, as Poland’s low exposure to hard-hit sectors and 
its diversified economic structure cushioned the impact of the pandemic on economic activity. 
According  to  the  latest  estimate  by  the  statistical  office,  real  GDP  growth  reached  5.9%  in 
2021,  reaching  its  pre-pandemic  level  of  output  in  Q2-2021.  Poland’s  economic  growth  is 
expected to decelerate in 2022 and 2023 driven by Russia’s unprovoked invasion of Ukraine, 
which  has  clouded  the  economic  outlook,  as  projected  by  the  Euroepan  Commission  2022 
Spring economic forecast. Due to public support which encouraged cutting worktime rather 
than jobs, the impact of the crisis on the labour market has been mild. 

On the social side, strong economic growth in the past drove up employment and created 
moderately inclusive growth, while reducing the risk of poverty in the population. The 
share of people at risk of poverty saw a significant fall over the period 2014-2018, reaching 
18.9%  in  2018,  well  below  the  EU  average.  The  income  share  of  the  bottom  40%  of  the 
population showed a marked increase over the same period, going from 21% in 2014 to more 
than 22.5% in 2018. Nevertheless, significant disparities continue to exist across vulnerable 
groups. The difference in employment rates between men and women remains high and the 
gap has widened in recent years. Similarly, the gender pay gap has increased over the 2014-
2019 period, as opposed to the falling trend in the EU. The COVID-19 crisis is also likely to 
have accentuated limited employment opportunities for disadvantaged groups, who are facing 
a significantly higher risk of poverty and for whom social exclusion remains a challenge. The 
unemployment  rate  among  youngsters  increased  visibly  compared  to  the  total  population, 
which  could  lead  to  lower  future  earnings,  skills  depreciation,  and  depressed  productivity 
growth  in  the  long  term,  especially  if  there  is  a  sustained  increase  in  long-term  youth 
unemployment.  Despite  investments  in  online  education,  the  COVID-19  pandemic  has 
deepened inequalities in education, affecting in particular disadvantaged students, which may 
also  lead  to  increased  early  leaving  from  education  and  training  in  the  long  run.  Women’s 
participation in the labour market also remains well below men, as they generally bear a larger 
share of care responsibilities.  

Overall, and compared to initial expectations of a much deeper and protracted recession 
in  Poland,  the  economic  scars  of  the  pandemic  recession  appear  to  be  comparatively 
moderate.  In light of the relatively swift recovery that Poland is projected to experience in 
economic activity, policy attention should be placed on more structural  – rather than purely 
cyclical - constraints on growth and prosperity. In light of Poland’s aforementioned structural 
challenges,  which  became  more  apparent  as  the  economy  ‘heated  up’  in  the  pre-pandemic 
years, the plan’s strong focus on vocational education, governance and productivity-enhancing 
investment  into  the  green  and  digital  transition,  can  be  regarded  as  a  comprehensive  and 
adequate response to the economic crisis.  

39 

 
 
Impact on growth potential  

In the long run, structural reforms contained in the Polish RRP are expected to entail a 
GDP  gain  of  at  least  1.9%  by  2040  according  to  the  authorities,  relative  to  the 
counterfactual scenario without the RRP. Two thirds of these effects are assumed to come 
from  increasing  the  quality  of  human  capital,  improving  the  skills  composition  and  the 
increased size of the Polish labour force. The remaining third of the effect is expected to come 
from the build-up of productive capital, in particular reforms to enhance the efficiency of public 
administration  and  improve  the  business  environment.  These  measures  would  raise 
productivity and maintain the competitiveness of the Polish economy. As a result, a successful 
implementation of the RRP could facilitate the country’s transition to a new, more diversified 
economic model, based on a larger share of high value-added activities. By addressing long-
standing weaknesses of the Polish economy and preparing the country to successfully face the 
challenges  posed  by  21st  century  trends,  these  reforms  could  have  a  long-lasting  beneficial 
effect on Poland’s economic performance and growth potential. 

The RRP focuses on scaling up innovative solutions in the economy and transforming the 
economy towards the circular economy. The plan aims to increase the innovation capacity 
of the economy by supporting research institutions and laboratories and their closer cooperation 
with businesses in particular in the areas of digitalisation and green transition. The objective is 
also to increase the innovation potential on the supply side (creators and providers of innovative 
solutions) as well as on the demand side (implementing innovative solutions). By introducing 
tax incentives Poland expects to see a greater uptake of robotisation and automation processes. 
Improving the framework for technology transfer between science and the industry as well as 
the  development  of  research  capacities  should  lead  to  a  higher  rate  of  commercialised 
innovative  technologies,  in  particular  in  the  area  of  environmental  solutions  related  to  the 
circular economy, unmanned vehicles and agriculture.  

Low  labour  force  participation  is  another  important  factor  constraining  Poland’s 
potential  growth,  which  the  RRP  aims  to  address  via  several  channels.  Measures  to 
increase the labour market relevance of skills and to reduce mismatches as well as measures 
aiming for better and more digitally-inclusive education should facilitate a higher participation 
in the labour market. The RRP also intends to expand the long-term care facility network for 
the elderly which can unburden family members, particularly women, hence supporting their 
return to the labour market. Increased investments in childcare can also help tackle the lower 
labour  market  participation  of  women.  These  measures  could  have  a  beneficial  impact  on 
potential economic growth, especially given the projections of a fast-ageing Polish population. 

By addressing problems in the efficiency of public administration and procedures, the 
RRP could also facilitate a more favourable business environment and investment climate 
which is more conducive to private investment and innovation.  Reducing the regulatory 
and administrative burden for business by e.g. simplifying certain procedures and streamlining 
existing  land-planning  legislation  can  help  lower  barriers  to  investment  and  enhance  the 
competitiveness and productivity of Polish businesses. A fundamental reform to enhance the 
use of public consultations in the law-making process is also expected to lead to an improved 
and more stable regulatory framework, increasing business confidence. Extending the number 
of areas defined as special economic zones is also expected to increase investment levels and 
attract  investors,  particularly  foreign  ones.  Poland’s  potential  growth  should  significantly 
benefit from these reforms in the coming decades, particularly through increased productivity 
growth, investment, and innovation. 

*** 

40 

 
 
Taking into consideration the reforms and investments envisaged by Poland, its recovery and 
resilience  plan  is  expected  to  contribute  to  effectively  addressing  a  significant  subset  of 
challenges identified in the country-specific recommendations, or challenges in other relevant 
documents  officially  adopted  by  the  Commission  under  the  European  Semester,  and  the 
recovery  and  resilience  plan  represents  an  adequate  response  to  the  economic  and  social 
situation of Poland. This would warrant a rating of A under the assessment criterion 2.2 in 
Annex V to the RRF Regulation. 

4.3. Growth  potential,  job  creation,  economic,  institutional  and  social  resilience, 
European Pillar of Social Rights, mitigating the impact of the crisis, and social 
territorial cohesion and convergence 

Box 2: Stylised NGEU impact simulations with QUEST - Poland 

Model simulations conducted by the Commission using the QUEST model show that the 
economic impact of the NGEU in Poland could lead to an increase of GDP of between 1.1% 
and 1.8% by 2026[1]. After 20 years, GDP could be 0.6% higher. Spillovers account for a 
part of the effect.  

According to these simulations, this would translate into up to around 105,000 additional jobs. 
Cross  border  (GDP)  spillovers  account  for  0.2  pps  in  2026,  showing  the  value  added  of 
synchronised  expenditure  across  Member  States  (line  2).  Even  in  a  scenario  with  a  lower 
productivity of NGEU funds, it would still lead to a significant impact (line 3)[2]. 

Table 1: QUEST simulation results (%-deviation of real GDP level from non-NGEU case, 
linear disbursement assumption over 6 years)   

Scenario 

202
1 

202
2 

202
3 

202
4 

202
5 

202
6 

202
7 

202
8 

202
9 

203
0 

204
0 

Baseline 

0.7 

1.3 

1.5 

1.6 

1.7 

1.8 

1.4 

1.0 

1.0 

0.9 

0.6 

   of which spillover 

-0.4 

-0.2 

0.0 

0.1 

0.2 

0.2 

0.2 

0.2 

0.1 

0.1 

0.1 

Low productivity 

0.4 

0.9 

1.0 

1.0 

1.1 

1.1 

0.7 

0.3 

0.3 

0.3 

0.2 

This stylised scenario does not include the possible positive impact of structural reforms, 
which  can  be  substantial.  A  model-based  benchmarking  exercise  shows  that  undertaking 
structural  reforms  that  would  result  in  halving  the  gap  vis-à-vis  best  performers  in  terms  of 
indicators of structural reforms could raise Poland’s GDP by 15% in 20 years’ time, compared 
to 11% for the EU average[3].  

Due  to  the  differences  in  the  assumptions  and  methodology,  the  results  of  this  stylised 
assessment cannot be directly compared to the numbers reported in chapter 4 of Poland’s 
RRP. 

[1]  RRF  amounts  to  roughly  90%  of  NGEU,  which  also  includes  ReactEU,  Horizon,  InvestEU,  JTF,  Rural 
Development and RescEU. 

[2] Technically, the low productivity scenario considers a significantly reduced output elasticity of public capital. 

[3] Varga, J, in 't Veld J. (2014), “The potential growth impact of structural reforms in the EU: a benchmarking 
exercise ", European Economy Economic Papers no. 541.  

http://ec.europa.eu/economy_finance/publications/economic_paper/2014/pdf/ecp541_en.pdf 

41 

 
 
4.3.1.  Fostering economic growth and jobs 

The  implementation  of  the  Recovery  and  Resilience  Plan  is  expected  to  contribute  to 
economic growth and job creation in Poland. RRF-funded public expenditure is expected to 
provide a boost to aggregate demand in the short to medium term and to improve further the 
position  of  the  Polish  economy.  In  the  long  run,  investments  together  with  the  planned 
structural reforms could help address the current growth challenges, including low investment 
and innovation levels and skill mismatches. This would facilitate the country’s transition to a 
knowledge-based  economic  model  more  focused  on  high  value-added  activities,  and  which 
remains  competitive  amid  increased  automation  and  the  digital  and  green  transition. 
Implementing  the  RRP  is  therefore  expected  to  raise  potential  output  and  to  have  a  lasting 
impact on the economic performance of Poland. 

Non-refundable grants from the RRF amount to around 4.6% of pre-crisis GDP, which 
Poland plans to spend mainly on public investments spread over 6 years between 2021 
and 2026. These expenditures constitute a sizable fiscal stimulus, as a result of which the Polish 
authorities estimate real GDP to be 1.3% higher in 2025 relative to the counterfactual scenario 
without the RRF. The labour market is also expected to improve, with employment forecasts 
to be 0.4% higher by 2025 than it would be in the absence of RRF grants over the same time 
horizon. This short to medium-term boost to aggregate demand should speed up the recovery 
of  the  Polish  economy  from  the  COVID-19  crisis,  especially  in  light  of  the  high  share  of 
construction projects in the investment plan and considering that the Polish construction sector 
was among the hardest hit during the pandemic.  

The transmission channels of higher public investment spending to the broader economy 
are manifold. In addition to the direct effect of more public expenditures on GDP, there is also 
an indirect  response of the economy  via influencing private spending decisions, which will 
determine the size of the fiscal multiplier in the current environment of depressed demand, the 
usual effect of crowding out private expenditures via higher real interest rates is likely to be 
muted, given the expectations of continued monetary policy support by the National Bank of 
Poland for the coming years. In addition, by expanding the capital stock of the economy, public 
investment  can  raise  the  productivity  of  the  private  sector,  and  thereby  crowd  in  private 
investments. Higher public spending raises incomes in general, while higher productivity also 
contributes to faster real wage growth, which can further support household consumption. This 
is even more so if households tend to consume a large fraction of their earnings, which bodes 
well for Poland with household saving rates below the EU average. Finally, additional spillover 
effects are expected to come from the fact that the RRF will be implemented simultaneously in 
other EU Member States in a relatively short time. 

In the long run, the measures contained in the Polish RRP are expected to entail a GDP 
gain of at least 1.9% by 2040 according to the authorities, relative to the counterfactual 
scenario without the RRF. Two thirds are expected to come directly from improvements in 
human capital and skills, which are set to alleviate skills shortages in the Polish economy, while 
the remaining one third is expected to be a direct consequence of the build-up of productive 
capital. In addition, potential growth could be stimulated by improvements in the efficiency, 
accessibility and quality of the health system, which coupled with improvements in the labour 
market participation of disadvantaged groups, are expected to increase labour market activity.  

The  RRP  contributes  to  potential  output  also  by  speeding  up  the  recovery  from  the 
COVID-19  crisis,  hence  preventing  long-term  scarring  due  to  hysteresis  effects,  prolonged 
unemployment and rising bankruptcies and mitigating permanent economic damages as a result 
of the pandemic. 

42 

 
 
As far as the plausibility of these short and medium-run economic impact estimates is 
concerned,  the  Polish  RRP  rests  on  well-reasoned  macroeconomic  modelling  and 
econometric techniques. The implied fiscal multiplier of 1.3 over the period of 2021-2026 is 
only  slightly  below  the  averaged  1.4  estimated  by  the  Commission’s  own  QUEST 
macroeconomic model for the same public expenditure profile and calibrated for Poland. The 
estimated medium-term employment response in the RRP is also largely in line with that given 
by QUEST. 

In addition, the above short and medium-run estimates only consider the effects of public 
investments in the RRP, while structural reforms are not taken into account. Given that 
structural reforms could start to exert their beneficial economic impact in the medium term, 
this might constitute a downward bias in the estimated figures. 

Investment baseline 

The public investments outlined in the RRP are convincingly argued to be additional to 
what would have been the case in the absence of the RRF. The case for macro-additionality 
is supported by analysis in the Plan showing that baseline public investments, excluding those 
to be financed from RRF grants, are forecast to be at least as high on average over the period 
of 2021-2026 as they were in 2017-2019. This makes it likely that, by coming in addition to 
these investments, RRF-funded spending truly contributes to economic growth and does not 
just replace otherwise planned nationally-financed investments, being used only for public debt 
reduction.10 According to information supplied by the Polish authorities, nationally-financed 
baseline public investments (excluding military spending) are expected to be on average 38.3% 
higher in nominal terms  between 2021 and 2026 compared to the three  years preceding the 
pandemic. This corresponds to baseline investments maintaining a similar share of GDP across 
the two time periods. 

Prior to the pandemic the composition of public investments was dominated by spending 
on  transport  and  health  infrastructure.  Funds  from  the  RRF  place  an  emphasis  on 
investments  in  the  areas  of  environment  and  sustainable  mobility.  More  than  a  third  of  the 
funds are planned to go for green economy measures, which mainly include investments in 
renewable energy sources and energy efficiency measures. Over a fifth of the funds are directed 
to  investments  in  sustainable  mobility  measures,  including  the  promotion  of  clean  public 
vehicles and investments in railway infrastructure and the electrification of rolling stocks.  

4.3.2.  Strengthening social cohesion 

The  Recovery  and  Resilience  Plan  addresses  several  social  and  territorial  challenges 
relevant  for  Poland  and  contributes  to  the  implementation  of  the  European  Pillar  of 
Social Rights. It includes measures on the availability and quality of childcare, digitalisation 
of schools and development of digital skills, on vocational training and adult learning, and on 
health  and  long-term  care  and  access  to  public  services.  Upskilling  and  reskilling  of  the 
population, better coordination of policies and territorial coverage are specifically mentioned 
as objectives of several measures, including those related to the digitalisation of schools. 

The plan primarily aims to reduce social inequalities through reforms and investments 
in the education and skills system. Investments in childcare facilities are expected to support 
labour market participation, especially among women. Supplying all schools with modern ICT 

10 While it is never straightforward to establish a true counterfactual scenario, the default working assumption is 
that  even  without  the  RRF  public  investments  would  have  at  least  stayed  at  a  similar  level  than  prior  to  the 
pandemic. 

43 

 
 
                                                           
equipment for students and teachers on the basis of a strategic approach for the short, medium 
and long term are expected to contribute to improving learning conditions. Furthermore, people 
excluded or at risk of exclusion are expected to benefit from a dedicated share of investments 
on the strengthening of basic digital skills.  

Reinforcing and better coordinating the existing offer of secondary and higher vocational 
education  and  training  and  lifelong  learning  will  also  contribute  to  supporting  labour 
market participation. Reforms and investments in this field are expected to better equip the 
workforce with the skills needed for the modern economy, with a particular focus on the digital 
and  green  transitions.  Investments  in  setting  up  sectoral  skills  centres  are  also  expected  to 
channel a significant share of support towards the inclusion of persons with disabilities in the 
sectors concerned.  

In light of the above, the reforms and investments in the plan are coherent with the main 
relevant EU policy agendas in the field of skills, vocational training and adult learning. 
They  are  expected to  help  deliver on the related  principles of the European Pillar of Social 
Rights.  These  actions  are  also  expected  to  support  Youth  Guarantee  scheme,  notably  by 
increasing skills and qualifications of young people and ultimately improving the creation of 
qualified employment. 

Comprehensive reforms reinforced with significant investments are expected to improve 
the resilience, accessibility and effectiveness of the Polish healthcare system. Restructuring 
hospitals with substantial supportive investment based on a precise identification of investment 
needs at regional and national level are expected to contribute to address the challenges in the 
hospital sector. A set of specific reforms and targeted investments will cover a wide range of 
medical professions, including specialised medicine, emergency health services and nursing. 
Medical universities as well as their current and future students are expected to benefit from 
substantial  investment  support and the  creation  of new schemes to  encourage  choosing this 
study path and incentivising young medical professionals to remain in Poland after the end of 
their studies. Investments in universities’ infrastructure and the clinical base are to improve the 
studying  conditions  and  thus  help  increase  the  number  of  students  interested  in  taking  up 
medical studies. The attractiveness of the medical sector will be subject to a dedicated reform, 
including  minimum  salary  increases  for  certain  medical  professions  to  be  financed  from 
national sources.  

Reforms and investments aimed at improving connectivity and ensuring universal access 
to high-speed internet  should contribute to reducing existing territorial gaps.  The plan 
indicates that more than 35% of households in Poland are still unable  to access the internet 
with a speed of at least 100 Mbps, with strong differences between urban and rural areas, as 
well as between western and eastern Poland. This gap should be significantly narrowed by the 
investments in connectivity foreseen in the RRP. In addition, measures dedicated to increasing 
the  availability  of  digital  public  services  and  supporting  the  digital  transition  of  public 
administration shall contribute to improving accessibility of public services.  

4.3.3.  Reducing vulnerability and increasing resilience  

While  no  macroeconomic  imbalances  have  been  identified,  Poland’s  economy  faces 
several  challenges  to  a  more  sustainable  growth  path.  An  ageing  population  and  a 
decreasing  number  of  people  at  working  age  are  significant  challenges  that  may  hamper 
Poland’s growth potential in the medium-to-long term. The plan aims to tackle labour and skill 
shortages by investing in labour market relevance of skills and supporting reskilling/upskilling 
projects, particularly in SMEs, as well as by encouraging higher labour market participation of 
disadvantaged groups by investing in child-care and long-term care infrastructure. Moreover, 

44 

 
 
the strong focus on the green transition in the plan is set to reduce Poland’s dependence on 
fossil fuels, cushioning the potential impact of supply or price shocks as well as contributing 
to  addressing  energy  poverty.  This  will  be  achieved  by  an  expansion  of  renewable  energy 
production, by measures to reduce energy consumption of buildings and in industry, and by 
moving  towards  a  more  sustainable  transport  system  (such  as  through  the  purchase  of 
alternative fuels rolling stock, or the development of infrastructure for e-mobility). The plan 
also aims to address emerging weaknesses in the housing sector, which has seen swift house 
price  growth  in  recent  years,  through  a  reform  to  streamline  and  improve  land-planning 
legislation. Enhancing the investment climate is also a significant challenge for Poland given 
the low investment levels that the country has been experiencing in recent years compared to 
the EU average. Several measures included in the plan are expected to significantly reduce the 
regulatory  and  administrative  burden  to  businesses  and  to  contribute  to  safeguarding  the 
independence of the judiciary, which should improve the business environment and support 
increased investment levels.  

Poland’s plan includes a range of measures in the social, education and skills policy areas 
that can be expected to improve social resilience. The strategic approach to digitalisation in 
primary and secondary education aims to ensure equal access to digital and online education, 
as well as a more efficient integration of new technologies in teaching and learning. Improving 
the digital skills of all students, teachers, as well as of public officials, citizens without digital 
skills or those at risk of exclusion will help public administration, the education system and 
vulnerable social groups face important challenges. The creation of sectoral skills centres for 
up- and re-skilling, as well as support for the skills coordination in the regions will enhance 
employability and opportunities for labour market participation.   

Structural reforms, improved capacities and digitalisation efforts are set to strengthen 
institutional resilience. The digital transition of the country’s public administration is the most 
efficient  way  to  provide  faster,  cheaper  and  better  services.  A  more  effective  and  efficient 
public administration should provide a solid platform for the development of businesses and 
ensure quality services for citizens and businesses. Similarly, development of e-health services 
will contribute to improving the accessibility of healthcare accessibility and effectiveness of 
the health system, as well as to reinforcing the system’s administrative capacity. This, in turn, 
is expected to attract the investments needed to support growth and economic development. 
Efforts on the digitalisation of the public sphere have the potential to foster a user-friendly and 
accessible administration, while reducing risks of corruption.  

4.3.4.  Cohesion and convergence 

The Recovery and Resilience  Plan of  Poland includes a number of  measures aimed at 
reducing  territorial  and  economic  disparities.  The  socio-economic  consequences  of  the 
pandemic are likely to be unevenly distributed across regions due to different specialisation 
patterns. This entails a risk of widening territorial disparities within Poland.  

Improved  coordination  of  vocational  education  and  training,  higher  education  and 
lifelong  learning  in  the  regions  may  contribute  to  addressing  existing  weaknesses. 
Investments  in  sectoral  skills  centres,  underpinned  by  a  dedicated  reform,  are  expected  to 
promote  links  between  relevant  stakeholders,  such  as  educational  and  labour  market 
institutions, enterprises and employers’ organisations, and local and regional authorities. This 
should help improve the matching of skills with labour market needs at national and regional 
levels. Digitalisation in primary and secondary education aims to ensure equal access to digital 
and online education, as well as a more efficient integration of new technologies in teaching 
and learning. Improving the digital skills of all students, teachers, as well as of public officials, 

45 

 
 
citizens without digital skills or those at risk of exclusion can further contribute to mitigating 
regional disparities. 

Some of the measures included in the plan in the area of healthcare may also contribute 
to  alleviate  social  and  territorial  disparities.  They  aim  to  address  challenges  related  to 
accessibility of healthcare services, including emergency and specialised units. Among others, 
district hospitals are expected to benefit from targeted support for their partial restructuring 
into long-term care centres, based on a thorough analysis of local needs.  

Addressing territorial disparities is also among the objectives of thet digital component, 
with measures dedicated to promoting the development of network infrastructure, a focus on 
increasing access to high-speed internet services in white next-generation-access (NGA) areas 
and to strengthening the digitalisation of public services. 

Investments related to the green transition in the plan could have beneficial effects on 
social  and  territorial  cohesion  mainly  via  creating  new  and  more  accessible  job 
opportunities.  Investments  in  the  provision  of  low  and  zero-emission  rolling  stock  for  bus 
connections  in  areas  with  poor  transport  accessibility  are  expected  to  help  connect  remote 
regions  to  economic  centres  and  to  facilitate  the  commuting  of  jobseekers  to  where 
employment opportunities are more abundant, thereby improving the labour market outcomes 
of  the  population  in  less  developed  regions.  In  addition,  construction  projects  related  to 
renewables, in particular offshore wind farms and dedicated infrastructure investments, would 
provide  another  source  of  job  opportunities  for  medium  skilled  workers.  Assistance  for 
renovating and increasing the energy efficiency of family homes and public buildings would 
help  address  the  energy  poverty  prevalent  among  poor  households.  Measures  aimed  at 
increasing the availability of water and sewerage infrastructure in rural areas are expected to 
improve the quality of life in those regions. Investments in the agriculture sector may further 
contribute to territorial cohesion. 

The tax and social security reforms foreseen in the plan may have a beneficial impact on 
the labour market. Lowering income tax for those who reached the retirement age but do not 
retire and continue working creates an incentive to extend careers and increase the effective 
retirement age. This may positively contribute to employment, in particular via labour supply, 
addressing crucial demographic challenges including a shrinking working-age population. In 
addition, this may help alleviate old-age poverty, which is expected to increasingly become a 
challenge in the future, particularly for women, considering the design of the pension system 
in Poland and the low statutory retirement age. At the same time, extending full social security 
contributions to all civil-law contracts is expected to further reduce the segmentation of the 
labour market and provide better social protection, including through pension contributions, to 
certain groups of workers.  

While the precise impact of the above measures on social and territorial cohesion is uncertain, 
and they are unlikely to exhaustively solve all the existing challenges, the RRP is nevertheless 
expected to make a contribution to addressing them. 

***  
Taking into consideration all reforms and investments envisaged by Poland, its recovery and 
resilience plan is expected to have a high impact on strengthening the growth potential, job 
creation, and economic, social and institutional resilience of the Member State, on contributing 
to the implementation of the European Pillar of Social Rights, including through the promotion 
of policies for children and youth, and on mitigating the economic and social impact of the 
COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial  cohesion  and 

46 

 
 
convergence within the Union. This would warrant a rating of A under the assessment criterion 
2.3 of Annex V to the RRF Regulation. 

Box 3: Employment and social challenges in light of the Social Scoreboard accompanying 
the European Pillar of Social Rights 

The  Social  Scoreboard  supporting  the  European  Pillar  of  Social  Rights  points  to  some 
employment and social challenges in Poland. While the COVID-19 crisis has slowed down 
the  positive  labour  market  developments  observed  in  the  past,  Poland’s  labour  market 
performance  remained  strong  compared  to  other  Member  States.  The  unemployment  rate,  at 
3.4% in  2021, is one of the lowest in the EU and long-term unemployment has been decreasing 
(0.9% in 2021). There is a need to address skills mismatches and shortages. Individuals’ levels 
of digital skills are relatively low (only 43% have basic or overall basic digital skills). The rate 
of  early  leavers  from  education  and  training  is  very  low,  at  5.9%.  Poverty  has  been  steadily 
decreasing, however the share of people experiencing persistent poverty has increased. 

The gender employment gap and participation in formal childcare are at critical levels. 
While the overall employment rate (75.4%) was slightly higher than the EU average (73.1%) in 
2021, the employment rate of women was about 14.0 pps below that of men. This very large 
gender employment gap is attributable to women’s caring responsibilities. Poland has one of the 
lowest childcare enrolment rates in the EU, with 11.2% of children aged less than 3 years in 
formal childcare in 2020 (EU average in 2019: 35.3%), decreasing from 11.6% in 2017.  

The Recovery and Resilience Plan submitted by Poland addresses some employment and 
social challenges relevant for the implementation of the Pillar. To foster equal opportunities 

47 

 
 
 
 
and access to the labour market, the plan envisages measures in support to the employment of 
migrants and the social economy, as well as a strengthening of the public employment services 
through  capacity  building,  aiming  at  increased  efficiency.  Also,  measures  to  increase 
employment of certain groups, particularly women and older workers, are included in the plan.  

With  more  people  likely  to  fall  back  on  basic  safety  nets  due  to  the  COVID-19  crisis, 
reforms of social protection and inclusion are important in order to provide much needed 
support, in synergy with ESF funding. To support social protection and inclusion, Poland aims 
to  increase  access  to  childcare  through  proposed  infrastructural  investments.  This  will  be 
followed by a reform creating a new system to finance childcare, relying on the Recovery and 
Resilience Facility, ESF+ and national financing from the Toddler+ programme. However, the 
long-term sustainability of this system is still to be ensured. Healthcare challenges are addressed 
by creating  the right  conditions  for an increase in the number of medical  staff by supporting 
capacity of medical universities and increasing the number of students. The plan also aims at 
addressing challenges concerning the accessibility of long-term care. 

4.4. The principle of ‘do no significant harm’  

Poland has carried out an adequate Do No Significant Harm (DNSH) assessment of all 
measures  included  in  the  plan  within  the  meaning  of  Article  17  of  the  Taxonomy 
Regulation  (EU)  No  2020/852).  The  assessment  follows  the  methodology  set  out  in  the 
Commission´s  technical  guidance  on  the  application  of  DNSH  under  the  RRF  Regulation 
(2021/C 58/01). It covers the six environmental objectives, namely climate change mitigation, 
climate  change  adaptation,  sustainable  use  and  protection  of  water  and  marine  resources, 
circular  economy,  pollution  prevention  and  control,  and  protection  and  restoration  of 
biodiversity and ecosystems. Each DNSH assessment follows a two-step approach. The first 
step assesses whether there is a risk that a measure could do significant harm to one or more of 
the  environmental  objectives.  In  cases  where  the  analysis  identifies  a  risk,  a  more  detailed 
assessment is performed. Based on the information provided by Poland, no measure  for the 
implementation  of  reforms  and  investments  projects  included  in  Poland’s  recovery  and 
resilience plan is expected to do significant harm to the environmental objectives within the 
meaning  of Article 17 of the  Taxonomy Regulation.  Strong  commitments  are included that 
DNSH requirements shall be complied with, being enshrined in the design of measures and 
reflected in various milestones and targets. 

The  potential  harmful  environmental  and  climate  impact  of  all  relevant  measures  is 
addressed  through  appropriate  assurances  that  the  applicable  criteria  will  be  met. 
Measures targeting industry decarbonisation will aim at  levels  of greenhouse gas emissions  
substantially  lower  than  the  applicable  EU  Emission  Trading  System  benchmarks;  building 
renovations will comply with requirements linked to the boiler replacement and will ensure 
that at least 70% of demolition waste is reused or recycled; hydrogen production will meet the 
GHG emission threshold set out in the Delegated Act to the Taxonomy Regulation, and the 
rolling stock/vehicles will meet the applicable emission standards. With respect to wastewater 
and water management projects, Poland will ensure full compliance of supported projects with 
relevant  EU  legislation,  namely  the  Water  Framework,  Habitats  and  Birds,  EIA  and  SEA 
Directives  and  national  legislation.  Measures  related  to  the  development  of  hydrogen 
technologies will support only renewable and low-carbon hydrogen . These criteria are also 
reflected in the milestones and targets through references to relevant criteria and thresholds 
(e.g.  hydrogen  projects  need  to  meet  the  GHG  emission  threshold  of  3  tCO2e  per  tH2).  In 
transport,  only  electric  urban  buses  and  high-floor  buses  meeting  EURO  6  criteria  will  be 

48 

 
 
supported. Investments in roads will be limited and related only to increasing road safety, e.g. 
through the construction of road bypasses.  

The  DNSH  compliance  of  the  financial  instruments  (relevant  notably  to  measures  in 
transport  and  innovation)  will  require  that  an  investment  strategy  and  subsequent 
contractual  agreement  with  financial  intermediaries  is  aligned  with  the  Commission 
sustainability proofing guidance. This  requirement is  reflected in  the design of individual 
measures and corresponding milestones and targets.  

***  
Taking into consideration the assessment of all the measures envisaged, no measure for the 
implementation  of  reforms  and  investments  projects  included  in Poland´s recovery and 
resilience  plan is  expected  to  do a  significant  harm  to  environmental  objectives  within  the 
meaning  of  Article  17  of  Regulation  (EU)  No  2020/852 (the  principle  of  ‘do  no  significant 
harm’). This would warrant a rating of A under the assessment criterion 2.4 of Annex V to the 
RRF Regulation.  

4.5. Green transition 

Climate target 

Measures proposed in the plan to support climate change objectives account for 42.7% 
of  the  plan´s  total  allocations,  which  exceeds  the  37%  threshold.  In  absolute  terms,  the 
highest  contributions  towards  this  target  come  from  measures  targeting  offshore  wind 
installations, building renovations, railway modernisation, clean rolling stock, investments in 
green urban transition, and support to hydrogen technologies. The tagging applied follows the 
methodology  for climate tracking in  line with  Annex VI of the Regulation and the relevant 
conditions set out in the Regulation for applying specific climate co-efficients are reflected in 
the  description  of  milestones  and  targets  included  in  the  annex  to  the  draft  Council 
implementing decision. Where appropriate, the tagging is applied the sub-measure level, e.g. 
in  the  case  of  green  urban  investments,  railway  investements  and  bus  investements.  The 
increase of climate coefficient has not been proposed. 

49 

 
 
 
 
 
 
 
 
 
 
 
Table 6: Climate contribution of the components in the Polish recovery and resilience plan 

Component 

A - Resilience and competitiveness of the 
economy 

B - Green energy and energy intensity 
reduction 

C - Digital transformation 

D - Efficiency, accessibility and quality of the 
health system 

Cost (EUR 
million) 

Climate 
contribution 
(EUR 
million) 

Climate 
contribution 
(% of total 
cost) 

4,700 

130.4 

0.4% 

13,868 

8,766.2 

24.8% 

4,897 

4,381.5 

74 

0 

0.2% 

0% 

E - Green, smart mobility 

7,517 

6,119.3 

17.3% 

F - Improving the quality of institutions and the 
conditions for the implementation of the RRP 

0 

0 

0% 

Total 

35,363.5 

15,089.9 

42.7% 

Green transition 

Reforms and investments included in Poland’s recovery and resilience plan are expected 
to make a significant contribution to the gradual decarbonisation of the economy. The 
recovery and resilience plan builds on the National Energy and Climate Plan (NECP) 2021-
2030 and Poland's Energy Policy until 2040 (PEP2040), an energy transition strategy adopted 
in February 2021. The strategy envisages a gradual transition away from coal with no more 
than  56%  of  electricity  generated  from  coal  in  2030  (in  the  scenario  with  high  CO2  price 
increases, the share of coal could fall to 37%) and at least 23% renewables in gross final energy 
consumption,  while  primary  energy  consumption  decreases  by  23%  (compared  to  PRIMES 
2007 projections). The planned actions should reduce greenhouse gas emissions by 30% by 
2030 (compared to 1990).  

The recovery and resilience plan includes important reforms and sizable investments in 
energy and transport which are expected to accelerate Poland’s green transition towards 
a  low-carbon  economy  and  to  contribute  to  the  European  Green  Deal  objectives  of 
reducing emissions by at least 55% by 2030 and achieving climate neutrality in the EU 
by 2050. Reforms and investments in energy will be focused on supporting energy efficiency, 
heat  sources  in  district  heating,  renewables,  hydrogen  and  alternative  fuels,  transmission 
networks and smart infrastructure, and industry decarbonisation. In transport, the focus will be 
on the development and modernisation of rail, clean passenger transport and inter-modality. 
Investments  in  water  and  waste-water  management  will  aim  at  adapting  to  climate  change, 
while ensuring sustainable water use. 

After  years  of  relative  stagnation  in  the  share  of  renewables  in  Poland’s  energy  mix, 
measures included in the recovery and resilience plan are expected to unlock the potential 

50 

 
 
 
for  investments  in  that  field.  Poland  will  significantly  increase  the  installed  capacity  of 
onshore wind farms and photovoltaic installations. Doubling the installed capacity of these two 
technologies  from  11.2  GW  to  23.5  GW  in  2026  will  contribute  to  stepping  up  Poland’s 
decarbonization. The provisions prescribing the minimum distance between installations and 
dwellings (so-called 10H distance rule) that halted the development of onshore wind will be 
relaxed. The existing renewables support scheme will be prolonged and a long-term auctioning 
plan will be published in order to provide the predictability necessary to investors. Individual 
and  community  prosumers  will  be  supported  through  a  dedicated  regulatory  framework, 
notably through provisions on group billing in micro-grids. The development of offshore wind 
in the Baltic Sea will be supported by a dedicated legal framework and will be financed to a 
large extent through the RRF, both the project preparation phase with the development of a 
dedicated  port  and  the  actual  construction  of  the  wind  farms.  Under  the  plan,  decentralised 
renewables (mostly solar and wind) for energy communities and companies will be targeted 
through pre-investment and investment support. The above will be combined with investments 
in developing and modernising the electricity grid and introducing smart digital solutions to 
allow for the integration of additional renewables capacity. 

Energy efficiency measures included in the plan are expected to significantly decrease the 
negative impact of the current coal-based heating systems on greenhouse gas emissions 
and  other  air  pollutants,  while  increasing  energy  efficiency  in  the  end-use  (buildings, 
industry). Poland has persistent problems in complying with air quality standards stemming 
from the EU air quality directives. In addition, according to the WHO, as many as 36 of the 50 
most polluted cities in the EU were Polish cities. This is primarily due to coal-based individual 
heaters combined with a low energy efficiency of buildings. The recovery and resilience plan 
therefore rightly places an emphasis on accelerating the transition to clean alternatives. This 
will be achieved by upscaling and simplifying the Clean Air Priority Programme, which is the 
main vehicle for investment support in the energy efficiency of residential buildings. The level 
of  support  will  be  modulated  according  to  the  scope  of  investment,  but  will  also  take  into 
account the purchasing power of beneficiaries. Support to gas-fired boilers will be provided as 
part of a wider renovations scheme. In addition, new affordable housing supported under the 
recovery and resilience plan will meet efficiency standards going significantly (20%)  above 
near-zero energy building standards. This will be coupled with a reform providing for a pre-
determined  higher  level  of  subsidy  for  low-income  households.  These  measures  will  be 
combined  with  a  series  of  important  reforms  under  a  revised  National  Air  Protection 
Programme, which will mandate an end of any public subsidies to coal-fired heaters as of 2022 
and provide for a stronger enforcement of air quality standards set locally. Complementing that 
will be mandatory quality standards for solid fuels and a prohibition of misleading marketing 
in  that  sector.  Heating  will  be  also  addressed  at  the  district  heating  level  with  significant 
investments  in  clean combined heat  and power generation, meeting strict  ‘do no significant 
harm’ requirements. Additional reforms will be oriented towards simplifying and upscaling the 
Energy  Efficiency  Obligation  scheme  and  encouraging  the  use  of  Energy  Performance 
Contracts in the public sector.  

Poland’s recovery and resilience plan includes a comprehensive package of reforms and 
investments  aimed  at  supporting  the  production  and  distribution  of  hydrogen  and 
alternative fuels.  This  will include the adoption of legislation setting out  the details  of the 
functioning of the market, implementing EU law, taking into account the DNSH principle, and 
implementing a system of incentives, primarily for the production of renewable hydrogen, as 
well as low-carbon hydrogen that will comply with the GHG emission threshold . Support is 
planned  for  the  development  of  hydrogen  technologies  as  well  as  infrastructure  for  the 
production,  storage,  transport  and  use  of  hydrogen  as  a  fuel  in  various  sectors  (transport, 

51 

 
 
industry, heating and professional energy). It is expected that these measures will speed up the 
process of phasing out fossil fuels. 

The expected long-term increase in the cost of fossil fuels will present a major challenge 
to the competitiveness of Polish enterprises given the reliance of the economy on coal. In 
that context the recovery and resilience plan includes a dedicated investment support scheme 
aimed  the  implementation  of  green  solutions  in  companies.  The  scheme  will  focus  on 
improving industrial and energy processes in order to increase energy efficiency together with 
investments in renewable and low-carbon energy sources. In order to ensure coherence with 
the  EU  Emissions  Trading  System  for  companies  covered  by  the  latter,  investment  support 
under the plan will aim at thresholds substantially below benchmarks for the free allocation of 
allowances.  

In view of the fast-developing renewable energy sources, including energy generated by 
prosumers,  investments  in  energy  storage  systems  are  necessary  to  ensure  the  stable 
operation of the electricity grid. The plan envisages supporting both large-scale and small-
scale energy storage solutions. Pumped storage offers a reliable option that can quickly switch 
from the energy storage function to electricity generation. Backyard electricity storage facilities 
at the level of a prosumer can contribute to ensuring local stability of supply. 

In line with the 2019 and 2020 country-specific recommendations, measures in transport 
are focused on shifting the transport system to zero and low-emission mobility across a 
number of areas. The key challenges are the significant emissions and air pollution – mainly 
due to road transport – with a significant increase over the last decades (+219% emissions in 
the  period  1990-2019),  as  well  as  road  safety.  Reforms  aimed  at  making  transport  more 
sustainable are focused on mandatory clean vehicle procurement, the promotion of e-charging 
points in residential buildings and support to the preparation of Sustainable Urban Mobility 
Plans.  In  rail,  reforms  will  lower  infrastructure  access  charge  for  operators  affected  by  the 
economic crisis and promote intermodal transport. Road safety is addressed through important 
reforms providing greater protection to pedestrians and investment aimed at increasing road 
safety, with the ambition of decreasing road fatalities and seriously injured people across the 
country  by  50%  by  2030.  Significant  investments  are  targeting  transport  sustainability, 
including an upgrade of almost 500km of railway lines to increase capacity and speed for both 
freight and passengers; to promote clean public transport including with the purchase of zero-
emission  buses  for  urban  and  inter-urban  transport  and  zero-emission  rolling  stock  for  rail 
transport. Investments in rolling stock are expected to be  provided through schemes open to 
all  actors  and  non-discriminatory,  or  as  part  of  a  clearly  defined  Public  Service  Obligation 
(PSO) contract, in which case at the end of the contract the rolling stock will be made available 
to the next public service operator at market conditions net of public support. Support will only 
be granted to zero-emission rolling stock and equipped with ERTMS. Any intervention should 
comply with  the Technical  Specifications for  Interoperability (TSI). Additional  investments 
will be oriented towards increasing the capacity of inter-modal terminals, digitisation and road 
safety. Poland will also set up a dedicated investment fund which will provide equity or debt 
support  for  enterprises'  investment  projects  related  to  the  development  of  low  and  zero-
emission solutions in the field of sustainable mobility and energy, focusing on SMEs and mid-
caps. In order to ensure that this supply is matched with increased demand for clean vehicles, 
the purchasing of the latter will be encouraged through dedicated fiscal/financial measures in 
line with the “polluter pays’ principle.  

Water  and  wastewater  management  will  be  addressed  through  reforms  and  through 
investments  that  expand  wastewater  systems  in  rural  areas  and  adapt  those  areas  to 
climate  change  through  water  management  measures.  The  proportion  of  the  population 

52 

 
 
connected  to  wastewater  networks  remains  low.  This  is  particularly  the  case  of  rural  areas 
where currently 16% of the population does not have access to a drainage system and 42% does 
not have access to a sewage system. The recovery and resilience plan focuses therefore on rural 
areas, while recognising that urban areas also require significant investments to be financed 
through other resources.  A dedicated reform will  improve the conditions  for investments  in 
rural  areas  in  water  management  and  resource  efficiency  and,  as  a  result,  increase  the 
availability of water resources in rural areas through increased retention capacity. The proposed 
amendments  will  comply  with  the  requirements  laid  down  in  the  ‘Do  no  significant  harm’ 
Technical Guidance, in particular, they shall ensure compliance with the EU environmental 
legislation, including the EIA Directive and the Water Framework Directive. The amendment 
shall not lead to any deterioration of the level of compliance with EU environmental legislation. 
Water  management  in  rural  areas  will  also  be  addressed  through  reforms  and  investments 
aimed  at  drought  adaptation  and  flood  prevention;  improving  water  efficiency  by  properly 
regulating  water  relations  in  agricultural  areas  and  reducing  run-off.  Nature-based  climate 
change resilient methods and practices for water management in agricultural lands and forests 
will be prioritized, while possible further action will be supported once the resilient methods 
and practices have been exhausted, provided their need and nature is justified appropriately 
and does not affect negatively the good status of water bodies or the biodiversity objective. 
Taking into account the future impacts of climate change based on the best available science, 
only projects that do not lead to a deterioration of the status of surface waters and groundwater 
and do not prevent the improvement of the ecological status or potential of the affected water 
bodies will be supported. 

Poland’s  recovery  and  resilience  plan  also  includes  measures  that  will  contribute  to 
"closing the loop" of product life cycles through greater recycling and re-use. Changes to 
the  legislative  framework  shall  enable  trade  in  secondary  raw  materials  and  will  be 
accompanied by investment  supporting the development of technologies  contributing to  the 
creation of a market for secondary raw materials. The plan will also finance solutions aimed to 
develop and improve or implement green technologies related to the circular economy. 

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  recovery  and 
resilience plan is expected, to a large extent, to make a significant contribution to the green 
transition and to address the challenges resulting from it and ensures that at least 37% of its 
total  allocation  contribute  to  the  climate  target.  This  would  warrant  a  rating  of  A  under 
criterion 2.5 of Annex V to the RRF Regulation. 

4.6. Digital transition 

Digital transition 

Measures  contributing  to  the  digital  transition  account  for  21.3%  of  the  plan’s  total 
allocation, exceeding the required  minimum target of 20% outlined in the Regulation. 
Out of the plan’s six components, component C on Digital Transition clearly stands out as the 
main  contributor  to  the  digital  target  (with  an  allocation  of  EUR  4,818,000,000),  with 
interventions in network deployment, e-services in the public administration, education, digital 
skills  and  cybersecurity.  This  is  followed  by  digital  investments  in  innovation  and  labour 
market  (Component A),  healthcare services (Component D),  green energy  and  reduction of 

53 

 
 
 
energy  intensity  (Component  B)  and  sustainable  transport  (Component  E).  Taken  together, 
these components contribute EUR 7,535,000,000 to digital objectives. 

Digital tagging in the plan is in line with the methodology set out in Annex VII of the RRF 
Regulation.  Specific  weighting  coefficients  and  intervention  fields  are  identified  for  the 
calculation of each measure’s support to the digital objectives. Each investment is correctly 
associated with a single intervention field, although the plan could be improved by considering 
the  sub-measures  associated  to  some  investments  and  indicating  the  respective  intervention 
field for each sub-measure, for instance on cybersecurity (C3.1.1) and investments to digitise 
SMEs  (A4.4.1)  Otherwise,  the  choice  of  intervention  field  is  well-justified  and  reflects  the 
nature, focus, objective or expected outcome of the investments included in each component. 
The plan does not propose to increase the digital coefficients  for any measure. The tagging 
exercise is performed considering measures financed under both the grant and loan envelope.  

Table 7: Digital contribution of the components of the Polish recovery and resilience plan 

Component 

A - Resilience and competitiveness of the 
economy 

B - Green energy and energy intensity 
reduction 

Cost (EUR 
million) 

Digital 
contribution 
(EUR 
million) 

Digital 
contribution 
(% of total 
cost) 

4,700 

1,176  

3.3% 

13,868 

200 

0.6% 

C - Digital transformation 

4,897 

4,818 

13.6% 

D - Efficiency, accessibility and quality of the 
health system 

4,381.5 

1,000 

2.8% 

E - Green, smart mobility 

F - Improving the quality of institutions and the 
conditions for the implementation of the RRP 

7,517 

0 

341 

0 

1.0% 

0 

Total 

35,363.5 

7,535 

21.3% 

Digital transition 

The  reforms  and  investments  put  forward  in  the  plan  jointly  represent  a  significant 
contribution  to  the  digital  transformation  of  the  Polish  economy  and  society.  Poland’s 
main digital challenges include legal and administrative obstacles to the widespread roll-out of 
high-speed broadband networks, particularly in  rural  areas, low or ineffective use of digital 
tools  in  public  administration  and  the  delivery  of  public  services,  insufficient  digital  skills 
among students, teachers and, in general, among the adult population and also the lack of a 
comprehensive  digitalisation  policy  for  education.  Finally,  the  increasing  number  of  cyber-
attacks that show growing threats to cybersecurity also constitutes an important challenge. The 

54 

 
 
 
RRP is expected to tackle these challenges in an ambitious manner, in line with the EU Digital 
Strategy11. 

The  Polish  recovery  and  resilience  plan  dedicates  an  entire  component  to  the  digital 
transition. There are also reforms and investments in the digital sphere throughout the plan, 
amounting  to  21.3%  of  the  total  plan  allocation.  Component  C  is  dedicated  to  the  digital 
transformation of Poland and consists of three sub-parts: C1 on improving access to high-speed 
internet;  C2  on  developing  and  consolidating  e-services,  creating  the  conditions  for  the 
development of digital breakthrough applications in the public sector, the economy and society, 
and  improving  communication  between  public  institutions,  citizens  and  businesses;  C3  on 
increasing  security  in  cyberspace,  securing  data  processing  infrastructure  and  digitising 
security services infrastructure. The other four components of the Plan also contain measures 
that contribute to the digital transition, for instance in the areas of innovation, labour market, 
agriculture, green energy and reduction of energy intensity, health and transport, thus reflecting 
Poland’s objective to support the digital transition and to address the related challenges with a 
broad, cross-cutting approach.  

The largest allocation of financial resources within the digital component is dedicated to 
connectivity,  with  the  purpose  of  boosting  the  deployment  of  very  high-capacity 
networks, including fibre and 5G. This will be done in line with the best practices of the EU 
Connectivity Toolbox.12 The total amount allocated to investments in network infrastructure is 
EUR 1.4 billion for fixed broadband and EUR 1.2 billion for mobile broadband. With these 
resources  Poland  aims  to  provide  universal  access  to  high-quality  telecommunication 
infrastructure  and  modern  electronic  communication  services  in  market  failure  areas 
throughout the country, narrowing the gap between urban and rural areas. The investments will 
focus on: (i) covering 930,000 households in white NGA areas13, to achieve broadband internet 
access with a capacity of at least 100 Mb/s and possibly increasing it to Gigabit capacity; (ii) 
supporting  the  roll-out  of  5G  network  by  concluding  at  least  100  contracts  with  telecom 
operators  deploying  additional  base  stations  in  market  failure  areas.  These  measures  are 
expected to contribute to the achievement of the goals set out by the National Broadband Plan, 
namely speeding up the roll-out of ICT of the country by 2025, as well as achieving the EU’s 
2025 5G and Gigabit connectivity objectives. 

The reforms and investments in the RRP aiming at the digitalisation of the public sector 
are expected to contribute to the digital transformation of both the public and private 
sectors. According to the Digital Economy and Society Index (DESI 2021)14 Poland ranks 22nd 
on digital public services, well below the EU average, with only 49% of users of e-government 
services. To foster the development of public e-services, a more efficient management of IT 
resources in the public administration and a better interaction with citizens and businesses are 
needed.  Poland  will  introduce  provisions  for  the  digitalisation  of  processes  in  the  public 
administration,  on  the  management  of  electronic  documents  (online  handling  of  cases, 
production and collection of documentation, integration of e-services across administrative and 

11 COM(2020)67 - Shaping Europe’s Digital Future 
12 EU Connectivity Toolbox of 25 March 2021 
13  Next  Generation  Access:  Access  networks  which  rely  wholly  or  partly  on  optical  elements  and  which  are 
capable  of  delivering  broadband  access  services  with  enhanced  characteristics  as  compared  to  existing  basic 
broadband networks. 
14 Digital Economy and Society Index Report for Poland, 2021 

55 

 
 
                                                           
departmental boundaries) as well as on the introduction of electronic structured invoices. At 
the same time, a number of projects are expected to promote automated customer services and 
other digital solutions such as electronic identification, e-signature and data sharing platforms 
for  citizens  and  businesses  through  breakthrough  technologies  such  as  internet  of  things, 
blockchain and artificial intelligence. These investments are expected to have a  long-lasting 
impact  on  the  digital  transformation  of  the  public  administration  and  will  be  essential  for 
strengthening the interoperability capacities of its digital services. 

The  approach  to  digital  skills  addresses  the  two  strategic  priorities  of  the  European 
Digital Education Action Plan 203015. First, fostering the development of a high-performing 
digital  education  ecosystem  and,  second,  enhancing  digital  skills  and  competences  for  the 
digital transformation. The reforms foreseen in the area of primary and secondary education, 
skills  and  lifelong  learning  are  expected  to  facilitate  the  entry  in  the  labour  market  and  to 
prevent the digital divide by guaranteeing equal access to digital infrastructure, equipment and 
skills.  The  RRP  tackles  these  objectives  with  four  different  initiatives.  First,  through  the 
adoption  and  implementation  of  a  Digital  Competence  Development  Programme,  a  multi-
annual programme aimed at strengthening the development of digital competences in formal, 
informal  and  non-formal  education.  Secondly,  by  the  adoption  of  binding  minimum  legal 
standards for equipping schools with digital infrastructure that will support the implementation 
of investments in ICT, enabling the use of digital technologies in learning on an equal level in 
each school. Thirdly, via the policy on digitalisation of education, which is expected to create 
a first, comprehensive strategy, constituting the basis for changes in the education system and 
defining  the  directions  of  digitalisation  of  the  education  system  in  the  short  and  long  term. 
Finally, the large-scale investment in the ICT equipment for primary and secondary schools 
(including in vocational education and training), kindergartens, as well as examination centres 
will support the implementation of the above policy measures, facilitating a more efficient and 
meaningful integration of ICT in education. 

As far as the digitalisation of businesses is concerned, digital competences for SMEs are 
partially targeted by the investment on equipping companies to work remotely. The RRP 
envisages supporting 3,000 micro, small and medium-sized enterprises out of nearly 2 million 
with advice to firms on digitalisation, remote training for staff and the purchase of licenses and 
software to enable remote communication. In addition, the digital transformation of the public 
administration is expected to work as an incentive for companies to do the same, therefore the 
focus on e-services can indirectly contribute to the digital transformation of companies.  

Cybersecurity  has  a  prominent  role  in  the  Polish  RRP,  with  the  purpose  of  ensuring 
internet security and preventing cybercrime. Further to the growing number of cyber threats 
and  incidents,  Poland  intends  to  increase  the  resilience  of  IT  systems  in  the  public 
administration, state services responsible for security and businesses  as well as raise public 
awareness of security-related problems, in line with the Polish Cybersecurity Strategy. This 
includes improving capacity for incident detection and response, notably by setting up regional 
Security  Operation Centres (ISACs),  sectoral  Computer  Security  Incident  Response  Teams 
(CSIRTs),  as  well  as enhancing public-private information sharing  and  crisis  management 
systems. 

With  RRF  support,  Poland  will  participate  in  the  Common  Data  Infrastructure  and 
Services EU multi-country project on Cloud and Edge Computing, in order to develop 

15 COM(2020)624 - Digital Education Action Plan 2021-2027 Resetting education and training for the digital age, 
30 September 2020. 

56 

 
 
                                                           
the next generation of joint capabilities in data processing with the participation of Polish 
businesses  and  technological  actors.  Poland  committed  to  participate  in  this  EU  multi-
country  project  expected  to  be  implemented  as  a  potential  Important  Project  of  Common 
European Interest (IPCEI) on Next Generation Cloud Infrastructure and Edge Services. This 
project will aim at the development and first industrial deployment of advanced R&D projects 
towards the future of data processing along the cloud to edge continuum. It will also provide 
networking opportunities among businesses and research and technology organisations while 
fostering  know-how,  knowledge  transfer  and  capacity-building.  The  project  is  expected  to 
develop the next generation of cloud and edge solutions, with high levels of innovation, energy 
efficiency and a positive environmental impact contributing to the EU Green Deal ambition. 

The  plan  envisages  several  investments  in  the  area  of  innovation  that  will  equally 
contribute to the digital  objectives.  Projects  related to  the development  and equipment  of 
competence centres (specialist training centres, implementation support centres, observatories) 
and infrastructure will support an innovation ecosystem for unmanned vehicles. Investments 
in support of robotisation and innovation in enterprises will finance digitisation of processes 
that are expected to result in improved business efficiency.  

A number of investments aim to enhance digital transition in the agricultural sector. In 
particular,  investments  to  encourage  Agriculture  4.0  solutions  in  farms,  including  the 
purchasing of sensors and the implementation of digital ICT systems, can increase productivity 
while encouraging more environmentally friendly production practices.  

Some investments in the energy component also have a digital dimension. In particular, 
investments  in  the  development  of  transmission  networks,  including  smart  electricity 
infrastructure are expected to support the development of modern digital technologies in the 
electricity market that are necessary to better integrate dispersed renewables sources. 

In the health sector, significant investments for the digitalisation of health services are 
envisaged. Investments cover the launch of three central services: a Patient Health Analysis 
Tool, an AI-based decision-making support tool for doctors, and a central repository of medical 
data integrated with other key healthcare systems. Within five years of the RRP implementation 
Poland is committed to reach the level of 60% of medical document types digitised and 70% 
of adult patients covered by the Patient Health Analysis Tool. 

In the transport sector, digital investments to promote the efficiency and safety of road 
and railways transport are envisaged. The plan includes direct investments to digitalise road 
transport (via Intelligent Transport Systems and equipment for road safety enforcement and 
controls  including  100  automatic  road  traffic  surveillance  devices)  and  railway  transport 
(through  trackside  and  on-board  ERTMS  deployment,  including  retrofitting  of  180  existing 
rolling  stock,  the  purchase  of  183  new  trains,  the  installation  of  railways  level  crossing 
automation  and  traffic  control  systems  in  35  railways  stations  and  of  dynamic  information 
system  in  27  locations).  These  are  important  investments  that  are  expected  to  enhance  the 
efficiency and safety of transport. Additional investments that facilitate the generalised use of 
e-ticketing for railway passengers are also foreseen. 

The measures in the Polish plan contributing to the digital transition or helping to address 
the related challenges are aligned with both national and European strategies. At national 
level,  the  reforms  and  investments  described  in  the  plan  are  consistent  with  the  Polish 
Broadband Plan and with the Polish Cybersecurity Strategy as well as national and regional 
programmes funded from Cohesion Policy, such as the Operational Programme Digital Poland. 

57 

 
 
At European level, they are aligned with initiatives like the EU Digital Strategy16, the European 
Gigabit  Society,  the  EU  Skills  Agenda,  the  European  Pillar  of  Social  Rights,  the  European 
Education Area and the Digital Education Action Plan. 

This  comprehensive  set  of  measures  is  expected  to  have  a  lasting  impact  on  Poland’s 
digital transformation and to address the challenges resulting from it.  The reforms and 
investments described are expected to be instrumental in developing the broadband network, 
improving the delivery of public services to businesses and citizens as well as the digitisation 
of public administration, while strengthening their resilience and cybersecurity. They will also 
contribute to the digitalisation of the education system and the development of digital skills. 
Enhancing the digital transition in agriculture can improve the resilience, sustainability, and 
productivity  of  the  sector,  which  is  particularly  relevant  given  that  the  agriculture  sector 
accounts for 2.7% of Poland’s GDP and 8.7% of Poland’s total greenhouse gas emissions. The 
digitalisation of electricity networks should contribute to a better integration of renewables and 
to reducing energy losses and emissions. In transport, the electrification of railways combined 
with traffic automation will provide incentives to users to switch from individual to collective 
mode  of  transportation.  Making  greater  use  of  e-health  digital  solutions  is  also  expected  to 
strengthen  the  efficiency,  accessibility  and  quality  of  health  services.  Altogether,  these 
measures should contribute to the long-term transformation of the Polish economy towards a 
digitalised society. 

*** 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  recovery  and 
resilience plan is expected, to a large extent, to make a significant contribution to the digital 
transition and to address the challenges resulting from it and ensure that at least 20% of its 
total allocation contributes to supporting digital objectives. This would warrant a rating of A 
under criterion 2.6 of Annex V to the RRF Regulation. 

4.7. Lasting impact of the plan 

The  recovery  and  resilience  plan  includes  a  package  of  measures  aimed  at  addressing 
most of the challenges identified in the context of the European Semester. The measures 
in the plan also are set to facilitate the green and digital transitions and strengthen the growth 
potential, job creation and economic and social resilience of Poland. The proposed reforms and 
investments are thus expected to have a lasting, positive impact on the Polish economy and 
society. 

Most of the components of the plan are assessed as having a lasting impact on Poland. 
The measures  presented  in  this respect  comprise structural  changes to  the administration or 
relevant institutions and policies. The lasting impact refers to policy areas where the estimated 
long-term impact on growth potential and employment is significant, as specified in Chapter 
4.3,  but  also  in  areas  where  structural  changes  are  expected  to  improve  social  and  cultural 
aspects that are not necessarily quantifiable.  

16  Shaping  Europe’s  Digital  Future:  https://ec.europa.eu/info/strategy/priorities-2019-2024/europe-fit-digital-
age/shaping-europe-digital-future_en 

58 

 
 
 
                                                           
 
Structural change in public administration and institutions 

Poland’s recovery and resilience plan includes relevant structural changes to the public 
administration  and  institutions.  Notably,  reforms  to  improve  the  law-making  process,  to 
enhance the independence of the judiciary and to encourage the uptake of digital solutions in 
the public sector are set to have a lasting impact. An important reform relates to limiting the 
use  of  fast-track  legislative  procedures  and  enhancing  the  use  of  public  consultations  and 
impact assessments in the law-making process, which paves the way for an improved and more 
to  simplify  and  streamline 
stable  regulatory  framework.  Another  reform  package 
administrative procedures, limit the number of formalities and digitalise the main channel for 
handling administrative and legal procedures, is set to improve transparency and enhance the 
delivery of public services, thereby reducing the administrative burden for businesses.  

Digitalisation efforts across a wide range of public institutions and administration levels 
have the potential to structurally enhance efficiency and improve the quality of public 
services. Reforms to digitalise the activities and administrative processes are set to structurally 
enhance efficiency in public administration and speed-up the delivery of public services. The 
plan also puts a strong focus on investing in e-governance infrastructure and on developing the 
digital skills of public staff, which has the potential to enhance innovation, reduce costs and 
improve productivity in the public administration. 

The reform of the hospital supervision system will support cost-efficiency and the quality 
of services. The hospital sector reform envisages changes to the supervision and management 
system of hospitals covered by public financing in order to ensure a lasting improvement in 
effectiveness, quality, and access to healthcare and long-term care. The reform provides for the 
creation of a professionalised system of supervision of hospitals, strengthening management 
and improving the uptake of modern management tools, methods and systems in health care. 
These measures are expected to improve the resilience of the healthcare system. 

The  reform  to  modernise  and  simplify  public  finance  management  will  strengthen 
Poland’s  budgetary  framework.  The  full  and  effective  implementation  of  several 
amendments  to  the  Act  on  Public  Finances  will  enable  a  more  efficient  and  accountable 
management of public funds, as well as to help ensure the sustainability of public finances and 
prevent an unsustainable increase of expenditure in the future. In particular, the introduction of 
a new model of budget management and a new medium-term budgetary framework will help 
ensure fiscal discipline and provide benchmarks against which budgetary developments can be 
assessed over time. The plan also includes a measure to extend the scope of the Stabilising 
Expenditure Rule (SER) to more general government units, which is set to support the stability 
of public finances and control the increase in public expenditure and public debt.  

Structural change in policies 

Structural changes in policies are envisaged in all components of the plan and most of 
them are expected to have a lasting impact. Many of these changes refer to a new energy 
model for the transition to climate neutrality. The transition is considered as an opportunity to 
leverage  the  national  economy  in  a  spirit  of  sustainable  development  by  promoting 
technological  advancement,  job  creation,  and  the  preservation  of  natural  resources.  This 
includes  measures  related  to  the  decarbonisation  of  the  energy  sector  and  industry,  the 
reduction of energy dependency, increasingly sustainable mobility, improved energy efficiency 
of  buildings,  and  the  deployment  of  new  technologies  for  renewable  hydrogen  and  other 
renewable gases. The plan is expected to also increase the productivity of Poland’s economy 
and strengthen its resilience against future shocks in line with the 2020 new Industrial Strategy. 

59 

 
 
Several  policy  changes  are  envisaged  to  improve  the  business  environment  and 
investment climate with a lasting impact on the country’s competitiveness and potential 
for attracting foreign investors. These cover measures to reduce the administrative burden 
on businesses, including the simplification of administrative procedures and the limitation of 
the  two-instance  procedure  to  a  reduced  number  of  cases,  as  well  as  measures  expected  to 
partially  address  the  shortcomings  related  to  the  Polish  judicial  system.  The  measures  to 
streamline the legislation in land planning are expected to enhance investment levels and to 
contribute to a more stable regulatory framework which enhances sustainability and the quality 
of services provided to citizens in municipalities. The amendments to the investment zone act, 
which  are  set  to  increase  the  number  of  areas  defined  as  special  economic  zones,  will  also 
contribute to increased investment levels and attract investors, particularly foreign ones. The 
agricultural sector is set to benefit from a reform that provides clear and defined principles for 
contractual  relations  in  the  agri-food  supply  chain,  which  is  expected  to  increase  business 
confidence,  particularly  for  SMEs  and  small  producers,  as  well  as  reinforced  research  and 
innovation capacity through investment in research infrastructure.  

Measures in the area of labour market and education will have a lasting positive impact 
by  increasing  labour  market  participation,  addressing  labour  market  segmentation, 
modernisation  of  vocational  education  and  training,  and  providing  up-skilling  and 
reskilling opportunities. The plan includes measures to improve the coordination of policies 
in  the  regions  on  vocational  education  and  training,  higher  education  and  lifelong  learning, 
which can have an important lasting impact on the education system as a whole. The plan also 
contains measures to  improve labour market  participation and address  labour shortages,  for 
instance  through  increased  availability  of  childcare  facilities  and  modernising  public 
employment services, as well as addressing labour market segmentation by reducing disparities 
in social security contributions between various work contracts.  

Poland  has  put  emphasis  on  broad  stakeholder  public  consultations.  Comments  from 
stakeholders have been considered in the preparation of the plan. This led, for example, to the 
inclusion of measures to increase access to 5G mobile networks, an amendment to the planned 
reform of spatial planning, and enhanced investments in offshore wind farms and digitalisation 
of education. A series of working meetings and thematic roundtables structured the dialogue, 
and a public website of the plan was launched in February 2021, where proposals could be 
submitted. 

The  implementation  of  the  Polish  RRP  will  be  subject  to  strict  supervision  and 
consultation,  which  will  ensure  that  the  measures  included  in  the  Plan  have  a  lasting 
impact in the Polish economy. The plan envisages the creation of a monitoring committee 
that will be tasked with supervising the implementation of the measures under the recovery and 
resilience  plan.  The  monitoring  committee  will  be  composed  of  the  main  stakeholders  and 
social  partners,  which  will  ensure  that  the  RRF  funding  is  used  in  the  most  effective  and 
efficient way, contributing to the lasting impact of the measures included in the plan. 

*** 

Taking into consideration all reforms and investments envisaged by Poland in its recovery and 
resilience plan, their implementation is expected to a large extent to bring about a structural 
change in the administration, in relevant institutions and in relevant policies and to have a 
lasting impact. This would warrant a rating of A under criterion 2.7 of Annex V to the RRF 
Regulation. 

60 

 
 
 
4.8. Milestones, targets, monitoring and implementation 

Adequacy of the structure tasked with the implementation of the plan, monitoring of progress 
and reporting  

According to the plan, the Ministry of Funds and Regional Policy is responsible for the 
coordination of implementation of the recovery and resilience plan in Poland. Particularly, 
the Ministry of Funds and Regional Policy is responsible for monitoring the implementation of 
the  plan,  verification  of  achievement  of  milestones  and  targets,  reporting  to  the  European 
Commission, establishing procedures for the implementation of the audit, and for drawing up 
and submitting payment requests and management declarations to the European Commission. 
Regarding  coordination  and  reporting  mechanisms  between  the  Ministry  of  Funds  and 
Regional Policy and other bodies responsible for the implementation of the investments and 
reforms  under  the  components,  the  description,  although  brief,  seems  adequate.  The  same 
applies to the information concerning the assurance of management verifications, in particular 
for the fulfilment of milestones and targets. This will depend on an information system, which 
has already been put in place. 

The plan provides a description of the institutional actors in charge of the implementation 
of individual reforms and investments. The plan clearly indicates in all components a public 
entity  in  charge  for  the  implementation  of  each  reform  and  investment.  These  are  mainly 
ensured  by  the  relevant  ministries,  but  also  other  public  entities  and  local  governments, 
particularly in the investment part. In some cases, more than one body is responsible for the 
implementation.  While there is  no comprehensive information  on a clear division  of labour 
among  them,  the  plan  indicates  a  body  in  the  lead  of  coordination  and  implementation  of 
particular investments and reforms. The responsible bodies involved in the implementation of 
each  reform  and  investment  will  liaise  with  the  Ministry  of  Funds  and  Regional  Policy  via 
dedicated working  groups to  discuss the state of  play  of the implementation of the plan, to 
identify problems and to work out relevant solutions. The plan does not provide more details 
on the operational arrangements of these meetings. Instead, it says that the meetings’ frequency 
and the composition of groups will be adapted on an ongoing basis to the specificities of the 
challenges identified during the implementation of the plan.  

A  dedicated  Monitoring  Committee  is  planned  to  fulfil  an  implementation  monitoring 
role. While the Ministry of Funds and Regional Policy is in charge of the verification and the 
effectiveness  of  achieving  milestones  and  targets,  a  dedicated  body  –  the  Monitoring 
Committee – is expected to ensure the correct implementation of the plan. It will be composed 
of  representatives  of  the  bodies  implementing  the  plan,  social  partners,  non-governmental 
organisations and local governments. The plan stipulates that the Committee will monitor the 
implementation of reforms and investments, ensure that funds are spent properly, analyse the 
impact  of  measures  on  the  economy  and  its  sectors,  society  and  regional  development,  and 
ensure that measures implemented under other funding sources are complementary. However, 
it is not specified if the Committee would be involved in defining criteria and procedures for 
calls  that  would  be  the  basis  for  disbursement  of  grants  under  the  plan,  which  would 
significantly strengthen the monitoring function of the Committee. The Committee will operate 
based on a law that is currently not yet enacted. 

Milestones, targets and indicators  

The plan includes relevant and well-defined milestones and targets. The plan combines 49 
reforms and 53 investments (broken down into 6 components) that are accompanied by 283 
milestones and targets, making the overall number of the latter reasonable and manageable. 

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They  indicate  key  steps  towards  the  implementation  of  reforms  and  investment  and  are 
considered  realistic  and  sufficiently  ambitious  to  address  the  relevant  challenges.  The  right 
proportion between milestones and targets is maintained, with the latter slightly predominating. 

Milestones dominate the first phase of the plan's implementation, laying the groundwork 
for investments resulting from the adopted reforms. Most of the milestones involve key 
amendments  to  the  framework  of  the  crucial  CSRs  public  policies  such  as  labour  market, 
healthcare, education, business environment, energy, transport, R&D, and aim to be adopted 
in  the  period  2021-2023.  Targets,  quantifying  the  objectives  of  investments  and  reforms 
dominate in the second period of implementation with an accumulation of targets at the end of 
the implementation. Intermediate targets or the monitoring steps are set to track the progress 
over the timespan. 

The distribution of milestones and targets over the period until August 2026 is as follows: 

  78 for 2021-2022 
  91 for 2023-2024 
  114 for 2025-August 2026 

For most of the reforms and investments, milestones and targets are designed around a 
life-cycle  approach,  which  ensures  that  the  overall  objective  shall  be  achieved.  For  the 
reforms the initial milestone is often associated with the entry into force of the important piece 
of legislation.  Investments  in  turn, commence by launching  a call for tenders. Reforms  and 
investments end up with either an implementing milestone or output oriented target. Milestones 
and targets to ensure appropriate climate tracking/digital tagging and compliance with ‘do no 
significant harm’ (DNSH) principle are also included.  

Indicators chosen for the implementation of milestones and targets are clear, realistic and 
robust.  Data  sources,  methodology  of  collecting  the  data  as  well  as  the  verification 
mechanisms of milestones and targets, that will trace the implementation of the reform  and 
investments,  are  described  properly.  More  details  shall  be  defined  in  the  Operational 
Arrangement to be concluded with the Commission, as prescribed in Article 20(6) of the RRF 
Regulation.  

Overall organisational arrangements  

While there is  currently no dedicated law in place, the arrangements set up to devise, 
negotiate and ensure an efficient and regular implementation of the plan seem to have a 
sufficient legal mandate. Poland has not enacted a separate law that would cover mandates, 
functions, remits and responsibilities of various bodies involved in the implementation of the 
plan. However, the plan  indicates other legal  bases  defining them.  In particular, the law on 
principles of the conduct of development policy (of 6 December 2006, subsequently amended) 
gives  a  clear  mandate  to  the  Minister  of  Funds  and  Regional  Policy  to  (i)  coordinate  the 
preparation and implementation of development strategies co-financed by development funds 
of the European Union or other foreign sources, and to (ii) prepare a draft of the development 
plan.  The  development  plan  is  defined  as  a  document  setting  out  reforms  and  investments 
involving European Union funds aimed at mitigating the social and economic consequences of 
the crisis and strengthening the country’s sustainable development. The legal mandate for other 
bodies  implementing  the  plan  is  specified  in  the  plan  itself  (adopted  by  the  Council  of 
Ministers),  in  a  law  defining  the  remit  of  particular  ministries  (of  4  September  1997, 
subsequently amended) and in other laws and regulations defining their operations. The plan 
stipulates that the Monitoring Committee will operate on a basis of a law, however without 

62 

 
 
providing  any  further  detail,  in  particular  on  the  appointment  criteria  and  modalities  for  its 
members.  

The plan provides some information on the administrative capacity. The brief description 
focuses mainly on underlining the experience of the bodies (and their staff) in charge of the 
implementation  of  the  plan  in  implementing  similar  undertakings,  and  in  particular  in 
implementing the EU structural funds. The plan states that the implementation of some parts 
of  the  plan  can  be  delegated  to  dedicated  (public)  bodies  and  agencies  that  have  sufficient 
experience and expertise in the area (those bodies are mentioned in the plan). According to the 
plan, around 1400 individuals will be involved in implementing the plan, including those that 
are currently in charge of the implementation of other EU funds in Poland. However, the plan 
does not specify how many of those individuals still need to be recruited. 

***  

The arrangements proposed by Poland in its recovery and resilience plan are expected to be 
adequate to ensure  effective  monitoring  and  implementation  of  the  recovery  and  resilience 
plan,  including  the  envisaged  timetable,  milestones  and  targets,  and  the  related  indicators. 
This would warrant a rating of A under the assessment criterion 2.8 of Annex V to the RRF 
Regulation.  

4.9. Costing  

Poland submitted information about cost estimates for all measures of the plan involving 
a cost. All measures across the six components of the plan include a cost estimate accompanied 
by relevant information on the methodology and calculations on how it was reached.   

Poland provided complete costing information following the structure recommended by 
the  Commission  and  complemented  with  additional  elements  in  various  pieces.  In  the 
Guidance to Member States adopted by the Commission on 22 January 2021 Member States 
were  invited  to  fill  a  specific  table  providing  information  on  cost  estimates,  breakdown, 
methodology, reference data and possible independent validation. The table was intended to 
summarise  the  key  information  and  evidence  on  costing,  including  supporting  documents 
(evidence of similar past projects financed by the EU with information on whether they have 
been  reimbursed  and  subject  to  a  control  cycle,  review  or  accounting  reports,  studies  to 
substantiate  key  assumptions,  etc.).  Poland  provided  a  comprehensive  table  following  the 
structure recommended by the Commission and complemented it with specific spreadsheets 
for each measure as well as a short description of the cost estimates in the main document of 
the recovery and resilience plan. 

Reasonable costs 

The methodology and assumptions used to make the cost estimates are overall clear even 
though  they  vary  across  measures.  In  some  cases,  the  costing  estimate  is  reached  by 
aggregating  the  estimated  cost  of  the  various  inputs  required  for  the  implementation  of  the 
measure at stake. In other cases, the costing estimate is reached by referring to a unit cost of 
the output expected by that measure, using a methodology that is similar to the Simplified Cost 
Options used for some projects under ESIF and referred in Recital 18 of the RRF Regulation. 
Some measures refer to market prices to set the final cost estimate. 

All  measures  financed  by  the  recovery  and  resilience  plan  for  Poland  refer  to  costs 
incurred  and  actions  that  commenced  after  1  February  2020  and  entail  only  non-
recurrent  costs,  except  for  duly  justified  exceptions.  All  measures  included  in  the  plan 

63 

 
 
 
started after 1 February 2020, and all the costs are recorded after that date. In addition, some 
costs,  for  instance  staff  costs  under  a  project  related  to  the  development  and  equipment  of 
competence centres, which are classified under current expenditure in the European System of 
Accounts 2010 will be financed considering their strict temporary nature, their close link with 
the implementation of a specific investment or reform of the plan and their sustainability. All 
costs are therefore fully in line with Article 5(1) of the RRF Regulation. 

Poland did not provide an independent validation for any of the measures of the plan. 
The guidance note of 22 January 2021 encouraged Member States to provide an independent 
validation  of  estimated  costs.  Member  States  were  encouraged  to  seek  the  opinion  of  their 
national productivity boards or independent fiscal institutions on their recovery and resilience 
plans, including possible validation of cost estimates of their recovery and resilience plan. Even 
though  for  various  measures  Poland  referred  to  various  sources  of  independent  validations, 
these were not from independent bodies with specific audit powers or from the two institutions 
mentioned  above.  However,  it  was  not  considered  as  a  negative  element  per  se  in  the 
assessment as it was not a compulsory element for providing justification and evidence about 
the cost estimates of the plan.   

Plausible costs 

The volume and quality of information about the cost estimates is sufficient even though 
it varies across measure. The details as regards the methodology and the assumptions made 
to reach these cost estimates are thorough in many cases while more limited for other measures. 
The quality of the description of the methodologies and calculations made to reach the costing 
estimated  and  comparative  cost  data  is  relatively  heterogeneous.  The  sources  taken  as  a 
reference to make the cost estimates are clear for most measures. The bulk of them refer to past 
projects financed by the European Structural Investment Funds (ESIF). The other references 
mention various studies and evaluations both from public and private sectors. For a limited 
number of measures the description of the costing methodology and references to which the 
costing estimates relate are not fully detailed and are not always clear.   

Poland provided a significant amount of evidence and justification for the cost estimates. 
The  cost  estimates  of  most  measures  are  accompanied  by  a  high  volume  of  supporting 
documents and evidence on the basis of which the costing estimates were reached. These are 
mostly past projects but there are also cases of studies on specific areas. However, the relevance 
of some of those documents has not been ascertained for all cases. 

Risk of double financing from Union funds 

The cost estimates of the plan provide a relatively high level of assurance about the risk 
of double financing from the Recovery and Resilience Facility and other Union funds. For 
a significant number of measures in the plan there is a reference that part of the project has 
been or is expected to be financed by other EU budgetary sources, where relevant. The principle 
of  additionality  and  complementary  of  funding  of  Article  9  provides  that  the  reforms  and 
investment projects financed by the RRF may receive support from other Union programmes 
and  instruments  provided  that  such  support  does  not  cover  the  same  cost.  The  information 
provided refers to specific type of cost that will be financed by the various EU instruments with 
some exceptions where those details are not always fully clear enough. In addition, under the 
monitoring  arrangements  the  plan  specifies  that  every  administration  responsible  for  the 
implementation of the various measures of the plan will make controls in relation to legality 
and  regularity  and  will  adopt  the  necessary  measures  to  prevent,  correct  and  sanction  any 
misuse of funding, including the double financing of the same cost. It is important that this is 
closely  monitored  by  Polish  authorities  during  implementation  in  particular  for  those  cases 

64 

 
 
where it is not  yet known precisely at the stage of approval of the Recovery and Resilience 
Plan, whether the reforms and investment projects would be co-financed by other Union funds 
in the future. 

The costing estimates of the plan are commensurate to its expected economic and social 
impact. The recovery and resilience plan is expected to contribute to effectively addressing all 
or  a  significant  subset  of  challenges 
the  relevant  country-specific 
recommendations  and  contains  measures  that  are  expected  to  foster  economic  growth  and 
economic  cohesion  in  an  inclusive  manner,  to  boost  the  growth  potential  of  the  Polish 
economy, to stimulate job creation, and mitigate the adverse effects of the crisis.  

identified 

in 

*** 

The justification provided by Poland on the amount of the estimated total costs of the recovery 
and resilience plan is to a medium extent reasonable, plausible, in line with the principle of 
cost-efficiency  and  is  commensurate  to  the  expected  national  economic  and  social  impact. 
Poland provided sufficient information and evidence that the amount of the estimated cost of 
the  reforms  and  investments  of  the  recovery  and  resilience  plan  to  be  financed  under  the 
Facility is not covered by existing or planned Union financing. This would warrant a rating of 
B under the assessment criterion 2.9 of Annex V to the RRF Regulation. 

4.10. 

Controls and audit 

Robustness of internal control system and distribution of roles and responsibilities  

The plan provides sufficiently detailed information on the two-level national set-up for 
the internal control system of the RRP. The Polish set-up for the internal control system of 
the  RRP  consists  of  two  levels:  management  verifications  by  institutions  in  charge  of  the 
implementation of the reforms and investments; and audits carried out by the national audit 
body. Both levels are presented in the plan.   

The Ministry of Funds and Regional Policy coordinates the implementation of the Plan, 
while management verifications will be done by institutions in charge of the operational 
implementation  of  the  plan.  The  Ministry  of  Funds  and  Regional  Policy  is  the  central 
coordinating body for the RRP implementation and is responsible for the overall coordination, 
monitoring and reporting of the plan. It is also a single point of contact for the Commission. 
The Ministry is also in charge of preparing the payment claims and management declarations. 
At the same time, relevant internal units of the institutions responsible for the implementation 
of  the  reforms  and  investments  will  verify  compliance  of  implemented  measures  with 
applicable Union and national law. They are also in charge of the verification of progress in 
the achievement of defined milestones and targets.   

A dedicated department at the Ministry of Finance and regional offices will be in charge 
of audits. The plan stipulates that audits will be carried out by the department of the audit of 
public funds at the Ministry of Finance and 16 regional offices in the country. The audit body 
will  verify  the  correct  implementation  of  reforms  and  investments,  achievement  of  defined 
milestones and targets, and the effectiveness of mechanisms to prevent fraud and conflicts of 
interest. It will also detect and correct serious irregularities and avoid double funding. Finally, 
it will check the security of an IT system supporting the implementation of the RRF. The audit 
work will be carried out at the level of the coordination body, the bodies responsible for the 
reforms  and  investments,  other  bodies  supporting  implementation  of  the  plan  and  final 
recipients. This is the same audit authority as the one for the ESI Funds. Its independence from 

65 

 
 
 
the coordination body and institutions responsible for the implementation of the reforms and 
investments will be ensured. Therefore, the segregation-of-duties principle will be respected.  

The plan provides a general description of an audit approach. The overall audit approach 
applied  to  the  RRF  will  encompass  two  major  elements.  First,  system  audits  to  provide 
reasonable assurance that the system functions effectively and prevents, detects and corrects 
irregularities.  Secondly,  audits  of  investments  and  reforms  to  verify  the  achievement  of 
milestones and targets. The plan includes main elements on the audit work of the audit body 
and a commitment to prepare an audit strategy within 3 months of the adoption of the plan 
which will be afterwards updated annually.   

The internal control system seems to be robust. The plan presents a well-defined structure 
of the internal control system. This particularly applies to the collection and verification of the 
data on the achievement of milestones and targets. The plan specifies the sources of relevant 
information and transmission channels that the Ministry of Funds and Regional Policy will use 
to  collect  them.  It  also  stipulates  that  this  ministry  will  verify  them.  Overall,  the  legal  and 
institutional framework to prevent and combat corruption is largely in place.  

Adequacy of control systems and other relevant arrangements  

The outline of the control system put in place seems appropriate and control actors are 
identified across all levels. For the management verifications at component level, the level of 
information is not sufficient to draw conclusions on the adequacy of management verifications 
carried  out  by  the  institutions  responsible  for  the  implementation  of  the  reforms  and 
investments. The second level of the control system is entrusted to an independent audit body 
which  acts  with  complete  autonomy  and  independence  from  the  bodies  responsible  for 
managing the actions and operations covered by each component. The plan indicates that the 
IT system is already operational to support the implementation of the plan. The same system 
will be used for the collection and storing of data on final beneficiaries in accordance with the 
provisions of Article 22(2)(d) of the RRF Regulation. This system will be also used for the ESI 
Funds in the programming period 2021-2027. The audit body committed in the plan that the 
first audit performed before the first payment request will provide assurance on the accuracy, 
reliability and security of the IT system. Finally, with a view to effectively prevent and detect 
conflicts of interests, fraud, corruption, and double funding, a dedicated milestone is expected 
to ensure that the conditions for the systematic and extended use of the functionalities of the 
Arachne risk-scoring tool in the implementation of the Polish plan will be set out. Taking into 
account that this milestone should ensure the protection of the financial interests of the Union 
and  the  establishment  of  an  adequate  control  system,  it  should  be  fulfilled  before  the 
submission  of the first  payment  request  and no payment  under the  Facility  should  be made 
before its fulfilment. 

The corrective element of the control systems and corrective arrangements put in place 
by  Poland  in  cases  of  corruption,  fraud  and  conflicts  of  interests,  including  the 
arrangements  aimed  to  avoid  double  funding,  may  include  a  judicial  procedure,  in 
addition to the administrative processes described in the plan. As such, the effectiveness of the 
judicial system is relevant to assess the adequacy of the arrangements proposed by Poland. In 
this  regard,  two  dedicated  reforms  are  expected  to  ensure,  on  the  one  hand,  that  the 
independence  and  impartiality  of  courts  are  strenghtened  and,  on  the  other  hand,  that  the 
situation of judges affected by decisions of the Disciplinary Chamber of the Supreme Court in 
disciplinary cases and judicial immunity cases is remedied. Concretely, the plan provides that 
all disciplinary cases against judges will be adjudicated by an independent and impartial court, 

66 

 
 
thus not the Disciplinary Chamber. It also provides that judges will not be disciplinary liable 
for submitting a request  for preliminary  ruling to the Court of Justice, or for the content of 
judicial  decisions,  or  for  verifying  whether  another  court  is  impartial  and  independent. 
Procedural  guarantees  and  powers  of  judges  will  be  strengthened  in  the  disciplinary 
proceedings concerning them. All judges affected by the past Disciplinary Chamber rulings 
will have the right to have these rulings reviewed by an independent and impartial court. The 
first hearing in the context of such review proceedings will take place withing three months 
from the receipt of the motion of the judge asking for a review, and the review cases will be 
adjudicated within 12 months. Taking into account that the related milestones planned in the 
second quarter of 2022 should ensure the protection of the financial interests of the Union and 
the establishment of an adequate control system, they should be fulfilled before the submission 
of the first payment request and no payment under the Facility should be made before their 
fulfilment.   

Adequacy of arrangements to avoid double EU funding  

The  Polish  authorities  recognise  that  there  are  risks  of  funding  from  several  EU  and 
national sources and designed mechanisms to address such risks. The Polish authorities 
will use the following mechanisms and tools to address risks of double funding: (i) demarcation 
lines at the stage of programming of individual programmes co-financed by EU, (ii) ex-ante 
analysis  at  the  stage  of  project  selection,  (iii) management  verification  and  (iv)  automatic 
control algorithms in the IT system. The use of Arachne is also planned for the verification of 
double  funding.  The  fact  that  the  implementing  bodies  for  RRP  are  also  involved  in  the 
implementation  of  ESI  Funds  gives  additional  assurance  for  cross-checking  the  data  with 
traditional ESI Funds management systems and avoiding double funding.  

Legal empowerment and administrative capacity of control function  

Poland indicates the approval of the plan by the Government of the Republic of Poland 
of 30 April 2021 constitute the legal mandate for both the Ministry of Funds and Regional 
policy,  as  well  as  for  the  audit  body.  As  regards  the  administrative  capacity  of  the 
coordinating body, it will consist of 70 staff members, which according to Poland is sufficient 
to perform the task allocated to it. As regards the audit body, the Plan specifies that 50 staff 
member involved in the audits. It further elaborates on the experience of the involved staff and 
organisational arrangements to be put in place in order to ensure staff availability. The  plan 
also foresees the possibility to outsource certain audit tasks for the RRF to the external auditors 
if needed.  

***   
The arrangements proposed by Poland in the recovery and resilience plan to prevent, detect 
and correct corruption, fraud and conflicts of interest when using the funds provided under the 
Facility, including the arrangements aimed to avoid double funding from the Facility and other 
Union programmes,  are  assessed  to  be  adequate,  provided  that  the  pending  issues  are 
addressed in due time, through the dedicated milestones, in accordance with Article 20(5)(e) 
of the RRF Regulation. This would warrant a rating of A under the assessment criterion 2.10 
of Annex V to the RRF Regulation. 

4.11. 

Coherence 

The plan provides a comprehensive response to the consequences of the COVID-19 crisis, 
as well as a response to the main challenges identified based on the country´s performance 

67 

 
 
 
and  the  systemic  weaknesses  of  the  Polish  economy.  The  plan  builds  on  the  strategic 
objectives to restore the growth potential of the Polish economy, strengthen its competitiveness 
and to increase the standard of living in a long-term perspective, in particular by accelerating 
the  green  and  digital  transitions.  On  this  basis,  Poland  developed  three  specific  objectives 
focused on increased productivity of the Polish economy based on the digital transformation, 
the  energy  transformation  and  clean  smart  mobility,  and  increased  social  capital  based  on 
health and quality of education and skills. Reforms and investments were compiled in packages 
in the priority areas and stru ctured around the six pillars set out in the RRF Regulation. On 
this basis, Poland structured the measures in six components.  

Mutually reinforcing measures 

The plan  presents a coherent and comprehensive package of reforms and investments 
that are generally for the most part reinforcing each other. A strong reform drive is visible 
in various components. The plan demonstrates synergies among components, such as measures 
aimed at the development of digital skills and infrastructure and supporting the workforce by 
improving the matching of skills and qualifications with labour market needs as a result of the 
introduction of new technologies in the economy and the green and digital transformation, and 
reforms and investments to improve labour market participation). Synergies are generally well 
presented and clearly structured. There is a good interplay between reforms and investments in 
each  component.  Some  reforms,  such  as  the  improvement  of  the  law-making  process,  are 
expected to have a wider impact on the quality of legislation, including reforms proposed in 
the RRP. Reforms are to a large extent concentrated in the early years of the plan in order to 
create  favourable  conditions  for  effective  and  targeted  investments  (e.g.  introduction  of  a 
regulatory framework for the developments of hydrogen technologies, rules enabling trade in 
secondary  raw  materials)  and  to  address  implementation  barriers  (e.g.  for  onshore  wind 
investments and solutions in the economy using connectivity in 5G networks). Synergies are 
ensured in thematic components as well as horizontally across components, e.g. on the digital 
transition of the public administration or education or green and digital transition in innovation. 
No cases have been observed of areas where the measures proposed within any component (be 
it reforms or investments) contradict or undermine each other´s effectiveness. 

Complementarity of measures  

The plan presents  a consistent  vision throughout the thematic  areas,  components as  well as 
regarding the proposed reforms and investments. 

Business environment 

The plan sets out several relevant measures to enhance the business environment and the 
business climate in a subpart of Component A and in Component F. This includes several 
measures to reduce the administrative burden on business, such as the so-called ‘Legal Shield’ 
regulatory  package,  which  will  streamline  administrative  procedures  and  improve  the 
transparency of administration. The land reform included in the subcomponent is expected to 
increase  levels  of  investment  in  construction  by  improving  the  regulatory  framework  and 
giving  more  clarity  to  potential  investors  about  land-planning  development  in  all 
municipalities. The reform to expand the number of ‘special economic zones’ in Poland is set 
to  improve  confidence  and  attract  investment,  thereby  enhancing  investment  levels.  The 
proposed reform to limit the use of fast-track legislative procedures and enhance the use of 
public  consultations  in  the  policymaking  process,  as  well  as  the  reform  to  strenghten  the 
independence of the judiciary are also expected to improve the investment climate. Finally, a 
reform  to  protect  agri-food  SMEs  and  small  producers  against  unfair  trade  practices  will 
improve business sentiment in the agri-food sector.  

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Innovation 

In  order  to  enhance  Poland’s  capacity  for  innovation  the  plan  includes  a  dedicated 
package  of  investments  and  reforms  in  a  subpart  of  component  A.  The  measures  are 
coherent with national policies and strategies such as the roadmap for the transition to a circular 
economy and the “Constitution for Science”. The focus is on creating a legal framework to 
accelerate the processes of robotisation, digitalisation and innovation in the Polish industry and 
to  accelerate the uptake  of such technologies through targeted investments.  The component 
also envisages changes in the internal governance of research institutes to improve the effective 
cooperation  between  science  and  industry,  and  it  will  support  the  development  and 
dissemination  of  innovative  technologies.  The  dissemination  of  innovative  solutions  is  also 
expected to be improved through the creation of sectoral skills centres (in another sub-part of 
component A), demonstrating synergies and complementarity of various measures. By means 
of a set of reforms and investments, the plan is expected to incentivise the development and 
commercialisation  of  innovative  solutions,  in  particular  in  the  area  of  unmanned  mobility, 
environmental  projects  related  to  the  circular  economy,  hydrogen,  agri-food  and  health. 
Therefore, the projects  supported under this subcomponent contribute also to  the green  and 
digital  transition. Different  EU programmes, including inter  alia the EU  Space Programme, 
provide complementary support in this area. 

Education 

Measures  on  childcare,  digitalisation  of  schools,  upskilling  and  reskilling  complement 
each other and address different types of shortcomings at various levels. Component A 
addresses  the  participation  in  and  quality  of  childcare  through  targeted  investments 
underpinned by an envisaged reform of quality standards. It also includes a significant reform 
to put in place and finance a network of sectoral skills centres. Both aspects are expected to 
contribute to increasing labour market participation and improving education and skills. At the 
same time, Component C addresses the lack of a strategic approach to digital competences or 
digitalisation  in  education,  shortages  in  ICT  equipment  with  investments  in  computers  and 
other IT tools for both teachers and students, which promote digital education, together with 
investment in connectivity for schools and digital skills for various groups. This is in line with 
European  initiatives  such  as  EU  Digital  Strategy,  the  EU  Skills  Agenda,  the  European 
Education Area and the EU Digital Education Action Plan. 

Labour Market 

Challenges  related  to  the  labour  market  are  addressed  in  Component  A  and  focus  on 
increasing  labour  market  participation  and  lowering  segmentation.  Reforms  of  public 
employment services and of the early childhood education and care framework, supported by 
relevant investment in childcare facilities aim at increasing labour force participation, including 
of women and inactive persons. The envisaged measures to review the long-term care policy 
framework may further contribute to this objective. Also, the planned tax incentive for those 
who reach the statutory retirement age but continue working can have a similar effect for that 
group  of  workers.  At  the  same  time,  covering  all  civil-law  contracts  by  social  security 
contributions has potential to address the issue of the labour market segmentation and provide 
more social security to certain workers.  

Energy  

The energy transition is pursued through Component B, which focuses on improving air 
quality and energy efficiency, increasing the use of renewable energy sources and low-
emissions heating, as well as adaptation to climate change and reducing environmental 

69 

 
 
degradation. The proposed measures are coherent with the NECP and Polish Energy Policy 
until 2040 (PEP2040). To address the first challenge, the proposed reforms and investments 
include  the  replacement  of  the  most  polluting  boilers  combined  with  a  building  renovation 
programme to improve the energy performance of buildings. For the second specific objective, 
the  plan  proposes  to  establish  a  regulatory  framework  for  the  development  of  offshore  and 
onshore wind farms, hydrogen and alternative fuels, and energy storage facilities and will be 
accompanied  by  the  relevant  investments.  The  adaptation  to  climate  change  and  reducing 
environmental  degradation  will  be  addressed  through  legislative  changes  and  investments 
aimed at improving sustainable water and wastewater management in rural areas as well as 
neutralising risks and restoring large-scale brownfield sites and in the Baltic Sea. Investments 
supported  under  this  component  are  coupled  with  meaningful  reforms,  which  combined 
address important challenges that Poland faces for the energy transition. 

Digital 

While digital transformation is the core objective of Component C, there are measures 
that  contribute  to  the  same  goal  also  in  the  remaining  four  components,  building  on 
synergies  throughout  the  plan.  Measures  in  Component  C  focus  explicitly  on  the 
digitalisation of the economy, with a series of interventions. First, through developing high-
speed  internet  connection  to  close  the  gap  between  urban  and  rural  areas.  Second,  through 
removing  bottlenecks  in  the  digitalisation  of  the  public  administration,  the  economy  and 
society, which in turn incentivises companies to be more digitalised, and through facilitating 
remote  work.  Third,  through  fostering  digital  competences  in  education,  which  improves 
labour market readiness, as well as in other sectors to improve the overall level of basic digital 
knowledge in the country. This is accompanied by investments in ICT tools for educational 
institutions  and  by  overarching  standards  to  equip  schools  with  digital  infrastructure  on  an 
equal basis. Fourth, increasing cybersecurity of the public information systems and optimising 
data processing infrastructure to allow for better synergies among state services responsible for 
security. In addition to these measures, which are considered 100% digital, actions in the areas 
of entrepreneurship, health, agriculture, energy and transport also contribute to Poland’s digital 
transformation and to shape Europe’s digital future. Different EU programmes, including inter 
alia  a  new  satellite-based  secure  connectivity  system  initiated  at  the  EU  level,  provide  a 
complementary support in this area. 

Health 

The  plan’s  Component  D  addresses  the  challenges  in  the  Polish  healthcare  system  by 
presenting a comprehensive reform and investment agenda. This agenda covers multiple 
actions and measures addressing structural challenges for the health system, financed from both 
national and EU sources. It presents a coherent approach to improving accessibility and quality 
of healthcare with rationalisation of the pyramid of care and some far-reaching changes to the 
provision  of  the  primary  care  and  ambulatory  care  addressed  by  national  means.  The  plan 
provides for the restructuring of the hospital sector in the context of a comprehensive hospital 
care reform. The key goal is to help ensure a lasting improvement in resilience, effectiveness, 
quality and accessibility of hospital care. The measures for the hospital sector at district level 
under Component D also include reforms and investments for supporting the development of 
long-term care, in line with the planned general review of the long-term care policy framework 
covered under Component A. Other measures envisaged cover support for staffing in the health 
sector,  as  well  as  development  of  digital  solutions  for  healthcare.  Additionally,  measures 
planned  for  the  support  to  the  pharmaceutical  sector  and  for  specialised  medical  science 
research and analysis aim to strengthen the resilience of the health system, especially in view 
of  the  lessons  to  be  learnt  from  the  pandemic  and  the  importance  of  access  to  supply  of 

70 

 
 
medicines. These complementing measures have the potential to create synergies to support 
the successful roll-out of the broader agenda for a health system reform.  

Transport 

The  plan  contains  several  reforms  and  investments  to  promote  sustainable  transport 
across modes and in urban, interurban and rural areas. It contains an important reform and 
investment  to  improve  road  safety  with  a  comprehensive  approach  to  rules,  enforcement, 
equipment and infrastructure. It includes measures to promote clean public vehicles, demand 
for zero-emission vehicles, urban mobility in a comprehensive way and in complementarity 
with Cohesion policy. It also contains significant investments in railways infrastructure, in the 
framework of TEN-Ts and including electrification and zero-emission rolling stocks. Finally, 
it addresses the issue of digitalisation of transport via investments in efficiency and safety of 
road and railway transport (e.g. ITS, ERTMS) and e-ticketing. 

Coherence with EU cohesion policy funding 

As  Poland  is  the  largest  beneficiary  of  Cohesion  Policy  funding  in  the  EU,  significant 
complementarities are visible and generally spelled out in the text, but the level of details 
varies  across  the  components  and  effective  monitoring  and  implementation  will  be 
crucial.  Both  levels  of  programming  documents,  namely  the  Partnership  Agreement  and 
Programmes  (2021  –  2027)  are  currently  subject  to  negotiations.  An  overall  description  of 
complementarities accompanied by RRF/ESIF synergy tables at the horizontal level offers a 
first  overview  of  intended  complementarities  per  areas  covered  by  both  funds.  This  is 
complemented by a mechanism to avoid double funding, which appears to be reasonable, but 
needs  to  be  effectively  implemented  in  close  cooperation  between  responsible  actors  under 
both funds. All potential ESIF investments indicated in the plan are still subject to negotiations 
with the Commission and cannot be prejudged on the basis of the text in the plan. 

The  plan  does  not  present  inconsistencies  or  contradictions  between  the  different 
components.  In  order  to  promote  wider  coherence  across  instruments,  notably  with  the 
European cohesion policy funds, a balanced territorial allocation of resources is encouraged. 

***   
Taking into consideration the qualitative assessment of all components of Poland ´s recovery 
and  resilience  plan,  their  individual  weight  (size,  relevance,  financial  allocation)  and  their 
interactions,  the  plan  contains  measures  for  the  implementation  of  reforms  and  public 
investments which, to a high extent, represent coherent actions. This would warrant a rating 
of A under the assessment criterion 2.11 of Annex V to the RRF Regulation. 

71 

 
 
 
 
ANNEX – CLIMATE AND DIGITAL TAGGING 

Note: While the total cost of Poland’s recovery and resilience plan exceeds the total allocation of non-
repayable  financial  support  to  Poland,  Poland  will  ensure  that  all  spending  related  to  the  measures 
mentioned in this table as contributing to climate objectives are fully financed  by the funds from the 
Recovery and Resilience Facility.  

Measure/Sub-Measure Name = if italic, it refers to tagging of a sub-measure 
Int. Field = intervention field 
Coeff. = Coefficient for the calculation of support to climate change objectives and to digital 
transition, on the basis of Annex VI and Annex VII to the RRF Regulation 

Measure/Sub-Measure Name 

Amount 

Int. 
field 

Coeff.
% 

Int. 
field 

Coeff.
% 

Climate 

Digital 

Measure
/ Sub-
Measure 
ID 

A1.2.1 

for 

enterprises 

Investments 
in 
products, services and competences of 
employees  and  staff  related  to  the 
diversification of activities 

A1.4.1.2  Agriculture 4.0 

A2.1.1 

A2.2.1 

A2.3.1 

A2.6.1 

A4.4.1 

B1.1.1 

B1.1.2.2 

B1.1.3 

B1.1.4 

B1.2.1 

system 

industry 

technologies 

Investments  supporting  robotisation 
and digitalisation in enterprises 
Investments  in  the  deployment  of 
environmental 
and 
innovation,  including  those  related  to 
circular economy 
Development 
equipment  of 
and 
competence centres (specialist training 
centres, 
support 
implementation 
centres, observatories) and unmanned 
vehicle 
management 
infrastructure,  as  an  ecosystem  of 
innovation 
Investment  -  Development  of  the 
national 
of  monitoring 
services,  products,  analytical  tools, 
services 
accompanying 
and 
infrastructure using satellite data 
Investments 
to  equipping 
related 
workers/companies to work remotely 
Investments  in  heat  (cooling)  sources 
in district heating systems 
Replacement  of  heat  sources  and 
improvement  of  energy  efficiency  in 
residential buildings – non-gas boilers 
Thermal modernization of schools 
Strengthening the energy efficiency of 
local social activity facilities 
Energy  efficiency  and  RES 
in 
companies  –  investments  with  the 
highest  greenhouse  gas 
reduction 
potential 

72 

500 

168 
450 

162 

016 

40% 

 055 
010bis  

100% 
100% 

023 

40% 

164 

084bis 

40%  084bis 

100% 

150 

44 

 055  

100% 

 010  

100% 

300 

034 

40% 

1,920.6 

025bis 

100% 

290 
67 

025 
025  

40% 
40% 

300 

024bis  

40% 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
B2.1.1 

B2.2.1 

B2.2.2.1 

B2.2.3 

of 
smart 

Investments in hydrogen technologies, 
hydrogen  manufacturing,  storage  and 
transport 
Development 
networks, 
infrastructure 
RES  installations  operated  by  energy 
communities – investment part 
Construction  of  offshore 
infrastructure 

transmission 
electricity 

terminal 

to 

or 

B3.5.1 

B3.4.1.4 

B3.4.1.3 

B3.4.1.1 

B3.4.1.2 

increase 
energy 

B2.3.1  Construction of offshore wind farms 
B2.4.1 

Energy storage 
energy 
Renovation 
efficiency 
efficiency 
measures  of  public 
infrastructure, 
demonstration  projects  and  support 
measures 
Water  management  and  protection  of 
water resources (including river basin 
management,  specific  climate  change 
adaptation  actions,  reuse,  leakage 
reduction) 
Actions  aimed  at  reducing  noise  and 
improving air quality 
Nature  and  biodiversity  protection, 
natural heritage and resources, green 
and blue infrastructure 
Investment in energy-efficient housing 
for 
average-income 
low- 
households 
Providing  access  to  very  fast  internet 
in the areas of white spots 
Strengthening 
of 
the 
commercial  investments  in  modern 
electronic communication networks 
solutions 
Public 
improving 
of 
administrations and economic sectors, 
and  breakthrough  technologies  in  the 
public sector, the economy and society 
Level  playing  field  for  schools  with 
– 
mobile  multimedia 
investments related to the fulfilment of 
minimum equipment standards 
E-competences 
LAN connection, STEM laboratories – 
laboratories, 
AI 
part, 
digital 
examination commissions  
C3.1.1.1  Cyber security – CyberPL 

e-services, 
the 

functioning 

potential 

C2.2.1.1 

devices 

C2.1.2 

C2.1.3 

C1.1.1 

C1.2.1 

C2.1.1 

and 

IT 

800 

032 

100% 

300 

033 

100% 

 033  

40% 

53.8 

027 

100% 

437 

031 

100% 

3,250 
200 
1,600 

031 
033 
026 

100% 
100% 
40% 

 033 

40% 

750 

040 

40% 

280 

170 

048 

050 

40% 

40% 

755 

025ter 

40% 

1,200 

1,400 

420 

550 

184 
621 

193 

 051  

100% 

054bis 

100% 

011  

100% 

012  

100% 

108  
012  

100% 
100% 

021qui
nquies  
40%  011bis  

100% 

100% 

C3.1.1.2 

Infrastructure for data processing and 
delivery of digital services 

185 

011bis  

73 

 
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
011  

100% 

021qu
ater  
095  

100% 

100% 

54 

11 

1,000 

1,114 
893.5 

200 
1,243 

237 

251 

022 
074 

074 
065  

100% 
100% 

100% 
100% 

064 

100% 

066 

40% 

660 

066bis 

100% 

965 
175 
341 
500 

072bis 
079 
070 
072bis 

100% 
40% 
40% 
100% 

070 

100% 

C3.1.1.3 

C3.1.1.4  

D1.1.2 

E1.1.1 

E1.1.2.2 

E1.2.1 

E2.1.1.1 

E2.1.1.2 

E2.1.1.3 

E2.1.1.4 

Optimization  of  the  infrastructure  of 
law enforcement services  
IPCEI on Next Generation Cloud 

public 

transport 

Accelerating the digital transformation 
of  healthcare  by  further  developing 
digital healthcare services 
Support for a low-carbon economy 
Zero-emission 
(electric buses) 
Zero-emission public transport (trams) 
Modernization  and  revitalization  of 
railroads 
Improving  safety  of  railway-road 
crossings 
Increasing the capacity of the railway 
network 
Preparatory  works 
railway line 

for  high-speed 

E2.1.2  Railways passenger rolling stock 
E2.1.3 
E2.2.2 

Investments in intermodal transport 
Transport digitization 
Regional  railways  passenger  rolling 
stock 

E2.3.1 

74