COMMISSION STAFF WORKING DOCUMENT 2023 Country Report - Poland Accompanying the document Recommendation for a COUNCIL RECOMMENDATION on the 2023 National Reform Programme of Poland and delivering a Council opinion on the 2023 Convergence Programme of Poland
Date: 2023-05-24
Institutions: European Commission, Secretariat-General
Subjects: Poland, economic policy, economic recovery, economic reform, energy policy, fiscal policy, independence of the judiciary, social-security benefit, stability pact, stability programme

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.5.2023  SWD(2023) 621 final  COMMISSION STAFF WORKING DOCUMENT 2023 Country Report - Poland Accompanying the document Recommendation for a COUNCIL RECOMMENDATION on the 2023 National Reform Programme of Poland and delivering a Council opinion on the 2023 Convergence Programme of Poland {COM(2023) 621 final}  
 
 
 
 
 
 
 
 
 
 
 
ECONOMIC AND EMPLOYMENT SNAPSHOT 

Russia’s war of aggression against 
Ukraine has impacted the economy 

The  Polish  economy  recovered  quickly 
from 
the  COVID-19  pandemic,  but 
economic  growth  is  expected  to  stall  in 
2023.Poland  was  one  of  the  fastest-growing 
economies in the EU during the post-pandemic 
period,  benefiting  from  strong  policy  support, 
low  unemployment,  and  continued  inflows  of 
foreign  direct  investment.  However,  Russia’s 
invasion  of  Ukraine  has  put  significant 
pressure on the economy. Elevated commodity 
prices  are  weighing  on  both  real  disposable 
incomes  (i.e.  incomes  adjusted  for  inflation) 
and  consumption  growth,  especially  given  the 
high  share  of  energy  in  the  consumer  basket. 
High  uncertainty,  a  deteriorating  business 
sentiment, and the increased cost of borrowing 
are  impacting  economic  activity,  particularly 
investment.  As  a  result,  the  Commission’s 
forecast  projects  economic  growth  to  slow 
considerably in 2023 and stand below the EU 
average. 

increased  operating  costs 

Inflation  has  soared  amid  rising  global 
energy  prices  and  domestic  demand 
pressures. Poland’s inflation rate is expected 
to remain one of the highest in the EU in 2023 
and  2024.  The  energy-price  shock  in  2022 
came on top of global supply-chain disruptions 
and strong growth in global commodity prices. 
for 
This  has 
businesses,  which  –  given  exceptionally  high 
demand – encouraged firms to raise the prices 
they  charge  for  consumer  goods.  As  the 
economy  decelerates,  inflation  is  set  to  start 
gradually decreasing amid an easing of supply 
bottlenecks,  weakening domestic  demand  and 
a 
prices. 
Nevertheless,  risks  of  persistently  elevated 
inflation exist given high inflation expectations 

commodity 

global 

fall 

in 

and  nominal  wage  growth,  as  well  as  an 
expansionary fiscal stance.  

participation 

Unemployment  remains  at  historically 
low  levels  and  one  the  lowest  in  the  EU, 
giving  rise  to  acute  labour  shortages.  A 
record  low  unemployment  rate  has  led  to  the 
re-emergence  of  shortages  of  workers.  Low 
labour  market 
some 
of 
in  the 
population  groups,  and  a  decline 
working-age  population  keep  weighing  on 
labour  supply.  This  is  in  turn  holding  back 
Poland  from  fully  implementing  the  European 
Pillar  of  Social  Rights  and  achieving 
its 
national  employment  target  for  2030  (see 
Annex 14). At the same time, business surveys 
suggest  that  firms  are  having  problems 
finding people with the right skills, pointing to 
significant  skills  mismatches.  The 
labour 
market  adjustment  to the  expected  slowdown 
in economic growth is expected to come from 
lower  wage  growth  rather  than  from  an 
increase 
in  unemployment,  as  firms  are 
reluctant  to  lay-off  workers  given  the  strong 
difficulties they face in hiring. The 2022 ‘Polish 
Deal’ tax reform is estimated to have lowered 
the tax burden on labour benefitting more the 
lower  income  employees  as  well  as  older 
workers delaying retirement, while it increased 
the  tax  wedge (1)  for  higher-income  self-
employed.  The  reform  should  also  boost  the 
labour supply over the medium term (2). 

The  successful  integration  of  displaced 
persons  from  Ukraine  has  helped  the 
labour market, but challenges remain. The 

(1)  The tax wedge is the ratio of personal income tax and 
employer and employee social-security contributions 
(SSCs) less family benefits divided by total labour costs. 

(2)  European Commission, Joint Research Centre, 

calculation based on the EUROMOD model version 
I5.0+. Labour-supply reactions are estimated through 
EUROLAB (for details, see Narazani, E., Colombino, U. 
and Palma B., (2021) ‘EUROLAB: A Multidimensional 
Labour Supply-Demand Model for EU Countries’, 
European Commission, JRC127383). 

2 

 
 
                                                 
to 

unprecedented support to the roughly 1 million 
displaced persons from Ukraine (3) who settled 
in  Poland  contributed 
their  speedy 
integration  into  the  jobs  market.  According  to 
the  OECD (4),  these  are  estimated  to  have 
increased labour supply in Poland by 2.1% by 
the  end  of  2022,  easing  the  shortage  of 
workers,  especially  in  services.  Although  60% 
of  those  settled  in  Poland  by  April  2022  had 
found work, many face underemployment and 
skills  mismatches (5).  Moreover,  the  sudden 
increase  in  population  has  added  to  housing 
needs  in  regions  where  these  were  already 
considerable before the war, and it puts strain 
on  public  services,  including  the  education 
system  (see  Annex  17).  In  2022/23,  over 
192 000  out  of  an  estimated  500 000 
displaced children from Ukraine in Poland were 
enrolled  in  schools  and  pre-schools,  which 
increased  the  total  numbers  of  children  in 
school  and  pre-school  by  3%,  and  by  even 
more in large urban areas (6).  

Poland’s  competitiveness  has  remained 
resilient  to  the  energy  shock  and  the 
rising labour costs. The rise in energy prices 
globally  led  to  a  strong  terms-of-trade  shock 
over  2022,  which  contributed  to  a  significant 
deterioration 
in  Poland’s  current  account 
balance.  Still,  cost-competitiveness  remained 
stable  on  the  back  of  a  depreciation  of  the 
zloty and gains in labour productivity. This was 
reflected in strong exports, as evidenced in an 
increase  in  global  market  share  by  Polish 
exporters, as well as strong inflows of foreign 
labour  costs 
direct 
remain among the lowest in the EU. 

investment.  Poland’s 

The  banking  sector  is  showing  resilience. 
The  Polish  banking  sector  recovered  rapidly 
from  the  pandemic,  driven  by  strong  GDP 
growth  in  2021  and  early  2022.  Solvency 
remains  adequate,  while  funding  and  liquidity 

(3)  The distinctive number of persons holding a refugee 
status was 997 thousand as of 27 March 2023. 

(4)  OECD (2022). ‘The potential contribution of Ukrainian 

refugees to the labour force in European host countries’, 
OECD Publishing, Paris. 

(5)  OECD (2023), OECD Economic Surveys: Poland 2023, 

OECD Publishing, Paris.  

(6)  Union of Polish Cities (2022), Urban hospitality: 

unprecedented growth, challenges and opportunities.  

3 

of 

courts 

Banking 

profitability 

are  at  solid  levels  and  well  above  regulatory 
minima. 
improved 
significantly  following  the  increase  in  interest 
rates,  but  could  suffer  in  the  future  from  the 
costs associated with the potential annulment 
in 
foreign-currency-
legacy 
denominated mortgages in addition to costs of 
the mortgage  repayment holidays  adopted  by 
the  government  in  July  2022.  This  could  also 
have implications for credit supply (see Annex 
18).  Private  sector 
in  particular 
housing  loans,  cooled  down  rapidly  in  2022 
amid  a  rise  in  borrowing  costs  and  stricter 
bank lending standards.  

lending, 

Public finances are under strain. According 
to  the  Commission’s  forecast,  the  budget 
deficit  is  expected  to  increase  from  3.7%  of 
GDP  in  2022  to  5.0%  of  GDP  in  2023.  Total 
spending  on  defence  is  also  expected  to 
increase,  while  continued  energy  support 
measures  are  also  weighing  on  the  budget. 
Total expenditures on aid to displaced persons 
from Ukraine, which in 2022 were the highest 
in  the  EU,  are  set  to  decrease.  While  most  of 
the  energy  support measures  are  assumed to 
be withdrawn, the personal income tax reform 
(the  ‘Polish  Deal’)  introduced  in  2022  has 
permanently  lowered  government  revenues 
(see Annex 19). In 2024, the deficit is forecast 
to decrease to 3.7% of GDP. The ratio of public 
debt to GDP is set to remain below 60%, while 
increasing moderately until 2024.  

Challenges  remain  in  the  sustainability, 
efficiency,  and  transparency  of  public 
finances.  Retaining  the  very  low  retirement 
age 
(for  women  and  some  professional 
groups) amid a rapidly ageing population risks 
either  a  future  increase  in  old-age  poverty  or 
substantial increases in future public spending 
on  pensions.  This  could  put  pressure  on  the 
sustainability of government finances over the 
recent  years, 
medium-to-long 
improved  tax  compliance  has  contributed  to 
higher  government 
there 
remains  considerable  scope  to  increase  the 
efficiency  of  public  spending  on  social 
benefits,  public 
investment,  and  public 
procurement.  The  role  of  both  independent 
the  medium-term 
fiscal  oversight  and 
budgetary  framework  remains  limited,  and 
recent  budgetary  practices  relying  on  off-

revenues,  but 

term. 

In 

 
                                                 
budget funds reduce transparency and the role 
of the parliament. 

Tackling structural challenges will 
support sustained growth  

Productivity  growth  has  been  strong,  but 
Poland’s  growth  potential  is  being  held 
back  by  low  levels  of  investment  and 
innovation  as  well  as  challenges  in  the 
education  system.  Labour  productivity  in 
Poland  has  been  expanding  at  one  of  the 
fastest  rates  in  the  EU,  benefiting  from 
Poland’s  integration  in  global  value  chains, 
technology  transfer,  and  a  relatively  skilled 
population  (see  Annex  12).  The  comparatively 
high  birth  and  death  rate  of  Polish  firms 
suggests  there  are  low  obstacles  to  resource 
allocation (7).  Nevertheless, labour productivity 
levels remain well below the EU average, with 
great variations between Poland’s regions (see 
Annex  17).  The  green  and  digital  transitions 
are  being  held  back  by  a  lack  of  digital  skills 
among  workers  in  particular  specialists  in 
information  and  communications  technology 
(see  Annexes  5  and  10),  as  well  as  by  low 
rates  of  adult  participation  in  learning  (see 
Annex  14).  Low  shares  of  graduates  in  STEM 
subjects could limit the country’s research and 
innovation  potential  (see  Annex  11).  The 
adoption  of  technology  in  businesses  remains 
poor compared to the EU average, while SMEs 
innovation.  The 
levels  of 
show  meagre 
education  system  continues  to  be  challenged 
by teacher shortages in some subjects and by 
student  overcrowding  in  big  cities.  This  leads 
to  worse  educational  outcomes  and  deepens 
inequalities.  

Weaknesses  in  the  business  environment 
investment. 
are  holding  back  private 
Private investment as a share of GDP remains 
below  the  EU  average  and  the  levels  in  peer 
countries,  stifled  by  the  burdensome  and 
unstable 
environment. 
Administrative effectiveness and digital public 
administration also rank below the EU average 

regulatory 

(7)  Business ‘churning’ is above the EU average (18.9% vs 

16.1% in 2020) as is the share of high-growth 
enterprises (9.8% vs 9.4%). 

4 

in 

indicators  of 
amid:  (i)  a  deterioration 
governance  quality;  (ii)  a  lack  of  effective 
public  consultation;  and  (iii)  weaknesses  in 
public  procurement  (see  Annexes  12  and  13). 
Concerns persist over the rule of law in Poland, 
including  the  independence  of  the  judicial 
system. The perceived level of effectiveness of 
investment protection by the law and courts is 
very low among companies compared with the 
EU average (see Annex 12).  

in 

in 

remain 

challenges 

Further 
the 
healthcare system and long-term care, as 
health  outcomes  have  deteriorated.  The 
pandemic has taken a heavy toll, visible in the 
abrupt  decline  in  life  expectancy  and  high 
mortality  relative  to  the  EU  average  (see 
Annex  16).  Weaknesses  persist 
the 
healthcare  system  amid  a  weak  primary  care 
system  and  high  levels  of  unmet  health  and 
long-term  care  needs.  This  is  underlined  by 
shortages  of  medical  staff,  as  the  share  of 
doctors  and  nurses  in  Poland  is  one  of  the 
lowest in the EU relative to population. Poland 
is  also  one  of  the  countries  with  the  lowest 
use  of  digital  health  services  in  the  EU.  The 
long-term  care  system  is  insufficient  to  meet 
the needs of the ageing population due to low 
availability  of  community-based  care  (see 
Annex 14).  

the  economy  on  a  more 
To  put 
sustainable growth path, accelerating the 
energy  and  green  transitions  will  be  key. 
The  Polish  energy  mix  is  dominated  by  fossil 
fuels and was, until early 2023, heavily reliant 
on Russian imports. To effectively decarbonise 
its  economy  and  improve  energy  security  and 
affordability  at  the  pace  required  by  the  EU 
climate  and  energy  targets,  Poland  should 
scale  up the deployment of renewable energy 
sources  (RES).  RES  currently  account  for  only 
around 11% of the country’s energy mix. 

United 

Nations 

(SDGs),  but 

Poland is progressing moderately well on 
Sustainable 
some 
its 
Development  Goals 
performance  remains  below  the  EU 
average  in  SDGs  focusing  on  climate 
action, 
innovation, 
sustainable  cities,  and  gender  equality. 
Although  the  country  is  improving  on  certain 
to  environmental 
related 
SDG 

indicators 

hunger, 

zero 

 
                                                 
Box 1: 

Box on the energy policy response in Poland 

Poland has adopted measures to cushion the impact of energy price inflation. For 2023, 
the  gross  budgetary  costs  for  energy  support  measures  are  projected  to  amount  to 
1.7%  of  GDP.  Most  measures  do  not  preserve  the  price  signal  and  do  not  target  the 
most  vulnerable.  In  general,  the  energy  support  measures  are  valid  until  the  end  of 
2023. 

In 2023, the government replaced the first set of measures, which consisted mainly in 
reducing  VAT  rates  on  energy  and  granting  universal  cash  subsidies  to  households 
depending on their heating source, with adjusted price schemes for electricity and gas. 
For electricity, a two-tier price scheme is in place, freezing the price of electricity at the 
2022  level  for  households  within  limits  based  on  average  household  consumption. 
Above  these  limits,  the  price  is  capped  at  a  higher  level.  The  upper  price  cap  is  also 
applicable to SMEs. For  gas, prices are also frozen at 2022 levels  for households and 
vulnerable  entities,  without  consumption  limits.  The  gas-price  scheme  features  a 
targeted element: low-income households can claim a refund of the sum equivalent to 
VAT for every paid bill. The scheme for electricity prices includes a mechanism to fund 
the  upper  price  cap  based  on  taxing  windfall  profits.  The  government  has  introduced 
levies  limiting  the  revenues  of  energy  producers  and  vendors  in  line  with  the  Council 
Regulation 2022/1854. The levies are collected by a dedicated fund (Fundusz Wypłaty 
Różnicy Ceny) that compensates companies selling energy for the lost revenue due to 
selling below the market price. Thus, the scheme is assumed to be deficit neutral. 

Poland  applies  the  EU  solidarity  contribution  in  application  of  Council  Regulation  (EU) 
2022/1854 (8). 

On  the  security  of  energy  supply,  Poland  has decreased  its  dependency  on  fossil  fuel 
imports  from  Russia and  implemented  significant  infrastructure  projects  to  diversify 
supply. This includes the ‘Baltic Pipe’ and the two gas interconnectors with Slovakia and 
Lithuania.  Poland  has  also taken  several  measures  to  promote  energy  efficiency, 
including the ‘Clean Air Plus’ programme and energy savings.  

sustainability,  it  is  moving  away  from  targets 
on affordable clean energy (SDG 7), life below 
water  (SDG  14),  and zero hunger  (SDG  2).  On 
affordable clean energy, Poland has witnessed 
an  increase  in  per  capita  net  greenhouse-gas 
emissions  (SDG  13:  climate  action),  despite 
having  made  progress  in  increasing  the  final 
share  of  renewable  energy  in  gross  final 
energy  consumption.  Additionally,  Poland  is 
improving  on  decent  work  and  economic 
growth  (SDG  8)  and  industry,  innovation  and 
infrastructure  (SDG  9),  although  it  is  lagging 
on  quality  education  (SDG  4)  when  compared 
to  its  EU  counterparts.  Finally,  expenditure  on 
law courts (SDG 16) has increased, but further 
measures  to  strengthen  judicial  independence 
in the country are needed. 

In  addition  to  the  support  from  the  Recovery 
and Resilience Facility aimed at tackling many 
of the key  challenges it is facing (see Section 
2),  Poland  also  benefits  from  a  significant 
volume  of  EU  cohesion  funds  amounting  to 
EUR  88.3  billion  over  2021-2027  (see  Annex 
4). 

(8)  A mandatory, temporary contribution with a rate of at 

least 33% applied on the extraordinary and unexpected 
profits of businesses active in the extraction of crude 
petroleum, natural gas, coal, and refinery sectors. It is 
calculated on taxable profits from the fiscal year 
starting in 2022 and/or in 2023, which are above a 
20% increase of the average yearly taxable profits of 
the business in 2018-2021. 

5 

 
                                                 
 
THE RECOVERY AND RESILIENCE PLAN IS UNDERWAY 

digitalisation; 

Poland’s  recovery  and  resilience  plan 
(RRP),  approved  in  June  2022,  addresses 
many of the main challenges the country 
is facing. The RRP contains measures with an 
overall  value  of  EUR  35.4  billion  structured 
around  six  key  policy  areas:  the  green 
transition; 
health; 
competitiveness  and  innovation;  sustainable 
transport;  and  the  quality  of  institutions.  It  is 
estimated  that  the  economic  impact  of  the 
NextGenerationEU fund in Poland could lead to 
an increase in GDP of between 1.1% and 1.8% 
by  2026  and  translate  into  as  many  as 
105 000  additional 
jobs.  Additional  grant 
resources  available  to  Poland  through  the 
REPowerEU 
to 
EUR 2.76 billion.  

amount 

chapter 

Due to its late adoption in June 2022, the 
implementation  of  Poland’s  recovery  and 
resilience  plan  has  been  significantly 
delayed. Strengthening the independence and 
impartiality  of  courts  and  remedying  the 
situation  of  judges  affected  by  the  decisions 
of  the  Disciplinary  Chamber  of  the  Supreme 
Court 
judicial 
in  disciplinary  cases  and 
immunity  cases  are  a  precondition  for  the 
Commission  to  disburse  any  payment  to  the 
country  and  ensure  the  protection  of  the 
financial interests of the Union, allowing for a 
swift  and  steady  implementation  of  the  plan. 
implement  key 
Poland  has  started 
measures in the RRP, among which reforms in 
the areas of the fiscal framework, healthcare, 
digital transition, energy efficiency and labour 
market.  Although  Poland  has  not  officially 
submitted  addenda 
the  plan  nor  a 
to 
REPowerEU  chapter,  ongoing  discussions  with 
the Commission are taking place. Additionally, 
the  country  has  announced  its  intention  to 
take up additional loans.  

to 

The  following,  more  detailed 
review  of 
measures being implemented under the RRP in 
no way implies formal Commission approval or 
rejection of any payment requests.  

6 

These 

include 

reforms 

The  RRP  includes  reforms  to  modernise 
and  simplify  the  management  of  public 
finances. 
the 
introduction  of  a  new  model  of  budget 
management,  the 
introduction  of  a  new 
medium-term  budgetary  framework,  and  the 
extension  of  the  scope  of  the  stabilising 
expenditure  rule  to  more  general  government 
units. 

The  RRP  contains  several  labour  market 
measures  to  increase  the  employment 
rate, strengthen institutions, and address 
shortages  of  workers.  These  measures 
the  availability  of 
include: 
(i) 
(ii)  modernising  public 
childcare  facilities; 
(iii)  addressing 
employment  services;  and 
segmentation  in  the  jobs  market  by  reducing 
disparities 
in  social-security  contributions 
between various types of work contracts.  

increasing 

improve  coordination 

Reforms  to 
in 
several  areas  of  education  and  training 
are  set  to  give  workers  skills  that  are 
more  in  demand  among  employers  and 
increase  participation  in  adult  learning. 
in  the  area  of 
Additional  measures  are 
include  the 
innovation  and 
research  and 
creation  of  a  legal  framework  to  accelerate 
the  processes  of  robotisation,  digitalisation, 
and  innovation  in  the  industry.  The  RRP  also 
includes changes in the internal governance of 
research 
improving 
institutes  aimed  at 
cooperation  between  science  and  industry. 
Poland’s decision to buy digital  equipment for 
schools  and  adopt  a  strategic  framework  for 
digital-skills  development  will  improve  the 
digital skills of students and adults.  

Reforms  in  healthcare  are  expected  to 
make 
the  healthcare  system  more 
effective  and  efficient  and  to  improve 
accessibility  and  quality  of  health 
services, including by making greater use 
of  digital  solutions.  Further  measures  aim 
to  develop  the  skills  of  healthcare  staff  and 

 
 
strengthen  capacity  in  the  training  of  medical 
personnel. 

(i) 

The  green  transition  and  the  digital 
transformation of the economy are at the 
core  of  the  policy  response  in  Poland’s 
RRP.  About  43%  of  the  total  allocation  of 
Poland’s  RRP  is  dedicated to  green  objectives. 
The envisaged green reforms and investments 
renewable  energy 
aim  at: 
production, 
energy, 
onshore 
photovoltaics,  offshore  energy,  smart  grids, 
low-carbon 
renewable 
hydrogen); (ii) increasing energy efficiency; (iii) 
improving  air  quality;  and  (iv)  developing 
sustainable transport. Implementation of these 
measures  is  expected  to  help  Poland  achieve 
its 2030 climate and energy objectives.  

increasing 
(including 

hydrogen, 

and 

launch  of  significant 
foundation  for  the 
investments,  for  instance  in  energy-efficient 
housing,  the  roll-out  of  broadband  across 
Poland, or sustainable water management. The 
37 milestones under the first instalment of the 
plan  worth  EUR 4.22 billion  are  yet  to  be 
formally  assessed.  Key  measures  currently 
being implemented include: 

 

increasing access to high-quality childcare 
for  children  up  to  the  age  of  3  under  the 
‘Maluch+’ programme; 

  amendments to the Act on Public Finances 
extending  the  scope  of  the  stabilising-
expenditure 
the 
transparency  and  efficiency  of  public-
finance management; 

increase 

rule 

to 

About  21.3%  of  the  total  allocation  of 
Poland’s  RRP 
is  dedicated  to  digital 
objectives.  Measures  include:  (i)  improving 
connectivity; 
the 
administration 
infrastructure 
systems;  (iii)  introducing  electronic  structured 
invoices;  and  (iv)  significantly  improving  the 
country’s cybersecurity systems. 

(ii)  updating 
public 

laws  and 

of 

 

 

changes  to  the  law  on  higher  education 
and  science  strengthening  cooperation 
mechanisms 
and 
between 
industry; 

science 

changes 

reduce 
legislative 
administrative  burden  on  businesses  and 
the public; 

to 

The  RRP 
includes  reforms  to  reduce 
administrative  and  regulatory  burden, 
improve  the  quality  of  law-making,  and 
revise  spatial-planning  regulation.  These 
reforms  include  increasing  the  role  of  impact 
assessments  and  involving  stakeholders more 
in  the  policy  and 
law-making  processes. 
Additional measures are set to strengthen the 
independence  and  impartiality  of  courts  and 
ensure  an  effective  audit  and  monitoring  of 
these  additional 
the  RRP. 
measures  include  reforming  the  disciplinary 
regime  for  judges  and  ensuring  that  judges 
affected  by  decisions  of  the  Disciplinary 
Chamber of the Supreme Court have the right 
to have their case reviewed. 

In  particular, 

  a  new  law  to  support  the  automation, 
digitalisation  and  innovation  capacity  of 
enterprises  by  introducing  tax  relief  for 
using more robots; 

  an  amendment  to  the  act  on  investments 
in  onshore  wind  farms  and  regulatory 
changes  promoting  electricity  generation 
in  offshore  wind  farms  to  improve  the 
conditions 
the  development  of 
renewable energy sources. 

for 

Poland  has  started  to  implement  key 
aspects  of  the  RRP  (see  Annex  3).  The 
implementation of reforms underway includes 
reforms  in  the  areas  of  the  fiscal  framework, 
healthcare, 
transition,  energy 
efficiency,  childcare,  the  labour  market,  the 
business  environment  including  the  judiciary, 
lay  the 
science,  and 

industry.  They  also 

the  digital 

7 

 
Box 1: 

 Key deliverables under the RRP in 2023-2024 

 

Poland  committed  to  reform  the  disciplinary  regime  for  judges  and  to  set  up  a 
review  process  before  an  independent  court  for  judges  affected  by  decisions  of  the 
Disciplinary Chamber of the Supreme Court. 

  Entry into force of an amendment to the Investment Zone Act, to create a new 
model  for  granting  financial  support  to  businesses  undertaking  activities  in  special 
economic zones. 

  Adoption of a new law on spatial planning, which will introduce a requirement for 
all  municipalities  to  draw  up  and  adopt  a  long-term  strategy  for  land  development  in 
the municipality. 

 

Limiting  segmentation  in  the  jobs  market,  by  ensuring  that  all  civil-law 
employment contracts are subject to social-security contributions. 

  Strategic  review  of  long-term  care  to  identify  reform  priorities  to  improve 

efficiency and quality. 

  Reform  to  improve  the  conditions  for  developing  hydrogen  technologies  and 
other decarbonised gases. This is to be achieved by: (i) the entry into force of a law 
laying  down  rules  for  hydrogen;  and  (ii)  the  issuance  of  environmental  permits  for 
hydrogen refuelling stations. 

  Reform to improve the conditions for developing renewable energy sources. An 
amendment to the Renewable Energy Act is expected to introduce better conditions for 
the operation of energy clusters and the implementation of collective models of energy 
‘prosumers’ (9). 

  Publication  of  a  framework  to  co-finance  broadband  projects  ensuring 
universal access to high-speed internet. This is part of a broader reform aiming at 
guaranteeing  universal  access  to  high-speed  internet  and  digital  services  throughout 
Poland. 

  Signature  of  contracts  following  open  and  competitive  tenders  to  electrify 

478 km of railway lines and upgrade them to TEN-T standards (10). 

  Entry  into  force  of  a  legislative  act  safeguarding  the  system  for  monitoring 
and checking the supply of medicines. The objective of the reform is to introduce a 
regulatory  framework facilitating the  production of  medicines in Poland and attracting 
investment in new facilities to produce medicines in the country. 

(9)  Prosumers are businesses and households that both 

produce their own electricity (for example from rooftop 
solar panels) and consume electricity. Prosumers can 
sell excess electricity that they produce – but do not 
need – to the electric grid, and then consume electricity 
from the grid when their solar panels are not producing 
enough electricity for their immediate needs. 

(10)  Trans-European Transport Network (TEN-T) is a network 
of roads, railways, waterways, and airports that connect 
EU member states and other European countries. TEN-T 
was established by the European Commission to 
promote the development of a sustainable and efficient 
transport system that enhances economic growth, job 
creation, and the well-being of citizens. 

8 

 
 
 
                                                 
 
FURTHER PRIORITIES AHEAD 

in 

in 

the  education 

Beyond those  tackled  by  the  RRP,  Poland 
faces  additional  challenges  not  fully 
covered  in  the  plan.  The  rapidly  ageing 
population is putting the pension system under 
pressure.  The  efficiency  of  public  spending  on 
investment  remains  a 
social  policies  and 
challenge 
the 
amid  weaknesses 
transparency  of  public  finance.  Further  steps 
are  needed  to  address  skills  mismatches  and 
system. 
shortcomings 
Additional  measures  are  also  required  to 
reduce  reliance  on  fossil  fuels  and  accelerate 
the  green  transition.  Moreover,  enhancing  the 
investment  climate  would  boost  private 
investment.  Addressing 
challenges 
would  also  help  Poland  to  make  further 
the  Sustainable 
progress 
Development  Goals  (SDGs)  where  it  currently 
shows  some 
in 
particular  on  the  SDGs  for  affordable  clean 
energy (SDG 7) and quality education (SDG 4) 
(see Annex 1).  

in  achieving 

improvement, 

room  for 

these 

Ensuring efficient, sustainable, and 
transparent public finances as the 
population ages  

The  rapidly  ageing  population  is  putting 
the  pension  system  under  pressure. 
Poland  is  one  of  the  fastest-ageing  countries 
in  the  EU.  Within  four  decades,  the  share  of 
people  above  the  age  of  80  is  expected  to 
nearly  triple,  from  4%  of  the  population  in 
2019  to  12%  in  2060, with  a  sharp  increase 
occurring  from  2040.  However,  the  existing 
pension  system  assumes  a  retirement  age 
that  doesn’t  increase  even  as  average  life 
expectancy  and  years  spent  in  retirement 
continue  to  rise.  This  implies  that  benefits 
from  the  public  pension  system  will  decline 
rapidly  in  relative  terms  and  old-age  poverty 

to 

this  due 

would  increase (11).  Women  would  be  more 
their  shorter 
affected  by 
contributory  periods  and 
lower  overall 
pensionable earnings. To broadly maintain the 
current  level  of  pension  adequacy  without 
lengthening  working  lives,  the  government 
would  have  to  increase  public  spending  on 
pensions by 6.7% of GDP in 2070 (12). Benefits 
from  voluntary  saving  schemes (13)  under  the 
so-called  third  pension  pillar  would  likely  be 
insufficient to compensate for the loss of old-
age  income  given  the  low  contributions  made 
to  these  voluntary  saving  schemes,  although 
the  auto-enrolment 
some  solutions 
mechanism  in  the  Employee  Capital  Plans 
(PPK) mitigate this risk.  

like 

they 

come 

Recent changes in the general and special 
pension systems have made pension pay-
outs more generous to current pensioners 
price. 
but 
Recently introduced  13th  and  14th  pension 
benefits (14)  increased  annual  old-age  pension 
spending  by  close  to  10% (15).  Benefits  from 
the farmers’ special pension system were also 
expanded  in  recent  years  and  include:  (i)  the 
13th  and  14th  pension  payment;  (ii)  the  right 

at 

a 

(11)  Future benefits from the public pension system for new 
retirees will drop significantly in relative terms: from 
54% of final salary in 2019 to about 25% in 2060.  

(12)  Commission calculations based on The 2021 Ageing 

Report: Economic and Budgetary Projections for the EU 
Member States (2019-2070), Institutional Paper 148, 
2021, Brussels.  

(13)  Savings schemes include: PPE – pracownicze programy 
emerytalne; IKE – indywidualne konto emerytalne; IKZE 
– indywidualne konto zabezpieczenia emerytalnego; 
and PPK – pracownicze plany kapitałowe. 

(14)  Since 2019, the 13th month pension payment (i.e. an 
extra payment made in addition to the standard 
monthly pension payment) has been paid to all 
pensioners at the level of the minimum pension. Since 
2021, a 14th month pension has also been paid at the 
level of the minimum pension, with higher-income 
pensioners receiving a reduced amount. 

(15)  OECD (2021), Pensions at a Glance 2021: OECD and 

G20 Indicators, OECD Publishing, Paris.  

9 

 
 
                                                 
the 

general 

to continue to work while drawing the benefit 
(since  June  2022);  and  (iii)  a  supplement  to 
match 
old-age  minimum 
pension (16).  These  changes  reduce  incentives 
for  workers  to  work  longer  than  the  relatively 
low  retirement  age  as  well  as  to  switch  from 
the farmers’ special pension system (KRUS) to 
the  general  pension  system (ZUS).  One  of the 
changes introduced by the 2022 reform of the 
income-tax  system  under  the  ‘Polish  Deal’ 
included  reduction  of  the  tax  burden  on 
workers  delaying 
the 
statutory  age  to  prolong  working  lives  (see 
Annex 19). 

retirement  beyond 

improvements (17) 

Tax  compliance  has 
improved,  but 
considerable  scope  exists  to  boost  the 
efficiency  of  public  spending  on  social 
benefits  and  public  investment.  The  VAT 
compliance  gap  fell  to  11.3%  in  2020  but 
remains  above  the  level  observed  in  most 
other  EU  countries,  suggesting  scope  for 
further 
(see  Annex  19). 
Social  benefits  remain  largely  untargeted  and 
without  means-testing  at  household  level,  in 
particular for costly child benefits (the ‘Family 
500+’  programme).  This  has  resulted  in  a 
limited  redistributive 
welfare  system  with 
power. Much of public spending is captured by 
high-income  households,  as  the  richest  20% 
of Poles receive the same share of public cash 
transfers  as  the  poorest  20% (18).  In  2022, 
new  –  mostly  universal  –  support  measures 
were  introduced  to  offset  rising  energy  and 
living  costs.  However,  these  measures  did  not 
sufficiently  encourage  reduction  in  energy 
demand (see Annex 7). Furthermore, about one 
third  of  public  investment  spending  in  Poland 
did  not  result  in  an  increase  in  the  level  or 
quality of infrastructure that would have been 
achieved  by  the  most  efficient  countries  with 
comparable  levels  of  public  capital  stock  per 
capita (19).  Areas  with 
relatively  weak 

(16)  For more details on the changes see 

https://www.krus.gov.pl/.  

(17)  European Commission (2022) ‘VAT gap in the EU: report 
2022’, Publications Office of the European Union. 

(18)  OECD (2023), OECD Economic Surveys: Poland 2023, 

OECD Publishing, Paris.  

(19)  IMF (2022) Republic of Poland: Technical Assistance 
Report-Public Investment Management Assessment, 
Country Report No. 2022/321.  

performance include the coordination between 
entities,  budget  comprehensiveness  and  unity, 
maintenance  funding,  project  selection,  and 
portfolio  oversight  and  management.  The 
process of spending reviews that could support 
spending efficiency is being re-evaluated.  

Independent  fiscal  oversight  remains 
scattered,  reducing  transparency  in  the 
budgetary framework. Poland does not have 
a  fully-fledged  independent  fiscal  institution 
and  activities  related  to  the  monitoring  of 
fiscal  rules  are  scattered  among  several 
bodies,  with  the  Supreme  Audit  Office  (NIK) 
taking  a  central  role.  Compliance  with  fiscal 
rules can currently be assessed by three public 
institutions,  each  of  which  use  different 
methodologies  with  conflicting  conclusions 
and  communications,  as  was  the  case  in  the 
assessment  of  the  2021  budget  act (20).  The 
the  NIK  does  not  cover 
mandate  of 
macroeconomic  or  budgetary  forecasting,  and 
no  independent  institution  is  tasked  with  an 
assessment  of  the  long-term  sustainability  of 
public  finances  or  with  providing  costing 
estimates  to  the  parliament.  Weaknesses 
persist 
the  medium-term  budgetary 
framework (see Graph 3.1). 

in 

(20)  Poland’s Ministry of Finance publishes an annual report 
on budget execution, which also covers fiscal rules. The 
Monetary Policy Council submits to the parliament an ex 
ante assessment of the draft budget covering 
macroeconomic forecasts and, in the past, compliance 
with the stabilisation-expenditure rule. The NIK submits 
to the parliament a report on the execution of the 
Budget Act, including compliance with national fiscal 
rules. 

10 

 
                                                 
                                                 
Graph 3.1: Medium-term budgetary framework 
index 

systems. 

Challenges  remain  to  an  efficient  public 
procurement  process.  The  2021  reform 
improved  openness  and  transparency  in  the 
public  procurement 
In  2022, 
approximately  half  of  public  tenders  had  only 
one bidder participating (see Annex 12), which 
was  the  highest  percentage  among  all  EU 
countries.  The  World  Bank  estimates  that 
of 
potential 
procurement  costs  per  year if  Poland  used  a 
more  cost-effective  procurement  strategy 
without  necessarily  altering 
the  existing 
regulatory framework (23). 

savings  amount 

to  5% 

Poland scores 0 on the ‘link between budget & medium-
term fiscal plans’ and ‘involvement of independent fiscal 
institutions’.  
Source: Commission Fiscal Governance Database, 2021 
values 

Remaining weaknesses in 
education and healthcare 

The practice of channelling new spending 
via  extra-budgetary  funds  leads  to  an 
accumulation  of  debt  outside 
the 
coverage  of  regular  budgetary  practices 
and  rules.  Public  debt  outside  the  perimeter 
of  the  national  debt  brake  is  set  to  increase 
from  11%  of GDP in  2022  to  14%  of GDP  in 
2024  according  to  the  government’s  own 
projections (21).  This  is  mainly  on  account  of 
rising  debt  of  off-budget  funds  managed  by 
the  Polish  development  bank  (BGK),  with  the 
scope  of  activities  supported  by  BGK  funds 
constantly  broadening.  Bonds  issued  by  the 
BGK  likely  have  a  higher  premium  and  yields 
compared  to  state  treasury  issued  bonds 
leading  to  overall  higher  public  borrowing 
costs other things being equal. The diminished 
role of the Budget Act in recent years reduces 
transparency  and  undermines  the  role  of  the 
parliament  in  public  finances (22).  The  2023 
Convergence  Programme  includes  plans  to 
integrate  some  of  the  extra-budgetary  funds 
in the budget, in particular the COVID-19 Fund, 
and  a  gradual  reduction  in  borrowing  by  off-
budget funds to finance public spending. 

and 

The  pandemic  has  exacerbated  existing 
challenges  related  to  the  quality  and 
inclusiveness  of  education,  and  initial 
evidence shows that students’ basic skills 
deteriorated  over  this  period.  Teacher 
shortages have become more acute and more 
widespread  in  2023.  Problems  with  recruiting 
and  retaining  teachers  persist,  mainly  due  to 
low  salaries,  the  poor  image  of  the  teaching 
profession, 
deteriorating  working 
conditions (24). Despite a wide range of training 
opportunities  to  become  a  qualified  teacher, 
the  proportion  of  teachers  below  the  age  30 
ranges from less than 5% to 6%, compared to 
around  40%  of  teachers  aged  50  or  older. 
Trainee  teachers  account  for  only  2.8%  of  all 
employed  schoolteachers (25).  Due  to  multiple 
changes  in  the  schooling  system,  schools  and 
classes  are  overcrowded,  especially  in  larger 
cities. The focus on key competences is limited 
in both the new core curricula and in the new 
upper-secondary 
exam. 
school 
Because  the  central  subsidy  for  education  is 
increasing more slowly than expenditure, local 
governments  have  had  to  reduce investments 
infrastructure  and  extra-
in  educational 
children.  These 
curricular  activities 

leaving 

for 

(21)  Ministry of Finance (2022) The Public Finance Sector 
Debt Management Strategy in the years 2023-2026, 
Warsaw. 

(22)  NIK (2022) Analysis of execution of the state budget 
and monetary-policy assumptions in 2021, Warsaw. 

(23)  World Bank (2022) Poland Public Finance Review. 

Washington, D.C., World Bank Group. 

(24)  WUP Krakow (2023). Barometer of professions.  

(25)  Statistics Poland (2022) Education in the 2021/2022 

school year.  

11 

 - 0.5 1.0 1.5 2.0 2.5 3.01. Coverage of targets/ceilings2. Link annual budget & medium-term fiscal plans3. Involvement of parliament4. Involvement of IFI5. Level of detailPLEU average 
   
 
                                                 
                                                 
reductions affect children from disadvantaged 
socio-economic  backgrounds (26).  Against  this 
backdrop, Poland is aiming to make education 
more  inclusive  with  the  help  of  EU  funds. 
Efforts  to  improve  the  quality  of  higher 
education  continue  to  face  challenges,  as  the 
results  of  the  first  evaluation  of  higher 
education institutions under the new rules are 
questioned.  

in 

key 

shortages 

Labour 
sectors 
necessary  for  the  green  transition  have 
increased  in  recent  years.  In  2022,  labour 
shortages  were  reported  in  Poland  for  33 
occupations  that  required  specific  skills  or 
knowledge  for  the  green  transition.  These 
occupations  included  plumbers,  pipe  fitters, 
related 
roofers,  building  electricians,  and 
specialist  electricians (27). 
labour 
In  2022, 
shortages  were 
factor 
reported  as  a 
constraining production in industry (for 63.4% 
of  firms)  and  construction  (for  74.6%  of 
firms) (28). The job-vacancy rate has increased 
across key sectors such as construction (from 
1.0% 
in  2021)  and 
to  2.5% 
manufacturing (from 0.6% in 2015 to 1.1% in 
2021), although both sectors still stand below 
the EU average for vacancies in these sectors 
in  2021  of  3.6%  and  1.9%,  respectively (29). 
the  green 
Upskilling  and 
reskilling 
labour 
transition  and  promoting 
to 
markets  are  essential  policy 
accelerate  the  transition  to  net-zero  and 
ensure its fairness (see Annex 8). 

for 
inclusive 

in  2015 

levers 

Despite the comprehensive reform of the 
healthcare  system  planned  in  the  RRP, 

(26)  NIK (2022), Financing education by local governments.  

(27)  Data on shortages are based on European Labour 

Authority (2023), EURES Report on labour shortages and 
surpluses 2022. National authorities report through a 
questionnaire, based on administrative data and other 
sources as submitted by the EURES National 
Coordination Offices (definitions of shortages differ, so 
data are not comparable across countries and cover a 
wide variety of sectors). Skills and knowledge 
requirements are based on the ESCO (European Skills 
Competences and Occupations) taxonomy of skills for 
the green transition (for occupations at ISCO 4-digit 
level of which there are 436 in total). Examples are 
identified based on their ESCO ‘greenness’ score and 
relevant sectors. 

(28)  European Business and Consumer Survey. 

some  areas  require  further  action.  This  is 
especially  the  case  for  preventive  health 
services,  primary  care  and  psychiatric  care. 
Health-promotion  and 
sickness-prevention 
programmes  have  been  underdeveloped, 
despite  high  rates  of  reported  preventable 
mortality,  and  the  share  of  spending  on 
preventive  care  fell  in  2019.  Because  the 
the 
number  of  psychiatrists 
population  is  the  lowest  in  the  EU,  psychiatric 
healthcare 
in  Poland  does  not  provide 
comprehensive  and  accessible  care, especially 
for  children  and  adolescents  and  those  living 
rural  areas (30). 
towns  and 
in 
smaller 
Additionally, 
the  prevalent  hospital-based 
model  of  mental  healthcare  is  not  efficient. 
The  Ministry  of  Health  has  initiated  reforms 
that  are  based  on  providing  more  care  in 
community-based settings.  

relative 

to 

Reducing reliance on fossil fuels 
and accelerating the green 
transition  

continue 

(RES),  which 

The  Polish  energy  mix  remains  heavily 
dominated  by  fossil  fuels.  Approximately 
90%  of  Poland’s  energy  mix  in  2021  was 
derived  from fossil fuels. Coal  alone accounts 
for around 60% of the energy mix and 72% of 
total  electricity  generation.  Renewable  energy 
sources 
to  be 
substantially  less  subsidised  than  fossil  fuels, 
only accounted for around 13% of the energy 
mix  and  only  18%  of 
total  electricity 
generation  (see  Annex  6).  Poland  allocates 
more  than  the  EU  average  to  fossil-fuel 
subsidies,  especially  for  coal  and  oil.  The 
mining  of  hard  coal  is  expected  to  phase  out 
gradually  and  only  by  2049 (31).  While  energy 
prices  have  decreased,  uncertainty  remains 
regarding 
requires 
next  winter,  which 
continued  efforts  to  structurally  reduce  gas 
demand. 

(30)  Maps of health needs – System and Implementation 

Analysis Database, Ministry of Health Poland. 

(31)  International Energy Agency. Poland 2022 – Energy 

(29)  Eurostat (JVS_A_RATE_R2). 

Policy Review. 

12 

 
                                                 
                                                 
Poland has undertaken a number of steps 
to  reduce  its  dependence  on  Russian 
imports  of  fossil  fuels.  In  2021,  Russia 
accounted for 53% of the value of Polish fuel 
imports (32).  Poland  has  recently  completed  a 
number  of  gas-infrastructure 
investments 
funded  from  national  and  EU  cohesion-policy 
funds,  which  made  it  possible  for  the  country 
to substantially diversify its natural-gas supply 
and  increase  energy  security  starting  in  the 
second  half  of  2022  (see  Annex  7).  Beyond 
this,  the  reduction  of  Poland’s  reliance  on 
fossil  fuels  is  an  essential  part  of  ensuring 
security of supply. 

rate 

Current  measures  to  decarbonise  the 
economy  are  not  well  aligned  with  the 
EU’s  2030  climate  and  energy  targets. 
Poland  has  been  decarbonising  at  a 
than  other  EU 
substantially  slower 
Member  States.  Compared  with  2005,  Polish 
greenhouse-gas  emissions  fell  by  only  1%  in 
2021  against  an  EU  average  reduction  of 
24% (33).  Emissions  from  the  energy  sector 
remain  high,  as  do the impacts  of  the  carbon 
price on the economy. Poland is also behind in 
reducing  emissions  in  the  non-ETS  sectors, 
including  buildings  and  transport  (see  Annex 
6).  The  government’s  2019  National  Energy 
and  Climate  Plan  (NECP)  prescribes  that  the 
share of RES in the energy mix to increase to 
between  21%  and  23%  of  gross  final  energy 
consumption  by  2030.  This  RES  target  is  not 
sufficiently  ambitious  in  light  of  the  32% 
overall  EU  renewable  energy  target  set  for 
2030  in  2018.  Although  an  update  of  the 
NECP  is  expected  in  2023,  the  lack  of  an  up-
to-date  energy  policy 
is  holding  back 
decarbonisation efforts while the absence of a 
long-term  strategy  for  climate  neutrality 
hinders  long-term  planning.  This  is  further 
exacerbated by the fact that, as laid out in its 
national strategy ‘Energy Policy of Poland until 
2040’,  Poland  plans  a  considerable  expansion 
of gas-fired generation capacity and intends to 
considerably 
gas 
natural 
is  one  of  the  top 
consumption.  Poland 
revenue-generating  members  of  the  EU  ETS, 

increase 

its 

(32)  E. (2022, November 15). ‘Poland on the way to 
independence from Russian fuels’ | Obserwator 
Finansowy: Ekonomia, Debata, Polska, Świat. 

but only designates 50% of these revenues  – 
the  minimum  percentage  required  by  the  ETS 
Directive  –  to  climate  and  energy-related 
initiatives. Achieving carbon neutrality by 2050 
will require a shift towards energy efficiency, a 
diffuse  electrification  of  the  economy,  a 
significant  deployment  of  RES  and  scaling  up 
the manufacturing of clean technologies (34). 

inefficient,  contributing 

Despite a number of measures in place to 
contain  energy  demand,  further  efforts 
are  needed  to  improve  energy  efficiency, 
especially  for  residential  buildings  and 
district  heating  systems.  Final  energy 
consumption in Poland was 75,2 Mtoe in 2021, 
and it has mostly been on the rise throughout 
the last decade (see Annex 6). Currently, more 
than half of the energy demand of residential 
buildings for heating is satisfied by coal, either 
through  direct  use  or  indirectly  in  district 
heating.  However,  residential  buildings  remain 
largely  energy 
to 
higher  investment  needs  compared  to  other 
EU  countries.  Additionally,  the  district-heating 
sector requires targeted reforms and stepped-
up 
its 
to 
decarbonisation  and  to  ensure  its  long-term 
financial viability. On the positive side, because 
of  the  rise  in  energy  prices,  heat-pump  sales 
have increased substantially in recent months, 
making Poland one of the EU’s fastest growing 
markets  for  heat  pumps.  The  RRP  and  the 
2021-2027 
programmes 
cohesion-policy 
include a broad range of measures to improve 
energy  efficiency  in:  (i)  selected  economic 
sectors;  (ii)  private  and  public  buildings;  and 
(iii)  district  heating  systems.  However,  further 
efforts  are  needed  to  adequately  address 
these challenges.  

investments 

accelerate 

energy 

generation 

from 
Increasing 
renewable  energy  sources 
is  key  to 
decarbonising  the  Polish  economy  and  to 
achieving  climate  neutrality.  Although  RES 
account  for  a  small  share  of  the  energy  mix, 
national  and  EU  support  for  photovoltaic  (PV) 
installations  has  resulted  in  Poland  becoming 
one  of  the  fastest  growing  PV  markets in  the 
EU, with installed capacity reaching 11 GW. In 
2022,  Poland 
installed  4.9  GW  of  solar 
capacity,  equivalent  to  12%  of  the  EU’s  total 

(33)  EU Climate Action Progress Report, 2022. 

(34)  Net Zero Industry Act. COM(2023) 161. 

13 

 
                                                 
                                                 
newly  installed  capacity  that  year.  The  2020 
Offshore Wind Act outlines the framework for 
the  development  of  offshore  wind  farms.  On 
onshore wind energy, Poland has introduced a 
law to amend the minimum distance between 
onshore  wind 
installations  and  residential 
buildings  to  700  metres.  Although  the  recent 
revision  boosts  investment  in  onshore  wind 
capacity, the 700-metre-distance rule reduces 
the surface area available to build installations 
compared  with  the  initially  envisaged  500-
metre 
(see  Annex  7).  Accelerated 
investment  in  renewable  hydrogen  generation 
could  enable 
fast-track 
the  country 
decarbonisation  in  the  transport  and  industry 
sectors. 
in 
further 
biomethane  could  increase  the  security  of 
energy  supply  and  decrease  dependence  on 
fossil fuels. 

investment 

Finally, 

limit 

to 

To  unleash  the  potential  of  renewable 
energy  sources,  Poland  needs  to:  (i) 
improve  its  internal  networks  for  energy 
transmission  and  distribution;  and  (ii) 
reform  its  regulatory  environment. 
In 
particular, Poland should implement measures 
to  remove  barriers  to  RES  permitting:  (i) 
accelerating  the  inclusion  of  RES  in  spatial 
plans;  (ii)  setting  up  renewables  go-to  areas; 
(iii) amending rules on grid-connection permits; 
and (iv) reforms and investments to modernise 
obsolete  and  inefficient  distribution  networks. 
Poland still has a long way to go to dismantle 
regulatory  and  administrative  barriers 
to 
accelerate  the  deployment  of  RES.  Further 
reforms  are  needed  to:  (i)  enable  industry  to 
benefit 
through 
arrangements  such  as  power  purchase 
agreements  (PPAs);  (ii)  remove  restrictions  on 
energy  communities;  and  (iii)  promote  the 
deployment  of  renewables 
in  the  district 
heating sector. 

energy 

clean 

from 

Decarbonising  the  transport  sector  will 
be  essential  to  reducing  greenhouse-gas 
emissions.  In  the  absence  of  coordinated 
decarbonisation  measures,  emissions  from 
transport in Poland have continued to rise, and 
even  tripled  between  1990-2019.  Moreover, 
90%  of  these  emissions  stem  from  road 
transport.  Public  urban  transport  and  rail 
transport  are  still  not  attractive  alternatives 
compared with private cars, thus exacerbating 

air  pollution  and  traffic  congestion.  Between 
2008  and  2018,  regional  and  suburban  bus 
lines  were  reduced,  resulting  in  approximately 
65% of the rural population now being unable 
to  access  public  transportation.  Against  this 
backdrop, although the RRP includes measures 
to  promote  sustainable  mobility  via  public 
urban 
and 
investments in railways, a strategic framework 
to decarbonise the transport sector is needed. 

transport, 

vehicles, 

clean 

Strengthening the business 
environment and investment  

progress 

Investment 

Low  levels  of  investment  could  limit 
future  productivity  gains  and  economic 
growth  in  Poland.  Private  investment  as  a 
percentage of GDP in 2022 was low at 19.1%, 
well  below  the  EU-wide  average  (25.8%)  and 
that of regional peers such as Czechia (29.1%) 
and  Hungary 
is 
(35.0%). 
in  the  most  productive 
particularly  weak 
and 
sectors, 
information 
as 
such 
rapid 
technology,  where 
communications 
high 
requires 
technological 
investment  outlays (see  Annex  12).  The  share 
of  buildings  and  infrastructure  investment  in 
total  investment  was  51.5%,  while  intangible 
assets  (e.g.  R&D  investment  and  intellectual 
property) accounted for just 9.7%, limiting the 
ability  of  the  economy  to  move  up  the  value 
chain.  The  country  is  also  performing  below 
the  EU  average  on  innovation  indicators  (see 
Annex  11).  Overall, 
capital 
investments in high-productivity sectors will be 
crucial to sustaining Poland’s strong economic 
performance and facilitating the shift towards 
a greener growth model. 

increasing 

is  poor.  No 

Social  dialogue 
impactful 
measures have been implemented in 2022 to 
strengthen  consultations  with  –  and  the 
involvement  of  –  social  partners 
in  the 
legislative  process  and  improve  the  overall 
quality  of social  dialogue (see Annex 14). The 
collective bargaining coverage remains limited. 

Serious  concerns  related  to  the  rule  of 
law  continue  to  impair  the  investment 
climate in Poland. The perception of judicial 
independence  among  the  general  public  and 

14 

 
included 
number  of  other  areas.  These 
shortcomings  in  the  independence  of  the 
prosecution  service  and  in  the  functioning  of 
the Supreme Audit Office, both of which affect 
fight  against 
the  effectiveness  of 
corruption. 

the 

to 

the 

rulings  on 

companies  is  very  low  (see  Annex  12).  The 
Commission’s  2022  Rule  of  Law  Report (35) 
highlights  persistent  concerns  that  affect  the 
independence of the judiciary. Since July 2021, 
the  Court  of  Justice  of  the  EU  and  the 
European  Court  of  Human  Rights  have 
delivered  several 
issues 
identified  by  the  Commission.  Poland  refused 
to comply with interim measures orders of the 
European  Court  of  Human  Rights  and  has  so 
far  failed  to  fully  comply  with  an  interim 
measures order of the Court of Justice of the 
EU  of  14  July  2021  pertaining  to  the 
disciplinary  regime  for  judges.  In  view  of 
notable progress in the implementation of the 
aforementioned  interim  measures  order,  in 
April  2023,  the  Court  of  Justice  of  the 
European  Union  reduced  the  daily  financial 
penalty imposed on Poland from 1 million EUR 
to  0.5  million  EUR (36).  In  its  RRP,  Poland 
the  disciplinary 
reforming 
committed 
regime  for  judges  and  to  setting  up  a  review 
independent  court  for 
process  before  an 
judges  affected  by  decisions  of 
the 
Disciplinary Chamber of the Supreme Court. To 
this end, Poland adopted a law, which entered 
into 
On 
Parliament 
the 
13 January 2023, 
adopted  another  law  to  further  address  the 
commitments  in  its  RRP.  The  President  of  the 
Republic referred this law to the Constitutional 
Tribunal. Therefore, it has not yet entered into 
force.  At  the  time  of  Poland’s  first  payment 
request,  the  Commission  will  carefully  assess 
the  satisfactory  fulfilment  of  the  milestones 
committed  to  by  Poland.  Poland  has  not 
addressed the serious concerns related to the 
National Council for the Judiciary following the 
reform of the country’s justice system in 2017. 
the 
Furthermore, 
Commission  decided  to  refer  Poland  to  the 
Court of Justice of the EU for violations of EU 
law  by  the  Polish  Constitutional  Tribunal  and 
the 
law,  which,  according 
its  case 
Commission,  challenged  notably  the  primacy 
of EU law (37). The Commission’s 2022 Rule of 
Law  Report  also  highlighted  concerns  in  a 

on  15 February 2023, 

15 July 2022. 

Polish 

force 

on 

to 

(35)  EUR-Lex - 52022SC0521 - EN - EUR-Lex (europa.eu). 

(36) https://curia.europa.eu/jcms/upload/docs/application/pdf/

2023-04/cp230065en.pdf  

(37) https://ec.europa.eu/commission/presscorner/detail/en/ip

_23_842.  

15 

 
                                                 
KEY FINDINGS 

Poland’s  RRP 
to 
address a  series  of  structural challenges 
through:  

includes  measures 

 

improving the efficiency of public spending 
and  making  the  public  finances  more 
transparent; 

steady  implementation  of  its  recovery  and 
resilience plan. 

Beyond  the  reforms  and  investments  in 
the  RRP  and  in  the  2021-2027  cohesion-
policy programmes, Poland would benefit 
from: 

as 

the 

such 

  addressing  disparities  in  labour  market 
gender 
participation 
employment gap; ensuring more Poles are 
covered  by  social-protection  systems; 
strengthening public employment services; 
and 
fostering  quality  education  and 
demand-driven skills; 

 

 

 

 

 

improving  the  resilience,  accessibility,  and 
effectiveness  of 
the  health  system, 
including  through  increased  access  to  e-
health services; 

strengthening 
between 
researchers  and  businesses  to  improve 
innovation; 

collaboration 

improving  the  further  digitalisation  of 
public 
schools, 
administration, 
the 
including 
development of appropriate infrastructure;  

and 
through 

businesses, 

significantly  accelerating  investments  in 
decarbonisation,  energy 
transformation, 
and sustainable transport; 

the 

improving 
in 
particular  by  raising  the  standard  of 
certain aspects of judicial protection; 

investment  climate, 

  ensuring effective public consultations and 
the  involvement  of  social  partners  in  the 
policy-making process; 

Poland  should  urgently  fulfil  the  required 
the 
targets 
milestones  and 
protection  of  the  financial  interests  of  the 
Union  with  a  view  to  allow  for  a  swift  and 

related 

to 

taking  measures 
the 
sustainability  of  the  pension  system,  and 
strengthening independent fiscal oversight;  

improve 

to 

improving  the  efficiency  of  spending  on 
social  benefits  and  public  investment,  as 
well  as  continuing  to 
improve  public 
procurement; 

to 

taking  further  steps 
tackle  skills 
mismatches  and  addressing  challenges 
related to the quality and inclusiveness of 
education and training;  

stepping  up  efforts  to  reduce  its  reliance 
on  fossil  fuels  and 
improving  energy 
efficiency,  in  particular  of  the  building 
stock;  increasing  energy  generation  from 
renewable  energy  sources,  including  by 
permitting 
streamlining 
procedures; 
distribution 
energy 
improving 
networks,  increasing  transparency  of  grid 
connection  procedures  and  planning; 
promoting  sustainable  public  transport 
modes;  enhancing  investments  in  green 
skills 
transition 
and 
technologies; 

energy 

key 

the 

further  enhancing  the  investment  climate, 
including 
judicial 
independence;  and  improving  the  social 
dialogue. 

safeguarding 

by 

 

 

 

 

 

16 

 
 
ANNEXES 

 
 
 
 
LIST OF ANNEXES 

Cross-cutting indicators 

A1.  Sustainable Development Goals 

A2.  Progress in the implementation of country-specific recommendations 

A3.  Recovery and resilience plan - overview 

A4.  Other EU instruments for recovery and growth 

A5.  Resilience 

Environmental sustainability 

A6.  European Green Deal 

A7.  Energy security and affordability 

A8.  Fair transition to climate neutrality 

Productivity 

A9.  Resource productivity, efficiency and circularity 

A10.  Digital transformation 

A11.  Innovation 

A12.  Industry and single market 

A13.  Public administration 

Fairness 

A14.  Employment, skills and social policy challenges in light of the European Pillar of Social Rights 

A15.  Education and training 

A16.  Health and health systems 

A17.  Economic and social performance at regional level 

Macroeconomic stability 

A18.  Key financial sector developments 

A19.  Taxation 

A20.  Table with economic and financial indicators 

A21.  Debt sustainability analysis 

LIST OF TABLES 

A2.1. 
A3.1. 

Summary table on 2019-2022 CSRs 
Key elements of Poland's RRP 

19 

22 

22 

25 

28 

29 

32 

33 

33 

38 

44 

47 

47 

49 

51 

53 

57 

59 

59 

62 

65 

67 

70 

70 

72 

74 

75 

26 
28 

 
 
 
Industry and Single Market 

A5.1. 
Resilience indices summarising the situation across RDB dimensions and areas 
A6.1. 
Indicators tracking progress on the European Green Deal from a macroeconomic perspective 
A7.1. 
Key energy indicators 
A8.1. 
Key indicators for a fair transition in Poland 
A9.1. 
Overall and systemic indicators on circularity 
A10.1.  Key Digital Decade targets monitored by DESI indicators 
A11.1.  Key innovation indicators 
A12.1. 
A13.1.  Public administration indicators 
A14.1.  Social Scoreboard for Poland 
A14.2.  Situation of Poland on 2030 employment, skills and poverty reduction targets 
A16.1.  Key health indicators 
A17.1.  Selected indicators at regional level - Poland 
A18.1.  Financial soundness indicators 
A19.1.  Taxation indicators 
A20.1.  Key economic and financial indicators 
A21.1.  Debt sustainability analysis - Poland 
A21.2.  Heat map of fiscal sustainability risks - Poland 

LIST OF GRAPHS 

Progress towards the SDGs in Poland in the last 5 years 
Poland’s progress on the 2019-2022 CSRs (2023 European Semester) 
Share of RRF funds contribution to each policy pillar 
Cohesion policy funds 2021-2027 in Poland: budget by fund 
Synergies between cohesion policy funds and RRF six pillars in Poland 
Cohesion policy funds contribution to the SDGs in 2014-2020 and 2021-2027 in Poland 
Thematic – greenhouse gas emissions from the effort sharing sectors in Mt CO2eq, 2005-2021 
Energy mix (top) and electricity mix (bottom), 2021 
Thematic – environmental investment needs and current investment, p.a. 2014-2020 
Underground gas storage levels in Poland 
Share of gas consumption per sector, 2021 
Share of gas consumption per industrial sector, 2021 (% of industry total gas consumption) 
Poland´s retail energy prices for industry (top) and households (bottom) 
Public (top) and Private (bottom) R&I investment in Energy Union R&I priorities 
Fair transition challenges in Poland 
Distributional impacts of energy prices due to rising energy expenditure (2021-2023) in Poland 
Trend in material use 
Treatment of municipal waste 

A1.1. 
A2.1. 
A3.1. 
A4.1. 
A4.2. 
A4.3. 
A6.1. 
A6.2. 
A6.3. 
A7.1. 
A7.2. 
A7.3. 
A7.4. 
A7.5. 
A8.1. 
A8.2. 
A9.1. 
A9.2. 
A11.1.  R&D intensity in Poland over time 
A12.1. 
A12.2.  Nominal labour productivity per hour worked (EU=100) 
A12.3.  Business environment and productivity drivers 
A13.1.  Poland. E-government maturity and e-government users 
A13.2.  Poland. a) Regulatory impact assessment, b) Stakeholder engagement and c) Ex post evaluation of legislation 
A15.1.  Age profile of teachers in Poland 
A16.1.  Life expectancy at birth, years 
A16.2.  Projected increase in public expenditure on healthcare over 2019-2070 
A17.1.  GDP (PPS) per capita (2010) and GDP growth (2010-2020) in Poland 
A18.1.  Credit growth 
A19.1.  Tax revenues from different tax types, % of total taxation 
A19.2.  Tax wedge for single and second earners, % of total labour costs, 2022 

Investment, % GDP 

LIST OF MAPS 

A17.1.  Poland GDP per capita (PPS) by NUTS 2 region, 2020 

20 

32 
33 
38 
44 
48 
50 
51 
55 
57 
59 
60 
65 
68 
70 
72 
74 
76 
77 

24 
25 
28 
29 
29 
30 
33 
34 
35 
38 
39 
39 
40 
42 
44 
45 
47 
48 
51 
53 
54 
55 
57 
58 
62 
65 
65 
67 
70 
73 
73 

67 

 
 
 
CROSS-CUTTING INDICATORS 
ANNEX 1: SUSTAINABLE DEVELOPMENT GOALS 

of 

four 

dimensions 

This Annex assesses Poland’s progress on the 
Sustainable Development Goals (SDGs) along 
the 
competitive 
sustainability.  The  17  SDGs  and  their  related 
indicators  provide  a  policy  framework  under  the 
UN’s  2030  Agenda  for  Sustainable  Development. 
The  aim  is  to  end  all  forms  of  poverty,  fight 
inequalities  and  tackle  climate  change  and  the 
environmental crisis, while ensuring that no one is 
left  behind.  The  EU  and  its  Member  States  are 
committed  to  this  historic  global  framework 
agreement  and  to  playing  an  active  role  in 
maximising  progress  on  the  SDGs.  The  graph 
below  is  based  on  the  EU  SDG  indicator  set 
developed  to monitor progress  on  the  SDGs  in  an 
EU context. 

While  Poland  is  improving  on  some  of  the 
indicators  related  to  environmental 
SDG 
sustainability, it is moving away from SDG 7 
(Affordable  and  clean  energy),  SDG  14  (Life 
below  water)  and  SDG  15  (Life  on  land). 

final 

energy 

in  gross 

Poland  has  made  some  progress  on  energy 
consumption  indicators  including  the  share  of 
renewable 
energy 
consumption  (SDG  7;  from  11.4%  in  2016  to 
15.6% in 2021; EU average 21.8%). However, it is 
moving  away  from  the  EU  average  on  per  capita 
net  greenhouse  gas  (GHG)  emissions  (SDG  13; 
10.1  tonnes  in  2021  compared  to  9.6  tonnes  in 
2016;  EU  average  of  7.4  tonnes 
in  2021). 
Moreover,  Poland  is  rapidly  losing  carbon  sinks, 
with  the  net  GHG  emissions  from  land  use  and 
forestry  (LULUCF)  increasing  from  -122.7  tonnes 
CO2  eq.  per  km²  in  2016  to  -67.9  in  2021, 
compared  to  the  EU  average  of  -50.1).  Moreover, 
Poland’s energy import dependency has increased 
(from  19.8%  in  2015  to  42.8%  in  2020;  EU 
average 57.5%). As for affordable energy (SDG 7), 
the percentage of the Polish population unable to 
keep  their  homes  adequately  warm  was  lower 
(3.2%  in  2021)  than  the  EU  average  (6.9%). 
Poland’s 
(RRP) 
includes measures to address some of the energy-

resilience  plan 

recovery  and 

Graph A1.1: Progress towards the SDGs in Poland in the last 5 years 

For detailed datasets on the various SDGs, see the annual Eurostat report ‘Sustainable development in the European Union’; for 
details on extensive country-specific data on the short-term progress of Member States: Key findings - Sustainable development 
indicators - Eurostat (europa.eu). The status of each SDG in a country is the aggregation of all the indicators for the specific goal 
compared to the EU average. A high status does not mean that a country is close to reaching a specific SDG, but signals that it is 
doing better than the EU on average. The progress score is an absolute measure based on the indicator trends over the past 5 
years. The calculation does not take into account any target values as most EU policy targets are only valid for the aggregate EU 
level. Depending on data availability for each goal, not all 17 SDGs are shown for each country. 
Source: Eurostat, latest update of early April 2023, except for the EU Labour Force Survey (LFS) indicators released on 27 April 
2023. Data mainly refer to 2016-2021 or 2017-2022. 

21 

 
 
 
 
 
 
related  challenges,  namely  on 
the  energy 
renovation  of  buildings,  energy  efficiency  of 
business  and  the  decarbonisation  of  energy 
production. On SDG 14, Poland is not progressing, 
as  shown,  in  particular,  by  its  low  and  decreasing 
share of coastal water bathing sites with excellent 
water quality (44.8% in 2021; EU average 78.2%). 
While  Poland 
improving  on  several  SDG 
indicators  related  to  SDG  11  (Sustainable  cities 
and communities), its share of buses and trains in 
total  passenger  transport  has  decreased  (from 
21.3%  in  2015  to  12.4%  in  2020;  EU  average 
reduce 
the  country  needs 
12.8%)  and 
premature  deaths  due  to  exposure  to  fine 
particulate  matter  (PM2.5)  (96 
in  2020;  EU 
average 54). 

to 

is 

While  Poland  is  improving  on  most  SDG 
indicators related to fairness (SDGs 1, 3, 5, 8 
and  10),  it  still  needs  to  catch  up  on  SDG  2 
(zero  hunger)  and  is  moving  away  from  SDG 
4  (quality  education).  Poland  performs  well  on 
the  indicators  for  people  at  risk  of  poverty  or 
social exclusion (SDG 1; 16.8% in 2021 compared 
to 20.6% in 2016 and the EU average of 21.7% in 
2021) and for income distribution (SDG 10; 4.0 in 
2021  compared  to  4.8  in  2016  and  the  EU 
average  of  5.0  in  2021).  In  addition,  Poland  has 
improved  on  several  fairness-related  indicators 
such as the long-term unemployment rate (SDG 8; 
0.9% in 2022 compared to 1.5% in 2017 and the 
EU  average  of  2.4%).  However,  Poland  needs  to 
reduce  avoidable  mortality  (SDG  3;  418.9  deaths 
per 100 000 persons in 2020, compared to the EU 
average of 271.7) and improve on the indicator on 
people  outside  the  labour  force  due  to  caring 
responsibilities (SDG 5; 1.1 pps in 2022, compared 
to  the  EU  average  of  1.2  pps).  Moreover,  the 
country  is  moving  away  from  SDG  4  on  several 
indicators  related  to  quality  education,  including 
tertiary  educational  attainment  (40.5%  in  2022 
compared  to  43.6% in  2017;  EU  average:  42% in 
2022)    although  it  seems  to  have  reversed  the 
negative  trend  on  early  leavers  from  education 
and  training (4.8%  in  2022,  compared  to  5.0% in 
2017  and  the  EU  average  of  9.6%  in  2022)  and 
still performs better than the EU average on both 
indicators.  Poland  is  also  moving  away  from  the 
EU  average  on  several  indicators  related  to  food 
and  farming  (SDG  2),  including  the  indicator 
regarding the area under organic farming (3.5% in 
2020  compared  to  4%  in  2015  and  the  EU 
average of 9.1% in 2020).  

is 

rate 

(SDG  8;  76.7% 

Poland 
improving  on  some  SDGs  on 
productivity (SDGs 8 and 9), but it is moving 
away from the EU average on SDG 4 (Quality 
education).  Poland  performs  well  on 
its 
in  2022 
employment 
compared  to  70.0%  in  2016  and  the  EU  average 
of 74.6% in 2022). On the negative side, Poland is 
moving away from the EU average on the indicator 
for  the  investment  share  of  GDP  (SDG  8;  17%  in 
2021  compared  to  18.5%  in  2016  and  the  EU 
average  of  22.4%  in  2021).  Therefore,  the  Polish 
RRP includes several measures aimed at improving 
the  investment  climate.  Poland  is  improving  but 
still  performs  far  below  the  EU  average  on 
indicators  related  to  R&D  and  innovation,  and 
sustainable 
industry  (SDG  9),  including  gross 
domestic  expenditure  on  R&D  (1.44%  of  GDP  in 
2021, compared to the EU average of 2.27%) and 
air  emissions  intensity  of  fine  particulate  matter 
(PM2.5)  from  industry  (0.28  g  per  euro  in  2020, 
compared  to  the  EU  average  of  0.07  g).  On  the 
share  of  households  with  a  high-speed  internet 
connection,  Poland  has  made 
considerable 
progress and is close to achieving the EU average 
of  70.2%  in  2021.  However,  the  share  of  adults 
with  at  least  basic  digital  skills  (SDG  4)  remains 
low (42.9% in 2021, compared to the EU average 
of 53.9%). 

is 

Poland 
indicators 
improving  on  SDG 
related  to  macroeconomic  stability  (SDGs  8 
and 16), but still needs to catch up compared 
to the EU. It has improved on SDG 8 (Decent work 
and  economic  growth),  although  real  GDP  per 
capita  (EUR  14 600  in  2022)  remains  below  the 
EU average of EUR 28 820. As regards justice and 
strong institutions (SDG 16), Poland has increased 
its  general  government  total  expenditure  on  law 
courts (SDG 16) (EUR 78.1 per capita) but needs to 
catch  up  with  the  EU  average  of  EUR 100.7. 
However,  perceptions  of  the  independence  of  the 
justice  system  have  become  more  negative,  with 
the  percentage  of  people  who  consider  the 
judiciary to be fairly good and very good declining 
steeply from 50% in 2017 to 24% in 2022 (the EU 
average  is  53%).  Poland’s  Corruption  Perceptions 
Index  has  also  deteriorated  (from  60  in  2017  to 
55  in  2022,  compared  to  the  EU  average  of  64). 
On  the  positive  side,  Poland  performs  well  on the 
‘population  with  confidence 
in  the  European 
Parliament’ index’ (55% of the population in 2022, 
compared to 43 in 2017 and the EU average of 50 
in  2022).  The  Polish  RRP  includes  measures 
related to the independence of the justice system.  

22 

 
As the SDGs form an overarching framework, any 
links  to  relevant  SDGs  are  either  explained  or 
depicted with icons in the other Annexes. 

23 

 
ANNEX 2: PROGRESS IN THE IMPLEMENTATION OF COUNTRY-SPECIFIC 
RECOMMENDATIONS 

Graph A2.1: Poland’s progress on the 2019-2022 
CSRs (2023 European Semester) 

The Commission has assessed the 2019-2022 
country-specific  recommendations  (CSRs) (38) 
addressed to Poland as part of the European 
Semester.  These  recommendations  concern  a 
wide  range  of  policy  areas  that  are  related  to  15 
of  the  17  Sustainable  Development  Goals  (see 
Annexes  1  and  3). The  assessment  considers  the 
policy  action  taken  by  Poland  to  date (39)  and  the 
commitments  in  its  recovery  and  resilience  plan 
(RRP) (40).  At  this  stage  of  RRP  implementation, 
33%  of  the  CSRs  focusing  on  structural  issues 
from  2019-2022  have  recorded  at  least  ‘some 
progress’,  while  50%  recorded  ‘limited  progress’ 
(see  Graph  A2.1).  As  the  RRP  is  implemented 
further,  considerable  progress 
in  addressing 
structural CSRs is expected in the years to come. 

Source: European Commission 

(38)  2022 CSRs: EUR-Lex - 32022H0901(21) - EN - EUR-Lex 

(europa.eu) 

      2021 CSRs: EUR-Lex - 32021H0729(21) - EN - EUR-Lex 

(europa.eu) 
2020 CSRs: EUR-Lex - 32020H0826(21) - EN - EUR-Lex 
(europa.eu) 
2019 CSRs: EUR-Lex - 32019H0905(21) - EN - EUR-Lex 
(europa.eu) 

(39)  Including policy action reported in the national reform 

programme and in Recovery and Resilience Facility (RRF) 
reporting (twice a year reporting on progress in implementing 
milestones and targets and resulting from the payment 
requests assessment). 

(40)  Member States were asked to effectively address all or a 

significant subset of the relevant country-specific 
recommendations issued by the Council in 2019 and 2020 in 
their RRPs. The CSR assessment presented here considers the 
degree of implementation of the measures included in the 
RRP and of those carried out outside of the RRP at the time 
of assessment. Measures laid down in the Annex of the 
adopted Council Implementing Decision on approving the 
assessment of the RRP, which are not yet adopted or 
implemented but considered credibly announced, in line with 
the CSR assessment methodology, warrant ‘limited progress’. 
Once implemented, these measures can lead to 
‘some/substantial progress or full implementation’, 
depending on their relevance. 

24 

No Progress17%Limited Progress50%Some Progress25%Substantial Progress4%Full Implementation4% 
 
 
 
 
 
                                                 
 
  
 
 
 
 
Table A2.1: Summary table on 2019-2022 CSRs 

(Continued on the next page) 

25 

PolandAssessment in May 2023*RRP coverage of CSRs until 2026Relevant SDGs2019 CSR 1Some progressEnsure that the nominal growth rate of net primary government expenditure does not exceed 4.4% in 2020, corresponding to an annual structural adjustment of 0.6% of GDP. Not relevant anymoreNot applicableSDG 8, 16Take further steps to improve the efficiency of public spending, including by improving the budgetary process.Some progressRelevant RRP measures planned as of 2021, 2022, and 2025.SDG 8, 162019 CSR 2Limited progress Ensure the adequacy of future pension benefits and the sustainability of the pension system by taking measures to increase the effective retirement age and by reforming the preferential pension schemes. Limited progressRelevant RRP measures planned as of 2022.SDG 8Take steps to increase labour market participation, including by improving access to childcare and long-term care, and remove remaining obstacles to more permanent types of employment. Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, and 2026.SDG 3, 4, 5, 8Foster quality education and skills relevant to the labour market, especially through adult learning.Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025, and 2026.SDG 42019 CSR 3Limited progressStrengthen the innovative capacity of the economy, including by supporting research institutions and their closer collaboration with business. Some progressRelevant RRP measures planned as of 2022, and 2025.SDG 9Focus investment-related economic policy on innovationLimited progressRelevant RRP measures planned as of 2022, 2024, 2025 and 2026.SDG 9, 10, 11[Focus investment-related economic policy on] transport, notably on its sustainabilityLimited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 10, 11[Focus investment-related economic policy on] digital [infrastructure]Substantial progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 9, 10, 11[Focus investment-related economic policy on] energy infrastructureSome progressRelevant RRP measures planned as of 2024, 2025 and 2026.SDG 7, 9, 10, 11, 13[Focus investment-related economic policy on] healthcareLimited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 3, 10, 11[Focus investment-related economic policy on] cleaner energy, taking into account regional disparitiesLimited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 7, 9, 10, 11, 13Improve the regulatory environment, in particular by strengthening the role of consultations of social partners and public consultations in the legislative process.No progressRelevant RRP measures planned as of 2022, and 2023.SDG 162020 CSR 1Limited progressTake all necessary measures, in line with the general escape clause of the Stability and Growth Pact, to effectively address the COVID-19 pandemic, sustain the economy and support the ensuing recovery. When economic conditions allow, pursue fiscal policies aimed at achieving prudent medium-term fiscal positions and ensuring debt sustainability, while enhancing investment. Not relevant anymoreNot applicableSDG 8, 16Improveresilience,accessibilityandeffectivenessofthehealthsystem,includingbyprovidingsufficientresources and accelerating the deployment of e-health services. Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 32020 CSR 2Limited progressMitigatetheemploymentimpactofthecrisis,inparticularbyenhancingflexibleandshorttimeworkingarrangements. Some progressRelevant RRP measures planned as of 2023.SDG 8Better target social benefits and ensure access to those in need.No progressSDG 1, 2, 10Improve digital skills. Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 4Further promote the digital transformation of companies and public administration. Some progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 9, 162020 CSR 3Limited progressContinue efforts to secure access to finance and liquidity for companies. Full implementationSDG 8, 9Front-load mature public investment projectsSome progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 8, 16and promote private investment to foster the economic recovery. Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 8, 9Focus investment on the green and digital transition, in particular on digital infrastructure, Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 9, 10, 11clean and efficient production and use of energy, Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 7, 9, 10, 11, 13and sustainable transport, Limited progressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 10, 11contributing to a progressive decarbonisation of the economy, including in the coal regions.Limited progressRelevant RRP measures planned as of 2022, and 2023.SDG 6, 10, 11, 12, 152020 CSR 4No progressEnhance the investment climate, in particular by safeguarding judicial independence. No progressRelevant RRP measures planned as of 2022 and 2023.SDG 16Ensure effective public consultations and involvement of social partners in the policymaking process.No progressRelevant RRP measures planned as of 2022, and 2023.SDG 162021 CSR 1Some progressIn2022,pursueasupportivefiscalstance,includingtheimpulseprovidedbytheRecoveryandResilience Facility, and preserve nationally financed investment.Full implementationNot applicableSDG 8, 16Wheneconomicconditionsallow,pursueafiscalpolicyaimedatachievingprudentmedium-termfiscalpositions and ensuring fiscal sustainability in the medium term.Some progressNot applicableSDG 8, 16Atthesametime,enhanceinvestmenttoboostgrowthpotential.Payparticularattentiontothecompositionofpublicfinances,onboththerevenueandexpendituresidesofthebudget,andtothequalityofbudgetarymeasuresinordertoensureasustainableandinclusiverecovery.Prioritisesustainableandgrowth-enhancinginvestment,inparticularinvestmentsupportingthegreenanddigitaltransition.Substantial progressNot applicableSDG 8, 16Giveprioritytofiscalstructuralreformsthatwillhelpprovidefinancingforpublicpolicyprioritiesandcontributetothelong-termsustainabilityofpublicfinances,including,whererelevant,bystrengtheningthe coverage, adequacy and sustainability of health and social protection systems for all.No progressNot applicableSDG 8, 16 
 
 
 
  
 
Table (continued) 

Note:            
* See footnote (40). 
** RRP measures included in this table contribute to the implementation of CSRs. Nevertheless, additional measures outside the 
RRP are necessary to fully implement CSRs and address their underlying challenges. Measures indicated as 'being implemented' 
are only those included in the RRF payment requests submitted and positively assessed by the European Commission.  
Source: European Commission 

26 

2022 CSR 1Limited progressIn 2023, ensure that the growth of nationally financed primary current expenditure is in line with an overall neutral policy stance, taking into account continued temporary and targeted support to households and firms most vulnerable to energy price hikes and to people fleeing Ukraine. Stand ready to adjust current spending to the evolving situation.No progressNot applicableSDG 8, 16Expand public investment for the green and digital transitions, and for energy security taking into account the REPowerEU initiative, including by making use of the Recovery and Resilience Facility and other Union funds.Limited progressNot applicableSDG 8, 16For the period beyond 2023, pursue a fiscal policy aimed at achieving prudent medium-term fiscal positions.Some progressNot applicableSDG 8, 16Improve the efficiency of public spending, including by continuing the reform of the budget system.Some progressRelevant RRP measures planned as of 2021, 2022, and 2025.SDG 8, 16Ensure the adequacy of future pension benefits and the sustainability of the pension system by taking measures to increase the effective retirement age and by reforming the preferential pension schemes.Limited progressRelevant RRP measures planned as of 2022.SDG 82022 CSR 2Swiftly finalise the negotiations with the Commission of the 2021-2027 cohesion policy programming documents with a view to starting their implementation.2022 CSR 3Limited progressIncrease labour market participation, including by improving access to childcare and longterm care, and remove remaining obstacles to more permanent types of employment.Limited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, and 2026.SDG 3, 4, 5, 8Foster quality education and skills relevant to the labour market, especially through adult learning and improving digital skills.Limited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 4Better target social benefits and ensure access to those in need.No ProgressSDG 1, 2, 102022 CSR 4Limited progressImprove the resilience, accessibility and effectiveness of the health system, including by providing sufficient resources to reverse the pyramid of care and accelerating the deployment of e-health services.Limited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 3Strengthen the innovative capacity of the economy, including by supporting research institutions and their closer collaboration with business.Some ProgressRelevant RRP measures planned as of 2022, 2024, 2025 and 2026.SDG 9Enhancefurtherdigitalisationofbusinessesandpublicadministration,includingthroughdevelopmentof infrastructure.Some ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 9, 162022 CSR 5Limited progressEnhance the investment climate, in particular by safeguarding judicial independence.Limited ProgressRelevant RRP measures planned as of 2022 and 2023.SDG 16Ensure effective public consultations and involvement of social partners in the policymaking process.No ProgressRelevant RRP measures planned as of 2022, and 2023.SDG 162022 CSR 6Limited progressReduce overall reliance on fossil fuelsLimited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 7, 9, 13by removing regulatory, administrative and infrastructural barriers to accelerate permitting procedures and deployment of renewable energy sources.Limited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 7, 8, 9, 13Reformbuildingrenovationpoliciesandsupportschemestoincentivisedeeperenergyefficiency,promoteenergysavingsandfasterphase-outoffossilfuelsinheatingandaccelerateddeploymentofheat pumps.Some ProgressRelevant RRP measures planned as of 2022, 2023, and 2026.SDG 7Accelerate modal shift towards public transport and active mobility and promote faster uptake of electric vehicles with incentives and investment in charging infrastructure.Limited ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 11Improve long- and medium-term strategic planning of the green transition by updating national energy policies in line with the European Green Deal objectives and the REPowerEU Communication to provide certainty to the business community and use funding effectively with a view to accelerating clean energy investments.No ProgressRelevant RRP measures planned as of 2022, 2023, 2024, 2025 and 2026.SDG 7, 9, 11, 13Progress on the cohesion policy programming documents is monitored under the EU cohesion policy. 
 
 
 
  
 
ANNEX 3: RECOVERY AND RESILIENCE PLAN - OVERVIEW 

Since  the  entry 
into  force  of  the  RRF 
Regulation  and  the  assessment  of  the 
national  recovery  and  resilience  plans, 
geopolitical  and  economic  developments 
have caused major disruptions across the EU. 
In  order  to  effectively  address  these  disruptions, 
the  (adjusted)  RRF  Regulation  allows  Member 
States to amend their recovery and resilience plan 
for  a  variety  of  reasons.  In  line  with  article  11(2) 
of the RRF, the maximum financial contribution for 
Poland was moreover updated on 30 June 2022 to 
an amount of EUR 22.5 billion in grants.  

Poland’s progress in implementing its plan is 
published 
in  the  Recovery  and  Resilience 
Scoreboard.  The  Scoreboard  also  gives  an 
overview  of  the  progress  made  in  implementing 
the RRF as a whole, in a transparent manner.  

No  disbursements  have  yet  been  made  to 
Poland.  Due  to  the  late  submission  of  the  RRP, 
Poland  was  not  eligible 
for  pre-financing. 
Disbursement  of  the  allocation  for  Poland  will 
depend on the progress in implementing the plan. 

Table A3.1: Key elements of Poland's RRP 

Source: RRF Scoreboard 

The  Recovery  and  Resilience  Facility  (RRF)  is 
the centrepiece of the EU’s efforts to help it 
recover  from  the  COVID-19  pandemic,  speed 
up  the  twin  transition  and  strengthen 
resilience  against  future  shocks.  The  RRF 
also  contributes  to  implementation  of  the 
SDGs  and  helps  to  address  the  Country 
Specific  Recommendations  (see  Annex 2). 
Poland  submitted 
recovery  and 
resilience  plan 
(RRP)  on  3  May  2021.  The 
Commission’s positive assessment on 1 June 2022 
and Council’s approval on 17 June 2022 paved the 
way  for  disbursing  EUR  23.9  billion  in  grants  and 
EUR  11.5  in  loans  under  the  RRF  over  the  2022-
2026 period.   

its  current 

Graph A3.1: Share of RRF funds contribution to each policy pillar 

Note: Each measure contributes towards two policy areas of the six pillars, therefore the total contribution to all pillars displayed 
on this chart amounts to 200% of the estimated cost of the RRP. The bottom part represents the amount of the primary pillar, the 
top part the amount of the secondary pillar. 
Source: RRF Scoreboard 

27 

Current RRPScope Initial planCID adoption date (date of submission)17 June 2022Total allocation EUR 23.9 billion in grants (6.2% of 2021 GDP) and EUR 11,5 billion in loansInvestments and reforms 53 investments and 49 reforms Total number of milestones and targets2230%10%20%30%40%50%60%70%80%Green transitionDigitaltransformationSmart,sustainable andinclusive growthSocial andterritorialcohesionHealth, andeconomic, socialand institutionalresiliencePolicies for thenext generation 
 
 
   
 
   
 
ANNEX 4: OTHER EU INSTRUMENTS FOR RECOVERY AND GROWTH 

The  EU  budget  of  over  EUR  1.2  trillion  for 
2021-2027  is  geared  towards  implementing 
the  EU’s  main  priorities.  Cohesion  policy 
investment amounts to EUR 392 billion across the 
EU and represents almost a third of the overall EU 
budget, including around EUR 48 billion invested in 
line with REPowerEU objectives. 

Graph A4.1: Cohesion policy funds 2021-2027 in 
Poland: budget by fund 

(1) million EUR in current prices, % of total; (total amount 
including EU and national co-financing) 
Source: European Commission, Cohesion Open Data 

to  produce 

In  2021-2027,  in  Poland,  cohesion  policy 
funds (41) will invest EUR 48.7 billion in the green 
transition  and  EUR  3.8  billion  in  the  digital 
transformation  as  part  of  the  country’s  total 
allocation  of  EUR  92  billion.  In  particular,  the 
European  Regional  Development  Fund  (ERDF) will 
support the energy transition, a strategic priority in 
Poland in 2021-2027. It will increase by 601 MW 
the  capacity 
renewable  energy. 
Together  with  the  Cohesion  Fund  (CF),  it  will 
improve the energy performance of over 259 470 
dwellings. The ERDF will also invest in sustainable 
transport  by  supporting  840  km  of  railway  lines 
and an additional  1 685 km of cycling roads. The 
ERDF  will  support  equal  access  to 
internet, 
providing  access  to  ultra-fast  broadband  to  more 
than 880 000 households and businesses. Due to 
a  significant  increase  in  repayable  forms  of 
support, particularly in the energy sector, financial 
instruments should be used strategically. The Just 
Transition  Fund 
(JTF)  will  help  workers  and 
businesses  in  five  (post)  coal-mining  regions  to 
find new jobs and activities. In Silesia, the largest 
EU  coal  region,  the  JTF  will  support  1 940 
businesses, create 27 000 new jobs, and generate 

(41)  European Regional Development Fund (ERDF), Cohesion Fund 
(CF), European Social Fund+ (ESF+), Just Transition Fund 
(JTF), excluding Interreg programmes. The total amount 
includes national and EU contributions. Data source: 
Cohesion Open Data.  

EUR 874 million in additional private investment. It 
will  also  help to  improve  the  energy  performance 
of  21 380  dwellings  in  Lower  Silesia.  Under  the 
European Social Fund Plus (ESF+), Poland allocates 
EUR 2.8 billion to education and EUR 1.3 billon to 
lifelong learning and skills. It will strengthen green 
and  digital  skills  by  aligning  vocational  education 
and training (VET) with labour market demand and 
supporting  upskilling  in  the  green  and  digital 
economy,  with  a  focus  on  women  and  vulnerable 
groups.  EUR  900  million  is  allocated  to  measures 
to achieve gender balance in the labour market. 

Of  the  investments  mentioned  above,  EUR 
12.7  billion  will  be  invested  in  line  with 
REPowerEU objectives. This is on top of the EUR 
6.7  billion  dedicated  to  REPowerEU  under  the 
2014-2020  budget.  EUR  8  billion  (2021-2027) 
and  EUR  3.2  billion  (2014-2020)  is  for  improving 
energy efficiency; EUR 2.1 billion (2021-2027) and 
EUR  3.5  million  (2014-2020)  is  for  renewable 
energy  and  low-carbon  R&I;  and  EUR  2.6  billion 
(2021-2027) is for smart energy systems. 

Graph A4.2: Synergies between cohesion policy 
funds and RRF six pillars in Poland 

(1) million EUR in current prices (total amount, including EU 
and national co-financing)   
Source: European Commission  

In  2014-2020  cohesion  policy  funds  made 
EUR  78.8  billion  available  to  Poland (42),  with 
an  absorption  of  91% (43). 
Including  national 
financing,  the  total  investment  amounts  to  EUR 
92.6 billion - around 0.1% of GDP for 2014-2020. 

(42)  Cohesion policy funds include the ERDF, CF, ESF and the 
Youth Employment Initiative (YEI). ETC programmes are 
excluded here. According to the ‘N+3 rule’, the funds 
committed for 2014-2020 must be spent by 2023. REACT-
EU is included in all figures. Total amount including EU and 
national co-financing. Data source: Cohesion Open Data. 

(43)  2014-2020 Cohesion policy EU payments by MS is updated 

daily on Cohesion Open Data.   

28 

13,274 14%58,377 64%15,597 17%4,777 5%CFERDFESF+JTF46,4663,60517,3351,5885,1823,…48,6823,75913,48114,0222,7413,2260100002000030000400005000060000Green transitionDigitaltransformationSmart, sustainableand inclusive growthSocial and territorialcohesionHealth, economic,social andinstitutionalresiliencePolicies for the nextgenerationEU CP 2014-2020 (million EUR)EU CP 2021-2027 (million EUR) 
 
   
                                                 
   
                                                 
 
 
flexibility 

Poland  continues  to  benefit  from  cohesion 
support  economic 
to 
policy 
recovery,  step  up  convergence  and  provide 
vital support to regions following the COVID-
19  pandemic.  The  Recovery  Assistance  for 
Cohesion and the Territories of Europe instrument 
(REACT-EU) (44)  under  NextGenerationEU  provides 
EUR 1.9 billion on top of the 2014-2020 cohesion 
policy  allocation  for  Poland.  On  this,  EUR  304 
million has been allocated to the ‘digital commune’ 
project  on digital  maturity, 
resistance  and 
cybersecurity in the 2 437 local governments most 
the  COVID-19.  REACT-EU  also 
affected  by 
supported  2 000  primary  healthcare  centres.  In 
addition, Cohesion’s Action for Refugees in Europe 
(CARE) supports Poland and its regions in providing 
emergency  assistance  to  people  fleeing  from 
Russia’s invasion of Ukraine, with a total budget of 
EUR  90  million.  With  SAFE  (Supporting  Affordable 
Energy),  the  2014-2020  cohesion  policy  funds 
may  also  be  mobilised  to  support  vulnerable 
households, 
jobs  and  companies  particularly 
affected by high energy prices. 

Graph A4.3: Cohesion policy funds contribution to 
the SDGs in 2014-2020 and 2021-2027 in Poland 

Other  EU  funds  make  significant  resources 
available  for  Poland.  The  common  agricultural 
policy  (CAP)  made  EUR  42.0  billion  available  in 
2014-2022,  and  will  continue  to  support  Poland 
with  EUR  22.1  billion  in  2023-2027.  The  two  CAP 
Funds  (European  Agricultural  Guarantee  Fund  and 
European Agricultural Fund for Rural Development) 
contribute  to  the  European  Green  Deal  while 
ensuring  long-term  food  security.  They  promote 
social,  environmental  and  economic  sustainability 
and  innovation  in  agriculture  and  rural  areas,  in 
coordination  with  other  EU  funds.  The  European 
Maritime  and  Fisheries  Fund  made  EUR  531 
million available to Poland in 2014-2020 and the 
European  Maritime,  Fisheries  and  Aquaculture 
Fund allocates EUR 512 million in 2021-2027. 

Poland  also  benefits 
from  other  EU 
programmes,  notably  the  Connecting  Europe 
Facility,  which  under  CEF  2  (2021-2027)  has  so 
far allocated EU funding of EUR 1.36 billion to 15 
specific  projects  on  strategic  transport  networks. 
Similarly,  Horizon  Europe  has  so  far  allocated 
more than EUR 153 million to Polish R&I actors on 
top  of  the  EUR  746  million  earmarked  under  the 
previous  programme  (Horizon  2020).  The  Public 
Sector  Loan  Facility  set  up  under  the  Just 
Transition  Mechanism  makes  EUR  292  million  of 
grant  support  from  the  Commission  available  for 
projects  in  Poland  for  2021-2027,  which  will  be 
combined  with  loans  from  the  EIB  to  support 
just 
investments  by  public  sector  entities 
transition regions. 

in 

(1) 5 largest contributions to SDGs in million (EUR) current 
prices 
Source: European Commission  

In both 2014-2020 and 2021-2027, cohesion 
policy  funds  have  contributed  substantially 
to 
the  Sustainable  Development  Goals 
(SDGs).  These  funds  support  11  of  the  17  SDGs, 
notably SDG 9 ‘Industry, innovation, infrastructure’ 
and SDG 7 ‘Affordable and clean energy’ (45). 

(44)  REACT-EU allocation on Cohesion Open Data. 

(45)  Other EU funds contribute to the implementation of the 
SDGs, in 2014-2022 this includes both the European 
Agricultural Fund for Rural Development (EARDF) and the 
European Maritime and Fisheries Fund (EMFF). 

for 

risks 

temporary 

unemployment 

support 
in 

Poland  received  support  under  the  European 
to 
instrument 
mitigate 
an 
emergency  (SURE)  to  finance  short-time  work 
schemes,  similar  measures,  and  ancillary  health-
related  measures,  to  mitigate  the  impact  of 
COVID-19. 
financial 
Council 
assistance  to  Poland  of  EUR  11.3  billion  in  loans, 
which supported around 20% of workers and 10% 
of firms in 2020.  

granted 

The 

Poland 

Instrument 
designing 

The  Technical  Support 
(TSI) 
supports 
in 
and 
reforms, 
implementing  growth-enhancing 
including  those  set  out  in  its  recovery  and 
resilience  plan  (RRP).  Poland  has  received 
since  2017, 
significant 
including (46)  support  to  reform  the  budgetary 
process,  develop  digital  competences,  strengthen 

technical 

support 

(46)  Country factsheets on reform support are available here. 

29 

44,9737,42913,8605,5602,98534,62013,01712,2595,8125,40305,00010,00015,00020,00025,00030,00035,00040,00045,00050,000SDG 9 Industry,innovation,infrastructureSDG 7 Affordableand clean energySDG 8 Decentwork andeconomic growthSDG 4 QualityeducationSDG 1 No povertyEU CP 2014-2020 (millions EUR)EU CP 2021-2027 (millions EUR) 
   
                                                 
                                                 
the  competitiveness  of  the  railway  sector  and 
enhance green mobility. 

30 

 
indicators. 

It  has  medium 

RDB 
resilience 
capacities  in  all  four  dimensions  of  the  RDB. 
Poland  shows  stronger  capacities  than  the  EU 
average  in  the  areas  ‘raw  material  and  energy 
supply’ and 'value chains and trade’. There is room 
for improving capacities compared to the EU with 
respect to ‘financial globalisation’, ‘climate change 
mitigation  and  adaptation’,  digitalisation,  ‘security 
and  demography’  and  ‘inequalities  and  social 
impact of the transitions’. 

Table A5.1: Resilience indices summarising the 
situation across RDB dimensions and areas 

(1) Data are for 2021, and EU-27 refers to the value for the 
EU as a whole. Data underlying EU-27 vulnerabilities in the 
area ‘value chains and trade’ are not available as they 
comprise partner concentration measures that are not 
comparable with Member States’ level values. 
Source: JRC Resilience Dashboards - European Commission 

ANNEX 5: RESILIENCE 

This  Annex 
illustrates  Poland’s  relative 
resilience capacities and vulnerabilities using 
the  Commission’s 
resilience  dashboards 
(RDB) (47).  Comprising  a  set  of  124  quantitative 
indicators,  the  RDB  provide  broad  indications  of 
Member  States’  ability  to  make  progress  across 
four interrelated dimensions: social and economic, 
green, digital, and geopolitical. The indicators show 
vulnerabilities (48)  and  capacities (49)  that  can 
become  increasingly  relevant,  both  to  navigate 
ongoing  transitions  and  to  cope  with  potential 
future shocks. To this end, the RDB help to identify 
areas  that  need  further  efforts  to  build  stronger 
and  more  resilient  economies  and  societies.  They 
in  Table  A5.1  as  synthetic 
are  summarised 
resilience 
illustrate  the  overall 
relative  situation  for  each  of  the  four  dimensions 
and their underlying areas for Poland and the EU-
27 (50). 

indices,  which 

According  to  the  set  of  resilience  indicators 
under  the  RDB,  Poland  generally  displays  a 
similar  level  of  vulnerabilities  compared  to 
the  EU  average.  Poland  shows  medium-high 
vulnerabilities in the digital dimension of the RDB, 
medium vulnerabilities in the social and economic 
and  the  green  dimensions,  and  medium-low 
vulnerabilities in the geopolitical dimension. It has 
higher  vulnerabilities  than  the  EU  average  in  the 
areas 
resources’  and 
'digitalisation  for 
industry  and  public  space'. 
Poland has relatively low vulnerabilities in relation 
to 
supply’, 
‘cybersecurity’,  'inequalities  and  social  impact  of 
the  transitions’,  ‘security  and  demography’,  and 
and 
financial 
‘economic 
sustainability’. 

‘sustainable  use  of 

‘raw  material 

stability 

energy 

and 

and 

Compared  to  the  EU  average,  Poland  shows 
an overall lower level of capacities across all 

(47)  For details see https://ec.europa.eu/info/strategy/strategic-
planning/strategic-foresight/2020-strategic-foresight-
report/resilience-dashboards_en; see also 2020 Strategic 
Foresight Report (COM(2020) 493). 

(48)  Vulnerabilities describe features that can exacerbate the 

negative impact of crises and transitions, or obstacles that 
may hinder the achievement of long-term strategic goals. 

(49)  Capacities refer to enablers or abilities to cope with crises 
and structural changes and to manage the transitions.  

(50)  This Annex is linked to Annex 1 on SDGs, Annex 6 on the 
green deal, Annex 8 on the fair transition to climate 
neutrality, Annex 9 on resource productivity, efficiency and 
circularity, Annex 10 on the digital transition and Annex 14 
on the European pillar of social rights. 

31 

PLEU-27PLEU-27Vulnerabilities IndexHighMedium-highMediumMedium-lowLowNot availableCapacities IndexHighMedium-highMediumMedium-lowLowNot availableDimension/AreaVulnerabilitiesCapacitiesSocial and economicHealth, education and workInequalities and social impact of the transitionsGreenEconomic & financial stability and sustainabilitySustainable use of resourcesClimate change mitigation & adaptationDigitalEcosystems, biodiversity, sustainable agricultureDigital for industryDigital for personal spaceCybersecurityDigital for public spaceRaw material and energy supplyGeopoliticalValue chains and tradeFinancial globalisationSecurity and demography 
 
                                                 
 
  
 
 
 
ENVIRONMENTAL SUSTAINABILITY 
ANNEX 6: EUROPEAN GREEN DEAL 

on 

several 

aspects 

Poland’s  green  transition  requires  continued 
action 
including 
advancing  the  deployment  of  renewables, 
improving  energy  efficiency,  and  reducing 
emissions from road transport. Implementation 
of the European Green Deal is underway in Poland; 
this  Annex  provides  offers  a  snapshot  of  the  key 
areas involved (51). 

Poland  has  not  yet  defined  all  the  climate 
policy  measures  it  needs  to  reach  its  2030 
climate 
target  for  the  effort  sharing 
sectors (52).  Data  for  2021  on  greenhouse  gas 
emissions  in  these  sectors  are  expected  to  show 
the country generated slightly less than its annual 
emission allocations (53). Current policies in Poland 
are  projected  to  keep  the  increase  of  these 
emissions contained at 6% relative to 2005 levels 
in 2030. This is too high to comply with the effort 
sharing  target  even  before  the  target  was  made 
more  ambitious  to  meet  the  EU’s  55%  objective. 
The  additional  measures  tabled  would  reduce  the 
greenhouse  gas  emissions  of  these  sectors  by 
12%, meeting the present target but not reaching 
the  new  target  to  reduce  by  17.7% (54).  In  its 
recovery  and  resilience  plan  (RRP),  Poland  has 

(51)  The overview in this Annex is complemented by the 

information in Annex 7 on energy security and affordability, 
Annex 8 on the fair transition to climate neutrality and 
environmental sustainability, Annex 9 on resource 
productivity, efficiency and circularity, Annex 11 on 
innovation, and Annex 19 on taxation. 

(52)  Member States’ greenhouse gas emission targets for 2030 
(‘effort sharing targets’) were increased by Regulation (EU) 
2023/857 (the Effort Sharing Regulation) amending 
Regulation (EU) 2018/842, aligning the action in the 
concerned sectors with the objective to reach EU-level, 
economy-wide greenhouse gas emission reductions of at 
least 55% relative to 1990 levels. The Regulation sets 
national targets for sectors outside the current EU Emissions 
Trading System, notably: buildings (heating and cooling), road 
transport, agriculture, waste, and small industry. Emissions 
covered by the EU ETS and the Effort Sharing Regulation are 
complemented by net removals in the land use sector, 
regulated by Regulation (EU) 2018/841 (the Land Use, Land 
Use Change and Forestry (LULUCF) Regulation) amended by 
Regulation (EU) 2023/839. 

(53)  Poland's annual emission allocations for 2021 were some 

210.4 Mt CO2eq, and its approximated 2021 emissions were 
at 209.7 Mt (see European Commission, Accelerating the 
transition to climate neutrality for Europe’s security and 
prosperity: EU Climate Action Progress Report 2022, 
SWD(2022)343). 

(54)  See the information on the distance to the 2030 climate 

policy target in Table A6.1. Existing and additional measures 
as of 15 March 2021. 

attributed  42.7 %  of  its  Recovery  and  Resilience 
Facility allocation to key reforms and investments 
to  attain  climate  objectives (55).  According  to  its 
national  energy  strategy,  Poland  aims  to  reduce 
economy-wide greenhouse gas emissions by 30 % 
by 2030 compared to 1990 (56).  

Graph A6.1: Thematic – greenhouse gas emissions 
from the effort sharing sectors in Mt CO2eq, 
2005-2021 

Source: European Environmental Agency. 

Poland is not on track to meet its net carbon 
removals  target  for  2030  for  its  land  use 
sector.  Poland’s  net  removals  have  been  in 
decline  mainly  due  to  forest  land  management. 
For 2030, Poland’s land use, land use change and 
forestry (LULUCF) target implies to remove 38 098 
kt CO2eq,  significantly  higher  than  the  present 
level of net removals (see Table A6.1) (57).  

Poland’s  economy  still  heavily  depends  on 
fossil  fuels,  particularly  coal.  In  2021,  fossil 
fuels provided for almost 90% of Poland’s energy 
mix,  with  coal  alone  accounting  for  42%.  Despite 
positive  progress  on  solar  PV  power  generation, 
renewables  provided  only  13%  of  the  energy  mix 
in  2021.  Poland’s  electricity  mix  also  relies  highly 
on  coal,  which  in  2021  provided  72%  of  total 

(55)  For example, reforms and investments in renewables 

(onshore and offshore wind, photovoltaic energy, energy 
communities) and green hydrogen, decarbonisation of 
heating and thermal modernisation of buildings, greening of 
cities and public transport, and improving water 
management.  

(56)  Under Poland’s national energy strategy with an outlook for 
2040. The target is not included in Poland’s national energy 
and climate plan. An update of the plan, mandated by 
Regulation (EU) 2018/1999 (the Governance Regulation), is 
underway. The national energy strategy is expected to be 
updated together with the plan.  

(57)  This value is indicative and will be updated in 2025 (as 

mandated by Regulation (EU) 2023/839). 

32 

05010015020025020052021Domestic transport (excl. aviation)Buildings (under ESR)AgricultureSmall industryWaste 
 
 
                                                 
   
                                                 
 
 
electricity,  while  18%  came  from  renewable 
sources.  According  to  its  national  energy  and 
climate  Plan  (NECP),  in  2030,  the  share  of 
renewable  energy  in  Poland’s  energy  mix  should 
increase  to  between  21  and  23%  of  gross  final 
energy  consumption.  This  target  was  considered 
unambitious in the Commission 2020 assessment. 
Poland  will  need  to  substantially  strengthen  its 
renewable  energy  target  in  the  updated  NECP  to 
reflect the more ambitious EU climate and energy 
targets  in  the  Fit  for  55  Package  and  in  the 
REPowerEU Plan. 

Graph A6.2: Energy mix (top) and electricity mix 
(bottom), 2021 

The energy mix is based on gross inland consumption, and 
excludes heat and electricity. The share of renewables 
includes biofuels and non-renewable waste.  
Source: Eurostat 

Untapping the potential of renewable energy 
is  crucial  to  decarbonising  Poland’s  energy 
system.  Against  this  backdrop,  a  successful 
implementation  of  Poland’s  RRP  could  have  a 
transformative  impact  and  shift  the  country’s 
low  and  zero-carbon 
energy  mix 
includes  funding  for 
technologies.  The  plan 
offshore  wind  energy  plants  and 
terminal 
infrastructure,  as  well  as  crucial  changes  to  the 
regulatory  environment  aimed  at  speeding  up the 

towards 

and 

renewable 

low-carbon 

construction  of  onshore  wind  energy  plants.  The 
plan  also  envisages  support  for  the  development 
of 
hydrogen 
technologies,  and  local  renewable  energy  sources 
by  energy  communities. 
It  also  envisages 
significant  investments  in  the  development  of 
transmission  and  distribution  networks  and  of 
smart  electricity  infrastructure,  to  further  enable 
renewables  to  be  integrated  into  the  energy  mix. 
Poland  has  also  started  studies  and  investments 
to  achieve  mid-term  goals  in  the  field  of  civilian 
nuclear  power  and  as  regards  small  modular 
reactors to decarbonise its energy consumption. 

Reducing  energy  consumption  by  improving 
energy efficiency across Poland’s economy is 
indispensable  to  decreasing  the  country’s 
dependency  on  fossil  fuels  and  carrying  out 
the  energy  transition  in  a  cost-effective 
manner.  Poland’s  NECP  targets  for  primary  and 
final  energy  consumption  (PEC  and  FEC)  were 
considered of modest ambition in the Commission 
2020  assessment.  Final  energy  consumption  in 
Poland was 75.2 Mtoe in  2021, mainly increasing 
throughout the last 10 years, except in 2020, due 
to the exceptional COVID-19 measures, which was 
followed  by  a  rebound  in  2021,  equal  to  a  5.6% 
increase.  Based  on  the  energy  consumption 
trajectory  for  2018-2021,  Poland  is  not  expected 
to be on track to meet its 2030 target for PEC and 
FEC, as these were notified in its NECP (58).  

investments 

The  energy  component  of  Poland’s  RRP 
strongly  focuses  on  energy  efficiency. 
It 
includes measures to optimise i) support to energy 
in  private  and  public 
efficiency 
buildings,  ii) changes  in  the  heating  sources,  iii) 
reforms  to  reduce  the  energy  consumption  of 
companies  as  well  as  iv) updates  to  the  clean  air 
priority  programme,  Poland’s  main  vehicle  for  the 
reducing emissions in buildings, which encourages 
complementing  the  replacement  of  coal  boilers 
with  energy  efficiency  measures 
(thermo-
envisages 
The 
modernisation). 
investment to modernise district  heating systems, 
which  focuses  on  replacing  heat  sources.  This 
investment  is  to  be  complemented  by  funding 
from  the  regional  programmes  that  will  focus  on 
network refurbishment. 

plan 

also 

(58)  After the conclusion of the negotiations for a recast EED, the 
ambition of both the EU and national targets as well as of 
the national measures for energy efficiency to meet these 
targets is expected to increase 

33 

72%9%1%18%Coal and coal productsNatural gasOil and oil productsRenewables42%16%29%13%Solid fossil fuels, peatand oil shaleGasOilRenewables 
     
                                                 
In Poland, a shift to sustainable mobility still 
lies  ahead,  especially  in  road  passenger 
transport.  The  market  development  for  zero-
emission  passenger  cars  is  lagging  behind  the 
overall  trend  in  the  EU.  The  electrification  of  the 
railway  network,  however,  is  more  advanced  than 
in the EU on average. At the same time, individual 
transport  exacerbates  problems  with  air  pollution 
and traffic  congestion, with significant health and 
economic  costs  in  Poland’s  cities.  Poland  has  the 
potential  to  rely  more  on  environmental  taxes  to 
further  internalise  the  cost  of  air  pollution,  in  line 
with  the  polluter  pays  principle (59).  As  transport 
taxes represented only 0.18% of GDP (EU average 
of  0.42%)  in  2020,  Poland  would  have  scope  to 
introduce a circulation tax, with a tax base related 
to  emissions,  on  passenger  car  taxes  (see  Annex 
19). 

and  2020, 

Poland would benefit from investing more in 
environmental  protection  and  in  measures 
protecting  biodiversity  and  ecosystems (60). 
Between  2014 
environmental 
investment  needs  were  estimated  to  be  at  least 
EUR  15.7  billion  while  yearly  investment  was  at 
just under EUR 7 billion, with a gap of at least EUR 
8.7  billion,  per  year  (see  Graph  A6.3) (61).  Poland 
still  needs  to  allocate  sufficient  resources  to 
protecting  and  managing 
the  Natura  2000 
network (62).  Investment  is  also  urgently  needed 
for preventing and controlling pollution, where the 
gap  has  been  estimated  at  more  than  EUR  4.1 
billion per year between 2014 and 2020 (1.3% of 
GDP).  These  investments  would  help  diminish  the 
health  costs  of  air  pollution  (1 095  years  of  life 
lost  for  100 000  inhabitants  due  to  PM2.5  in 
2020,  the  third  highest  number  in  the  EU)  and 
support the country’s resilience. 

(59)  European Commission, 2021, Green taxation and other 

economic instruments – Internalising environmental costs to 
make the polluter pay, Ensuring that polluters pay 
(europa.eu). 

(60)  Environmental objectives include pollution prevention and 

control, water management and industries, circular economy 
and waste, biodiversity and ecosystems (European 
Commission, 2022, Environmental Implementation Review, 
country report Poland). 

(61)  When also accounting for needs estimated at EU level only 

Graph A6.3: Thematic – environmental investment 
needs and current investment, p.a. 2014-2020 

Source: European Commission. 

the  growing 

Climate change is affecting many key sectors 
in  Poland (63).  Agriculture  and  forestry,  energy, 
the  built  environment,  transport,  health,  and 
tourism are all under pressure, as the frequencies 
intensities  of  extreme  weather  events 
and 
(droughts,  storms,  floods,  and  heatwaves)  are 
rising (64).  Longer  droughts  and  heavy  rainfall 
disturb 
season  and  depress 
agricultural  yields.  Heat-related  mortality  and 
morbidity  linked  to  pollution  and  allergens  are 
rising.  In  both  urban  and  rural  areas,  spatial 
planning  needs  to  anticipate  the  impacts  of 
climate  change.  Further  action  also  requires 
boosting 
the  penetration  and  coverage  of 
insurance  against  environmental  perils.  Poland’s 
RRP  includes  measures  on  sustainable  water 
management  and  pollution  management  in  the 
Baltic Sea as well as others on greening the built 
environment in cities. A revision of the plan offers 
an  opportunity  to  scale  up  action  in  climate 
adaptation. 
climate 
entails 
adaptation  considerations  into  sectoral  policies, 
e.g.  concerning  increasingly  scarce  water  supplies 
for  the  cooling  of  conventional  energy  plants, 
agricultural production, and drinking water. Poland 
needs to prioritise sustainable water management 
by  restoring  terrestrial,  marine,  and  freshwater 
ecosystems.  

factoring 

This 

(e.g. water protection, higher circularity, biodiversity strategy). 

(63)  European Environmental Agency, Advancing towards climate 

(62)  In 2021, Poland had 39.6% terrestrial protected areas 

resilience in Europe, forthcoming. 

(Natura 2000 and nationally designated areas), against the 
EU average of 26.4% (European Environment Agency, 2023, 
Natura 2000 Barometer). 

(64)  According to the 6th IPCC climate adaptation report, in 

southern Europe, more than a third of the population will be 
exposed to water scarcity at 2°C.  

34 

1.8822.3131.1731.0575376.0193.4051.9633.6865960,01000,02000,03000,04000,05000,06000,07000,0Pollutionprevention andcontrolWater (industries,excl. protection)Circular economy(incl. waste)Biodiversity andecosystemsR&I&D and otherEUR million (at current prices)Current investmentTotal need 
                                                 
      
                                                 
a 

at 

alternatives 

Poland  provides  fossil  fuel  and  other 
environmentally harmful subsidies that could 
be  considered  for  reform,  while  ensuring 
food  and  energy  security  and  mitigating 
social effects. Poland’s fossil fuel subsidies have 
been on the rise, especially for coal (0.20% of GDP 
in 2020) and petroleum products (0.08% of GDP). 
Poland allocates more to fossil fuel subsidies than 
to  renewable  energy  subsidies.  This  puts  low 
carbon 
disadvantage. 
Environmentally  harmful  subsidies  have  been 
identified,  via  an 
in  the 
agriculture,  forestry  and  fishing,  electricity,  gas, 
steam  and  air  conditioning,  transportation  and 
storage,  mining  and  quarrying  and  services 
sectors.  Examples  of  such  subsidies  include  the 
flat  rate taxation of privately used company cars, 
the reduced VAT rate for fertilisers and pesticides, 
the  excise  tax  refund  for  diesel  fuel  used  in 
agriculture, the excise tax exemption on the use of 
natural  gas  or  the  reduced  CO2  tax  rate  on  diesel 
in  agriculture (65).  A  mapping  of  all 
used 
environmentally  harmful  subsidies  by  Poland 
would help prioritise candidates for reform. 

initial  assessment, 

By  earmarking  a  higher  share  of  the  EU 
Emissions  Trading  System  (ETS)  revenue  for 
its 
climate  action,  Poland  could  reduce 
exposure to the cost of carbon. Poland collects 
some  of  the  highest  revenues  from  the  EU  ETS 
both  overall  and  per  capita (66).  However,  on 
average  it  allocated  just  50%  to  climate  and 
energy-related  purposes,  the  minimum  as  set  out 
in the ETS Directive.  

(65)  Fossil fuel figures in EUR of 2021 from the 2022 State of 

the Energy Union report. Initial assessment of 
environmentally harmful subsidies done by the Commission 
in the 2022 toolbox for reforming environmentally harmful 
subsidies in Europe, using OECD definitions, and based on the 
following datasets: OECD Agriculture Policy Monitoring and 
Evaluations; OECD Policy Instruments for the Environment 
(PINE) Database; OECD Statistical Database for Fossil Fuels 
Support; IMF country-level energy subsidy estimates. Annex 4 
of the toolbox contains detailed examples of subsidies on 
the candidates for reform. 

(66)  With ETS revenue increasing due to higher carbon prices, in 

2021, Poland’s revenue from the EU ETS amounted to some 
EUR 5.6 billion. 

35 

 
                                                 
Table A6.1: Indicators tracking progress on the European Green Deal from a macroeconomic perspective 

Sources: (1) Historical and projected emissions, as well as Member States’ climate policy targets and 2005 base year emissions 
under the Effort Sharing Decision (for 2020) are measured in global warming potential (GWP) values from the 4th Assessment 
Report (AR4) of the Intergovernmental Panel on Climate Change (IPCC). Member States’ climate policy targets and 2005 base 
year emissions under the Effort Sharing Regulation (for 2030) are in GWP values from the 5th Assessment Report (AR5). The 
table above shows the base year emissions 2005 under the Effort Sharing Decision, using AR4 GWP values. Emissions for 2017-
2021 are expressed in percentage change from 2005 base year emissions, with AR4 GWP values. 2021 data are preliminary. The 
table shows the 2030 target under Regulation (EU) 2023/857 that aligns it with the EU’s 55% objective, in percentage change 
from 2005 base year emissions (AR5 GWP). Distance to target is the gap between Member States’ 2030 target (with AR5 GWP 
values) and projected emissions with existing measures (WEM) and with additional measures (WAM) (with AR4 GWP values), in 
percentage change from the 2005 base year emissions. Due to the difference in global warming potential values, the distance to 
target is only illustrative. The measures included reflect the state of play as of 15 March 2021.  
(2) Net removals are expressed in negative figures, net emissions in positive figures. Reported data are from the 2023 
greenhouse gas inventory submission. 2030 value of net greenhouse gas removals as in Regulation (EU) 2023/839 
amending Regulation (EU) 2018/841 (LULUCF Regulation) – Annex IIa, kilotons of CO2 equivalent, based on 2020 submissions. 
(3) Renewable energy and energy efficiency targets and national contributions are in line with the methodology established under 
Regulation (EU) 2018/1999 (Governance Regulation).  
(4) Percentage of total revenue from taxes and social contributions (excluding imputed social contributions). Revenue from the EU 
Emissions Trading System is included in environmental tax revenue.  
(5) Expenditure on gross fixed capital formation for the production of environmental protection services (abatement and 
prevention of pollution) covering government, industry, and specialised providers.  
(6) European Commission, Study on energy subsidies and other government interventions in the European Union, 2022 edition.  
(7) The climate protection gap refers to the share of non-insured economic losses caused by climate-related disasters. This 
indicator is based on modelling of the current risk from floods, wildfires and windstorms as well as earthquakes, and an 
estimation of the current insurance penetration rate. The indicator does not provide information on the split between the 
private/public costs of climate-related disasters. A score of 0 means no protection gap, while a score of 4 corresponds to a very 
high gap (EIOPA, 2022).  
(8) Sulphur oxides (SO2 equivalent), ammonia, particulates < 10 µm, nitrogen oxides in total economy (divided by GDP).  
(9) Battery electric vehicles (BEV) and fuel cell electric vehicles (FCEV). 

36 

2030200520172018201920202021target/valueWEMWAMGreenhouse gas emission reductions in effort sharing sectors (1)Mt CO2eq; %; pp180,018%18%16%14%--17,7%-23,7-5,7Net carbon removals from LULUCF (2)kt CO2eq-48.019-37.389-36.748-18.295-18.958-20.095-38098n/an/a200520172018201920202021Share of energy from renewable sources in gross final consumption of energy (3)%7%11%15%15%16%16%21-23%Energy efficiency: primary energy consumption (3)Mtoe88,099,1104,1100,296,8103,991,3Energy efficiency: final energy consumption (3)Mtoe58,570,974,973,771,175,267,1201620172018201920202021201920202021Environmental taxes (% of GDP)% of GDP2,72,72,72,52,52,92,42,22,2Environmental taxes (% of total taxation) (4)% of taxation 8,17,97,77,27,17,85,95,65,5Government expenditure on environmental protection% of total exp.1,00,91,21,31,21,31,71,61,6Investment in environmental protection (5) % of GDP0,30,30,50,5--0,40,40,4Fossil fuel subsidies (6)EUR2021bn2,12,72,11,41,9-53,050,0-Climate protection gap (7) score 1-41,61,51,5Net greenhouse gas emissions1990 = 10084,088,087,083,084,084,076,069,072,0Greenhouse gas emission intensity of the economykg/EUR'100,960,950,900,820,80-0,310,300,26Energy intensity of the economykgoe/EUR'100,230,230,230,210,21-0,110,11-Final energy consumption (FEC)2015=100106,9113,8120,2118,4114,2120,6102,994,6-FEC in residential building sector2015=100104,5105,4118,5110,3110,9116,3101,3101,3106,8FEC in services building sector2015=100108,4102,6101,199,696,7108,3100,194,4100,7Smog-precursor emission intensity (to GDP) (8)tonne/EUR'102,72,72,42,42,1-0,90,9-Years of life lost due to air pollution by PM2.5per 100.000 inh.1440,91494,81536,61191,51095,4-581,6544,5-Years of life lost due to air pollution by NO2per 100.000 inh.139,4135,0151,1120,8101,5-309,6218,8-Nitrates in ground watermg NO3/litre------21,020,8-Land protected areas% of total38,339,8-39,639,639,626,226,426,4Marine protected areas% of total21,8--21,8-21,910,7-12,1Organic farming% of total utilised agricultural area3,73,43,33,53,5-8,59,1-201720182019202020212022202020212022Share of zero-emission vehicles (9)% in new registrations0,10,10,30,81,62,65,48,910,7Number of AC/DC recharging points (AFIR categorisation)---175927673295188626330028432518Share of electrified railways%63,663,764,264,264,264,256,6n/a56,6Hours of congestion per commuting driver per year25,024,425,225,2n/an/a28,7n/an/a'Fit for 55'DistanceProgress to policy targetsNational contribution to 2030 EU targetPolandEUMobilityFiscal and financialindicatorsEnergyPollutionBiodiversityClimate 
 
   
 
ANNEX 7: ENERGY SECURITY AND AFFORDABILITY 

Poland’s  supply  diversification  efforts  in 
recent years have helped mitigate the impact 
of  the  halt  in  Russian  supplies  and  avoid 
major disruptions. Gazprom no longer supplies it 
with natural gas as of 28 April 2022, by unilateral 
decision, following Poland’s refusal to pay for gas 
supplies in roubles. This Annex (67) sets out actions 
carried  out  by  Poland  to  achieve  the  REPowerEU 
objectives,  including  through  the  implementation 
of its recovery and resilience plan (RRP), in order to 
improve  energy  security  and  affordability  while 
accelerating  the  clean  energy  transition,  and 
contributing to enhancing the EU’s competitiveness 
in the clean energy sector (68).  

Since  2014,  Poland  had  already  significantly 
reduced its exposure to Russian  gas through 
strategic  investments  aimed  at  diversifying 
gas  supply  routes.  Its  dependency  on  Russian 
gas has been decreasing in the last decade,  from 
around  76%  in  2014  to  55%  in  2021.  Before 
Russia  invaded  Ukraine,  it  received  the  equivalent 
of  10  billion  cubic  metres  (bcm)/year  of  natural 
gas  from  Gazprom,  around  45%  of  its  domestic 
demand.  The  liquefied  natural  gas  (LNG)  terminal 
in  Świnoujście,  opened  in  2016,  with  a  maximum 
regasification  capacity  of  5  bcm  (54.4  TWh)  per 
year.  Poland  plans  to  expand  this  LNG  terminal, 
already expanded to 6.2 bcm/year in 2022, to 8.3 
bcm/year in 2023. Key infrastructure projects have 
been completed and became operational in 2022, 
including  the  interconnector  with  Lithuania,  the 
Baltic  Pipe,  and  the  interconnector  with  Slovakia. 
These  projects  became  operational  in  November 
2022  and  their  completion  gave  Poland  enough 
import  capacity  to  entirely  replace  lost  imports 
from  Russia.  In  particular,  the  Baltic  Pipe  allows 
transporting  up  to  10  bcm/year  of  gas  from  the 
Norwegian  shelf  through  Denmark  and  the  Baltic 
Sea  to  Poland.  The  interconnector  with  Lithuania 
gives Poland access to the Klaipedia LNG terminal 
in  Lithuania  and  –  thanks  to  bilateral  flows  – 
makes  it  possible  to  adjust  gas  flows  to  the 
shifting  regional  demand-supply  dynamics,  while 
interconnector  with  Slovakia  enables  the 
the 

transmission  of  5.7  bcm  to  Poland.  Additionally, 
Poland  plans  to  open  a  Floating  Storage  and 
Regasification Unit on the Baltic Sea near Gdansk 
in 2026, with an expected capacity of 6bcm of gas 
per year.  

Since  25  February  2023,  Russia  has  stopped 
oil supplies via the Druzhba pipeline, however 
Russia accounted only for about 10% of overall oil 
supplies  and  Poland  is  well  positioned  to  swiftly 
replace RU oil with alternative sources.  

Poland  is  on  track  to  fulfil  its  gas  storage 
obligations. It fulfilled its gas storage obligations 
last winter, reaching 98.91% by 1 November, and 
ended  the  heating  season  with  its  gas  storage 
filled at 50.15% on April 15th 2023 (69).  Its total 
storage capacity (3.73 bcm) is, however, relatively 
small  compared  to  its  annual  consumption  of 
around 20 bcm/year. GSP, the owner and operator 
of  Poland’s  seven  gas  storage  facilities (70),  is 
considering further expanding the total capacity.  

Graph A7.1: Underground gas storage levels in 
Poland 

Source: JRC calculation based on AGSI+ Transparency 
Platform, 2022 (Last update 1 May 2023) 

Poland  has  taken  several  measures  to 
decrease  energy  consumption  and  promote 
energy efficiency. On 15 July, the clean air plus 
programme  was  launched,  giving  up  to  a  90% 
subsidy  to  households  for  thermal  modernisation; 
including 
replacing  outdated  heating  boilers, 

(67)  It is complemented by Annex 6 as the European Green Deal 
focuses on the clean energy transition, by Annex 8 on the 
actions taken to mitigate energy poverty and protect the 
most vulnerable ones, and by Annex 9 as the transition to a 
circular economy will unlock significant energy and resource 
savings, further strengthening energy security and 
affordability. 

(69)  Regulation of the European Parliament and of the Council 
amending Regulations (EU) 2017/1938 and (EC) No 
715/2009 with regard to gas storage and Implementing 
Regulation (EU) 2022/2301 of 23 November 2022 setting 
the filling trajectory with intermediary targets for 2023 for 
each Member State with underground gas storage facilities 
on its territory and directly interconnected to its market area. 

(68)  In line with the Green Deal Industrial Plan COM(2023) 62 
final, and the proposed Net-Zero Industry Act COM(2023) 
161 final. 

(70)  UGS Wierzchowice, VGS GIM Kawerna (Kosakowo, Mogilno) 

and VGS GIM Sanok (Brzeznica, Husow, Strachocina, 
Swarzow). 

37 

 
 
                                                 
 
                                                 
 
 
district  heating  connections.  Moreover,  as  of 
January  3,  the  government  has  increased  the 
funding  for  thermal  modernisation  of  houses  and 
heat  sources  replacement.  Other  measures  to 
promote  energy  savings  include  extending  the 
white certificate scheme to the transport sector; a 
programme  supporting  energy  efficiency 
in 
businesses  using  energy  performance  contracts; 
and developing an energy savings registry.  Recent 
measures  and  high  prices  led  to  a  gas  demand 
reduction  of  about  13%  over  the  period  August 
2022  –  March  2023,  narrowly  missing  the  15% 
target.  The  government  has  also  imposed  a 
mandatory  10%  electricity  consumption  cut  on 
national and local government administrations.  

Natural  gas  plays  a  relatively  small  role  in 
Poland’s  energy  mix,  with  a  share  of  17%. 
Most  of  the  gas  is  consumed  by  industry  (35%), 
followed  by  the  energy  sector  (25.8%)  and  
households (25.8%).  

Graph A7.2: Share of gas consumption per sector, 
2021 

significantly  improve  the  ability  of  Poland  to 
integrate  offshore  energy  into  its  grid.  Under  the 
RRP, Poland has also committed itself to investing 
in  transmission  networks,  including  extensions  to 
link northern with southern parts of the country. It 
plans  to  develop  400  kV  transmission  lines  with 
relevant stations, to develop a data hub and to do 
a power quality analysis of the electricity market.  

its 

reinforcements  of 

internal 
Further 
transmission  and  distribution  grids  are 
needed  to  sustain  the  growth  of  renewable 
Increased  variable,  renewable-based 
capacity. 
generation,  coupled  with  the  expected  growth  in 
electricity  demand  cause  by  the  electrification  of 
the  economy,  will  have  an 
impact  on  both 
distribution  and  transmission  grid  infrastructure. 
Change  in  the  electricity  generation  portfolio  will 
need  to  be  accompanied  by  more  efficient  use, 
smartening  of  and  additional  investments  in  the 
electricity  network.  The  energy  regulator  (URE) 
estimates  that  until  2030  some  100  billion  PLN 
should be invested to adapt the distribution grid to 
variable renewable and distributed energy sources. 
In  addition,  up  to  2032  over  32  billion  PLN  are 
in  modernising  the 
planned  to  be 
the 
transmission 
enabling 
transmission  of  offshore  wind  electricity 
to 
southern Poland, where industry is located. 

invested 

network 

and 

Graph A7.3: Share of gas consumption per 
industrial sector, 2021 (% of industry total gas 
consumption) 

Source: Eurostat 

has 

few 

still 

electricity 
Poland 
interconnections with neighbouring countries. 
The  Polish  allocation  constraint  also  regularly 
limits  cross-border  capacity,  which  is  often  down 
to  zero,  negatively  affecting  Poland’s  price  signal. 
Poland is participating as a constructing country in 
the  project  for  synchronising  the  three  Baltic 
countries  with  the  European  continental  grid.  To 
this  end,  it  is  constructing  three  new  electricity 
lines  and  modernising  another  three 
in  the 
northeast of the country. These will enable the full 
functionality  of  the  Harmony  Link,  the  undersea 
high-voltage cable planned to be constructed with 
Lithuania. With its development delayed due to the 
current geopolitical context, it is now estimated to 
be completed in 2028. These investments will also 

Source: Eurostat 

38 

28.1%35.0%1.7%9.1%25.8%0.3%EnergyIndustryTransportServices and public sectorHouseholdsAgriculture, forestry andfishery0.0%5.0%10.0%15.0%20.0%25.0%30.0%35.0%40.0%45.0%Iron and steelChemical and petrochemicalNon-ferrous metalsNon-metallic mineralsTransport equipmentMachineryMining and quarryingFood, beverages and tobaccoPaper, pulp and printingWood and wood productsConstructionTextile and leather 
   
   
 
Graph A7.4: Poland´s retail energy prices for 
industry (top) and households (bottom) 

(1) On electricity, the band consumption is DC for households 
and ID for industry 
(2) On gas, the band consumption is D2 for households and I4 
for industry 
Source: Eurostat 

Recent  price  schemes  for  electricity  provide 
some  incentives  to  save  energy,  but  the 
newly  established  gas  price  cap  does  not 
encourage consumption reductions. Poland has 
been among the EU countries less affected by the 
rise in energy prices. For electricity, this is also due 
to  the  relatively  small  role  of  gas  in  Poland’s 
power  mix.  In  December  2022,  retail  electricity 
prices  were  EUR  188/MWh,  vs  the  EU  average  of 
EUR  318/MWh.  Similarly,  retail  gas  prices  of  EUR 
55/MWh were around one third of the EU average. 
Poland  has  introduced  a  cap  on  electricity  prices 
for households, public interest organisations, small 
and  medium-sized 
local 
authorities.  Electricity  prices,  expected  to  increase 
significantly  due  to the  tripling  of  coal  prices  and 
the  coal  intensity  of  Poland’s  power  mix,  are 
frozen  at  their  2022  level.  Individuals  will  pay 
approximately PLN 420/MWh + VAT (approx. 90€) 
for their electricity  consumption up to 2 000 KWh 
Households who consume above this threshold will 
pay PLN 693/MWh (around 150€). The cap is PLN 
785/MWh  (170€)  for  the other  entities/companies 
the  measures  cover.  Households  and  SMEs  that 
reduce  their  electricity  use  in  2023  by  10% 
compared  to  2022  will  also  be  rewarded  with  a 

enterprises, 

and 

10% discount on their electricity bills. National and 
local  authorities  were  obliged  to  reduce  their 
electricity  consumption  by  10%  starting  on  1 
October  2022.  Gas  prices  for  Polish  consumers  – 
except  businesses  –  are  capped  at  EUR  43/MWh 
following  a  bill  passed  in  December,  with  an 
additional  VAT  refund  for  the  most  vulnerable 
people who use gas for heating purposes. 

Renewables still play a minor role in Poland’s 
energy  mix,  but  recent  years  have  seen 
several  positive  developments,  especially  in 
solar  energy.  The  renewable  energy  in  the 
final  energy  consumption  amounts  at 
15.62%  (2021).  Between  2020  and  2022, 
installed  solar  PV  capacity  in  the  country  almost 
quadrupled,  from  3.9  GW  to  11  GW (71),  also 
thanks  to  a  very  popular  subsidy  scheme  for 
rooftop  solar panels. Prosumers account for more 
than  70%  of  total  installed  solar  capacity.  There 
are  several  incentive  schemes  to  install  and 
generate  solar  power  for  systems  of  all  capacity 
ranges. On  offshore  wind,  projects  with  a  total 
capacity of approximately 8.4 GW are currently in 
the  pipeline  (5.9  GW  under  Phase  I  and  2.5  GW 
under Phase II), and electricity from the first Polish 
offshore wind farm is scheduled to be fed into the 
grid  in  2026.  By  contrast,  onshore  wind  capacity 
has been growing slowly. The development of wind 
power capacity, in 2022 equal to around 8 GW (72), 
has  been  constrained  by  the  distance  law  (10  H), 
which has the effect of limiting maximum installed 
capacity  to  around  10GW.  Poland  has  committed 
itself to reforming the distance rule in its RRP. The 
amendment  of  the  distance  law (“10H”)  has  been 
adopted  in  March  2023,  lowering  the  minimum 
distance between turbines and housing to 700mt. 
While  this  will  have  a  positive  impact  on  onshore 
wind  development, it  will  leave  significant part  of 
onshore  wind  potential  untapped.    Compared  to 
the  original  government  proposal  to  set  the 
minimum distance at 500mt, the approved bill not 
only  reduces  the  surface  area  available  for 
onshore wind substantially but in many cases will 
also require new planning procedures which would 
cause  additional  delays.  The  Polish  Wind  energy 
association  estimates  that  10  GW  new  onshore 
wind  capacity  could  be  installed  by  2030  with  a 
500m  distance  rule,  while  a  rule  of  700m  would 
reduce this to 4 GW. 

(71)  IRENA Renewable Energy Capacity Statistics 

(72)  IRENA Renewable Energy Capacity Statisticsprosu 

39 

050100150200250€/MWhGas PolandGas EUElectricity PolandElectricity EU050100150200250300€/MWhGas PolandGas EUElectricity PolandElectricity EU 
  
                                                 
based  on  coal.  The  rise  in  coal  prices  gave  a 
significant  boost  to  heat  pump  deployments.  
Since 2017, annual  installations have quadrupled. 
Poland is one of Europe’s fastest growing markets 
for  heat  pumps.  In  2021  heat  pumps  sales  have 
increase  by  around  67%  compared  to  2020,  with 
more  than  93 000  units  sold.  This  positive  trend 
continued  in  2022,  with  a  greater  than  100% 
increase.  This  growth  needs  to 
year-on-year 
become  structural  to  decarbonise  the  still  coal-
dependent heating sector.  

Industrial  energy  efficiency  has  improved 
over the years, following the overall trend of 
decreasing  energy  intensity  of  the  Polish 
economy.  The  mandatory  implementation  of  the 
energy  audits  recommendation,  with  a  short 
payback  period  (e.g.  less  than  5  years),  could 
galvanise  investments  in  energy  efficiency  in 
industry,  further  contributing  to  the  development 
of  energy  supply  companies  and/or  the  white 
certificate  market  and  significantly  improving  the 
energy  efficiency  of 
industrial  sector. 
Regarding market surveillance activities, Poland is 
carrying out a relatively low number of checks on 
products  covered  by  ecodesing  and  energy 
labelling. This may imply some concerns as to the 
compliance  levels  of  the  concerned  products,  and 
therefore missed energy and CO2 savings (74). 

the 

In key transition technologies, there has been 
a  dramatic  increase  in  photovoltaic  capacity 
and  heat  pumps.  With  the  LG  Chem  batteries 
gigafactory  and  Northvolt  subsidiaries  located  in 
Poland,  the  country  is  well  placed  to  further 
develop  the  batteries  market  for  the  electric 
vehicles  segment,  but  also 
for  stationary 
applications,  (batteries  for  the  industrial  storage, 
or  for  homes  to  be  able  to  store  the  energy  they 
produce). Despite  these  positive  developments, 
Poland’s  public  research  &  development  (R&D) 
spending  on  Energy  Union  priorities  has  been 
declining  in  recent  years,  going  from  0.03%  of 
GDP in 2014 to 0.013% in 2020. 

in 

sectors 

that  are  hard 

Renewable  hydrogen could play a  significant 
role  in  decarbonising  the  energy  system, 
particularly  for  parts  of  the  industry  and 
transport 
to 
decarbonise. Poland is the third biggest hydrogen 
producer 
the  EU,  mostly  grey  hydrogen 
produced  by  refineries  and  chemical  plants.  The 
government adopted a national hydrogen strategy 
in November 2021. The strategy sets a target of 2 
GW of installation capacity by 2030 and is mostly 
focused  on  low-carbon  hydrogen,  but  does  not 
clarify  the  sources  of  the  additional  electricity 
necessary  for  hydrogen  production.  The  strategy 
foresees  end-use  applications  of  hydrogen  in  the 
transport, industry and energy sectors. Poland has 
the potential to produce and use biomethane from 
organic  waste,  sludge  and  farming.  It  has  no 
strategy  or  pilot  plants  to  support  the  use  of 
biogases  and  has  not  done  any  studies  on 
appropriate locations for such plants.  

in 

Structural  renovation  measures  could  help 
improve the energy performance of Poland’s 
building  stock  and  alleviate  energy  poverty 
by  helping  households  and  business  cope 
with  high  energy  prices.  In  the  last  decade, 
energy  demand 
the  building  sector  has 
decreased  considerably,  thanks  both  to  energy 
efficiency  improvements  and  the  decline  in  the 
energy 
intensity  of  space  heating  systems. 
However,  the  sector  still  has  a  high  saving 
potential.  The  building  stock  is  old,  with  65%  of 
buildings  over  30  years  old.  Around  a  fifth  of 
households  in  Poland  suffer  from  energy  poverty 
and  two-thirds  of  the  building  stock  still  lack 
proper  insulation (73).  Coal  covers  around  half  of 
residential  buildings’  heating  demand.  Major 
renovations,  together  with  thermal  renovations  to 
move away from fossil fuel-based energy sources, 
will  be  crucial  for  Poland  to  attain  the  long-term 
renovation  strategy’s  2030  goals.  The  energy 
services  market  is  not  well  developed,  despite 
some 
framework 
supportive  elements  and 
conditions (e.g. the white certificate scheme). 

The  transition  of  the  district  heating  sector 
is yet another major challenge for the energy 
transition.  Only  about  20%  of  Polish  district 
heating  systems  qualified  as  energy-efficient  in 
2018, in line with the definition of efficient district 
heating  and  cooling  in  the  Energy  Efficiency 
Directive, while 76% of district heating supply was 

(73)  Polish edition of the Velux Healthy Homes Barometer.  

(74)  The internet-supported information and communication 
system for the pan-European market surveillance. 

40 

 
                                                 
                                                 
Graph A7.5: Public (top) and Private (bottom) R&I 
investment in Energy Union R&I priorities 

Source: JRC SETIS (2022) 

41 

12%9%18%38%40%42%17%14%18%28%14%12%4%16%8%1%8%2%201020142021[% per priority]CCUSNuclear safetySustainable transportEfficient systemsSmart systemRenewables16111371Total [mn Euro]27%19%28%14%22%9%26%42%43%33%17%21%201020142019[% per priority]CCUSNuclear safetySustainable transportEfficient systemsSmart systemRenewables11613792Total [mn Euro] 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table A7.1: Key energy indicators 

(1) The ranking of the main supliers is based on the latest available figures (for 2021) 
(2) FSRU included 
(3) Venture Capital investments include Venture Capital deals (all stages) and Private Equity Growth/Expansion deals (for 
companies that have previously been part of the portfolio of a VC investment firm). 

Source: Eurostat, Gas Infrastructure Europe (Storage and LNG Transparency Platform), JRC SETIS (2022), JRC elaboration based 
on PitchBook data (06/2022) 

42 

EU20182019202020212018201920202021Import Dependency [%] 44%45%43%40%58%61%57%56%of Solid fossil fuels 8%6%0%-4%44%44%36%37%of Oil and petroleum products 99%97%97%96%95%97%97%92%of Natural Gas 78%82%78%84%83%90%84%83%Dependency from Russian Fossil Fuels [%]of Hard Coal68%65%74%66%40%44%49%47%of Crude Oil 77%68%72%63%30%27%26%25%of Natural Gas 62%55%55%57%40%40%38%41%20152016201720182019202020212022Gross Electricity Production (GWh)164,944166,635170,465170,039163,989158,043179,631-Combustible Fuels151,478151,234152,295154,428145,269137,254156,279-Nuclear0000000-Hydro2,4352,6223,0342,3872,6652,9373,101-Wind10,85812,58814,90912,79915,10715,80016,234-Solar 571241653007111,9583,934-Geothermal 0000000-Other Sources11667621252379484-Net Imports of Electricity (GWh)-3341,9992,2875,69510,62313,267888-   As a % of electricity available for final consumption 0%1%2%4%7%9%1% -Electricity Interconnection (%)--4.00%3.97%4.0%3.9%7.0%6.8%20152016201720182019202020212022Gas Consumption (in bcm)18.219.120.420.821.322.023.419.5Gas Imports - by type (in bcm)12.315.817.518.520.921.222.6-Gas imports - pipeline12.114.715.715.817.517.418.5-Gas imports - LNG0.21.11.82.73.53.84.1-Gas Imports - by main source supplier (in bcm)* (1)Russia8.810.910.39.79.69.610.5-Qatar0.32.03.14.64.64.64.7-Germany3.22.73.63.03.93.73.3-United States0.00.00.20.21.92.03.2-Others0.00.20.31.00.91.40.8-2019202020212022LNG TerminalsNumber of LNG Terminals (2)1111LNG Storage capacity (m3 LNG)320,000320,000320,000320,000Underground StorageNumber of storage facilities10101010Operational Storage Capacity (bcm)3.53.73.73.72019202020212022VC investments in climate tech start-ups and scale-ups (EUR Mln) (3)0.010.30.9n.a.as a % of total VC investments in Poland0.0%3.9%0.2%n.a.Research & Innovation spending in Energy Union R&i priorites (2)Public R&I (EUR mln)59.776.970.5n.a.Public R&I (% GDP)0.011%0.015%0.012%n.a.Private R&I (EUR mln)92.2n.a.n.a.n.a.Private R&I (% GDP)0.02%n.a.n.a.n.a.POLANDENERGY DEPENDENCEDIVERSIFICATION OF GAS SUPPLIESCLEAN ENERGYELECTRICITY 
 
   
 
 
 
ANNEX 8: FAIR TRANSITION TO CLIMATE NEUTRALITY 

in 

line 

with 

This  Annex  monitors  Poland’s  progress  in 
ensuring  a  fair  transition  towards  climate 
neutrality  and  environmental  sustainability, 
notably  for  workers  and  households 
in 
vulnerable  situations.  To  ensure  a  fair  green 
transition 
Council 
the 
Recommendation (75),  upskilling  and 
reskilling 
measures  will  promote  smooth  labour  market 
transitions and the implementation of REPowerEU. 
Under  the  recovery  and  resilience  plan  (RRP), 
crucial  reforms and investments for companies in 
products,  services  and  in  the  competences  of 
employees and staff support  the green transition, 
complementing  the  territorial  just  transition  plans 
and actions financed by the European Social Fund 
Plus (ESF+). Poland is also the largest recipient of 
the Just Transition Fund, which will strengthen the 
transformation in five Polish regions. 

Graph A8.1: Fair transition challenges in Poland 

Source: Eurostat, EMPL-JRC GD-AMEDI/AMEDI+ projects and 
World Inequality Database (see Table A8.1).           

Employment 
in  Poland’s  sectors  most 
affected  by  the  green  transition  remains 
stable, while the green economy is expanding 
and  workers  in  declining  activities  need 
active  support.  The  greenhouse  gas 
(GHG) 
emissions intensity of Poland’s workforce fell from 
21.6 to 21.4 tonnes per worker between 2015 and 
2021, well above the EU average of 13.7 in 2021 
(see  Graph A8.1  and  Table A8.1).  Employment  in 
Poland’s 
(EII) 
represented  5.4%  of  total  employment  in  2020 
(EU  average:  3.0%).  Employment  in  mining  and 
quarrying has decreased by 17.7% since 2015 (to 
around  189 000  workers)  due  to  the  decline  of 

energy-intensive 

industries 

coal and lignite mining in Poland. Total jobs in the 
environmental  goods  and  services  sector  grew  by 
40.1%  (to  272 537)  in  2015-2019  (EU:  8.3%), 
reaching  1.7%  of  total  employment  (EU:  2.2%) 
(see Annex 9 for circular jobs specifically). The job 
vacancy  rate  in  construction,  which  is  key  for  the 
green  transition,  is  2.1%  (2022)  vs  4%  (2022)  in 
the  EU (76).  Since  Poland  had  135 900  mining 
workers  out  of  208 100  in  the  EU  as  a  whole  in 
2021,  it  accounts  for  more  than  65%  of  mining 
employment in the EU. The increased demand for 
fossil  fuels  caused  by  reduced  imports  from 
Russia is expected to temporarily slow the mining 
industry's 
in 
employment. 

previously 

decline 

steady 

(see  Annex  15).  To  address 

industries,  workers’  participation 

Upskilling  and  reskilling  in  declining  and 
transforming  sectors  increased  slightly  and 
labour  shortages  are  relatively  limited.  Skills 
are  key  for  smooth labour  market transitions  and 
preserving jobs in transforming sectors. In energy-
intensive 
in 
education  and  training  increased  from  4.3%  in 
2015  to  8.1% in  2022  but  remains  below  the  EU 
average  (10.4%  in  2022).  In  Poland,  41%  of 
citizens  believe  they  do  not  have  the  necessary 
skills  to  contribute  to  the  green  transition  (EU: 
38%) (77) 
this 
challenge, specific investments under the RRP and 
the  Just  Transition  Mechanism  provide  training  to 
reskill  workers 
the 
transition, together with a broader training offer at 
level  and  flexibility  mechanisms  to 
regional 
encourage 
The  ESF+ 
reinforces  the  green  transition  in  all  16  regional 
programmes and in the national ESF+ programme 
through  various  interventions  that  promote  and 
support  the  deployment  of  green  skills,  e.g.  by 
offering  new  curricula  in  schools  or  adapting 
training for workers. As part of the Just Transition 
Fund, Silesia, which is Poland's and the EU's main 
mining  region  employing  the  major  part  of  Polish 
mining sector workers, will receive nearly EUR 200 
million for green skills for adults and workers put 
at risk by the transition. 

regions  affected  by 

in-company 

training. 

in 

While  people’s  ability  to  keep  their  homes 
adequately  warm  has  improved  significantly 
in  recent  years  until  2021,  the  spike  in 
energy  prices  can  be  expected  to  aggravate 

(75)  Council Recommendation of 16 June 2022 on ensuring a fair 
transition towards climate neutrality (2022/C 243/04) covers 
employment, skills, tax-benefit and social protection 
systems, essential services and housing. 

(76)  Eurostat (JVS_A_RATE_R2) 

(77)  Special Eurobarometer 527. Fairness perceptions of the 

green transition (May – June 2022). 

43 

00.20.40.60.811.21.41.61.8GHG per workerEmployment EIIEducation &training EIIEnergy povertyTransportpoverty(proxy)CarboninequalityEU LatestPL Latest (vs EU Latest)PL 2015 (vs EU Latest) 
 
  
                                                 
                                                 
 
Table A8.1: Key indicators for a fair transition in Poland 

Source: Eurostat (env_ac_ainah_r2, nama_10_a64_e, ilc_mdes01), EU Labour Force Survey (break in time series in 2021), EMPL-
JRC GD-AMEDI/AMEDI+ projects and World Inequality Database (WID).      

the situation again. The share of the population 
unable  to  keep  their  homes  adequately  warm  fell 
from  7.5%  in  2015  to  3.2%  in  2021 (78).  In 
particular,  8.2%  of  the  population  at  risk  of 
poverty  were  affected  in  2021  (EU:  16.4%  in 
2021),  as  were  2.3%  of  lower  middle-income 
households  (in  deciles  4-5)  in  2020  (EU:  8.2%  in 
2021). Before the energy price hikes, an estimated 
49.1%  of  the  total  population  and  56.2%  of  the 
(expenditure-based) 
(AROP) 
population  had  residential  expenditure  budget 
shares  on  electricity,  gas,  and  other  fuels (79) 
above  10%  of  their  household  budget  (above  the 
estimated  EU  average  of  26.9%  and  48.2%, 
respectively). 

at-risk-of-poverty 

population,  the  individuals  living  in  households 
with  budget  shares  for  private  transport  fuels (82) 
above  6%  would  have  increased  by  7.1 pps  (EU 
average:  +5.3 pps),  reaching  36.0%  in  January 
2023 (EU: 37.1%) due to the increase in transport 
fuel prices. Transport fuel price increases in Poland 
affect  the  upper-middle  and  higher  incomes  the 
most. 

Graph A8.2: Distributional impacts of energy prices 
due to rising energy expenditure (2021-2023) in 
Poland 

The  increased  energy  prices  in  2021-2023 
negatively affected households’ budgets. As a 
result  of  energy  price  changes  during  the  August 
2021  to  January  2023  period  relative  to  the  18 
months prior (cf. Annex 7), in the absence of policy 
support and behavioural responses (but accounting 
for  price  interventions),  the  share  of  individuals 
living  in  households  which  spend  more  than  10% 
of their budget on energy would have increased by 
the  whole 
8.7  percentage  points 
population 
the 
(expenditure-based)  AROP  population,  less  than 
the  EU-level  increases  (16.4 pps  and  19.1 pps, 
respectively) (80).  Almost  all 
(94 %) 
consider rising energy prices a serious problem (81). 
In  contrast  to  EU-wide  patterns,  the  expenditure 
shares would have increased almost evenly across 
income  groups,  in  particular  for  gas,  as  shown  in 
Graph A8.2.  Among  the  (expenditure-based)  AROP 

(pps)  for 
7.1 pps 

citizens 

among 

and 

by 

(78)  Energy poverty is a multi-dimensional concept. The indicator 
used focuses on an outcome of energy poverty. Further 
indicators are available at the Energy Poverty Advisory Hub. 

(79)  Products defined according to the European Classification of 
Individual Consumption according to Purpose (ECOICOP): 
CP045. 

Mean change of energy expenditure as a percentage (%) of 
total expenditure per income decile (D) due to observed price 
changes (August 2021 – January 2023), without accounting 
for targeted support measures. 
Source: EMPL-JRC GD-AMEDI/AMEDI+ projects, based on 
Household Budget Survey 2015 and Eurostat inflation data 
for CP0451 and CP0452. 

Access to public transport displays an urban-
rural  divide.  Citizens  in  Poland  perceive  public 
transport  to  be  available  (60%  vs  EU  55%), 
affordable (60% vs EU 54 %) and of good quality 
(66%  vs  EU  60%).  As  for  these  perceptions,  rural 
areas outperform rural areas in the EU overall on 
all  three  dimensions (83).  The  average  carbon 
footprint  of  the  top  10%  of  emitters  among  the 
population in Poland is 5 times that of the bottom 

(80)  EMPL-JRC GD-AMEDI/AMEDI+ ; see details in the related 

(82)  ECOICOP: CP0722. 

technical brief. 

(81)  Special Eurobarometer 527. 

(83)  EU (rural): 46%, 48%, 56% respectively. Special 

Eurobarometer 527. 

44 

0.0%0.5%1.0%1.5%2.0%2.5%3.0%ElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasElectricityGasD1D2D3D4D5D6D7D8D9D10PL GasPL ElectricityEU GasEU ElectricityIndicatorDescriptionPL 2015PL LatestEU LatestGHG per workerGreenhouse gas emissions per worker - CO2 equivalent tonnes21.621.4 (2021)13.7 (2021)Employment EIIEmployment share in energy-intensive industries, including mining and quarrying (NACE B), chemicals (C20), minerals (C23), metals (C24), automotive (C29) - %5.35.4 (2020)3 (2020)Education & training EIIAdult participation in education and training (last 4 weeks) in energy-intensive industries - %4.38.1 (2022)10.4 (2022)Energy povertyShare of the total population living in a household unable to keep its home adequately warm - %7.53.2 (2021)6.9 (2021)Transport poverty (proxy)Estimated share of the AROP population that spends over 6% of expenditure on fuels for personal transport - %28.936 (2023)37.1 (2023)Carbon inequalityAverage emissions per capita of top 10% of emitters vs bottom 50% of emitters55 (2020)5 (2020) 
                                                 
   
                                                 
 
  
 
50% (see Table A8.1), and is at the same level as 
includes  several 
the  EU  average.  The  RRP 
measures  aimed  at  shifting  the  energy  mix 
towards  low-carbon  technologies  by  facilitating 
the  deployment  of  renewables  and  increasing the 
use of alternative energy sources, reducing energy 
consumption  by  advancing  a  deep  renovation  of 
buildings,  and  reducing  the  energy  intensity  of 
industry  and  services  as  well  as  households.  In 
Poland, the average levels of air pollution in 2020 
stood  above  the  EU  average  (16  vs  11.2  µg/m 
PM2.5), with almost all regions exposed to critical 
levels  of  air  pollution (84).  This  has 
led  to 
significant  health 
in  particular  on 
impacts, 
vulnerable  groups,  and  36  530  premature  deaths 
annually (85).  

(84)  Double the recommendations in the WHO Air Quality 

Guidelines. (annual exposure of 5µg/m3) 

(85)  EEA- Air Quality Health Risk Assessment 

45 

 
 
 
 
                                                 
PRODUCTIVITY 
ANNEX 9: RESOURCE PRODUCTIVITY, EFFICIENCY AND CIRCULARITY 

The  circular  economy  transition  is  key  to 
climate  and 
delivering  on 
the  EU’s 
environmental  goals  and  provides 
large 
socio-economic  benefits. It  spurs  job  growth, 
innovation  and  competitiveness  and 
fosters 
resilience  and  resource  security.  The  circularity 
transition  of  industry,  the  built  environment  and 
agri-food  can  generate  significant  environmental 
improvements (see Annex 6), as they rank among 
the most resource-intensive systems. 

industrial  production,  (ii)  sustainable  consumption, 
(iii) bioeconomy,  (iv) new  business  models,  and 
(v) implementation  and  monitoring.  It  sets  out 
more than 40 tasks with a 4-year implementation 
timeline. Poland also had its 2022 national waste 
management  plan  (KPGO  2022  –  Krajowy  plan 
gospodarki odpadami 2022) approved in 2016 and 
amended  in  2021.  A  plan  with  a  more  forward-
looking  perspective 
is  being 
developed; adoption is expected by June 2023. 

(KPGO  2028) 

Poland’s  circular  economy  transition 
is 
insufficient  and  needs  accelerating  to  meet 
the  EU’s  circular  economy  goals.  The  EU’s 
2020 circular economy action plan (CEAP) aims at 
doubling  circular  material  use  by  2030  vs.  2020. 
Poland’s  circular  material  use  decreased  from 
10.2%  in  2016  to  9.1%  in  2021,  and  the  gap 
the  EU 
between  Poland’s  performance  and 
average  of  11.7%  has  widened.  The  CEAP  also 
aims  to  significantly  decrease  the  EU’s  material 
footprint.  In  2020,  Poland’s  material  footprint 
(17.6  tonnes  per  head)  was  above  the  2020  EU 
average (13.7 tonnes per head). The labour market 
benefits  of  the  circular  transition  have  recently 
started to  gain  importance,  with  a growth  rate  of 
in  circular 
2.8% 
economy  (CE)  sectors  represented  10.1%  of  the 
EU  total  in  2018 (86).  As  concerns  health  and 
safety  in  circular  jobs,  fatal  accidents  in  waste 
management  and  materials  recovery  are  above 
the average of all economic sectors and above the 
EU average in Poland (87). 

in  2019.  People  employed 

Poland  has  adopted  a  strategy  to  address 
circular  economy  challenges,  but  more 
measures  are  needed.  In  September  2019, 
Poland adopted the ‘Roadmap for the transition to 
Circular Economy’ (CE roadmap), which contains a 
set  of  tools,  not  just  legislative,  aiming  to  create 
conditions  for  the  implementation  of  a  new 
economic  model  in  Poland.  The  proposed  actions 
mainly  concern  analytical  and  conceptual  work, 
information and promotion, as well as coordination 
in  areas  within  the  competence  of  individual 
ministries.  The  CE  roadmap  is  structured  around 
(i) sustainable 
the 

following  main 

themes: 

(86)  European Environment Agency, 2022, Circular economy 

country profile – Poland. 

(87)  Eurostat [HSW_N2_02] for NACE Rev. 2 sector E38; 6.94 

fatal accidents p. 100 000 employed in 2018-2020 vs 1.34 
for all sectors in PL; 6.33 in the EU-27 for sector E38. 

46 

Graph A9.1: Trend in material use 

Source: Eurostat 

to 

starting 

treatment 

see 
is 
Waste 
improvements  due  to  recent  reforms.  Poland 
missed  the  2020  EU  target  for  recycling  50%  of 
municipal waste, only reaching 38.7%. Poland is at 
risk  of  missing  the  2025  EU  recycling  targets  for 
municipal  and  packaging  waste.  In  2021,  about 
39%  of  Poland’s  municipal  waste  was  still 
landfilled,  above  the  EU  average  (23%).  Another 
major  challenge  is  the  low  capture  rate  of  bio-
waste 
recycling 
capacities for separately collected bio-waste.  

combined  with 

insufficient 

is 

industrial  system 

insufficiently 
The 
circular and efficient. The economy, particularly 
industry,  is  less  efficient  at  using  materials  than 
the EU average, with a resource productivity of 1.4 
purchasing power standard per kilogramme vs 2.3 
for  the  EU-27.  There  is  substantial  room  for 
improvement 
regards  actions 
concerning  industrial  waste,  in  particular  from 
mining,  extraction,  industrial  processing  energy 
production and supply.  

in  Poland  as 

0.020.040.060.080.0100.0120.00.02.04.06.08.010.012.014.016.018.020.0201620172018201920202021kg/capitatonnes/capitaMaterial footprint Poland (tonnes/capita)Material footprint EU-27 (tonnes/capita)Trade in recyclable raw materials Poland (imports extra EU, kg/capita)Trade in recyclable raw materials EU-27 (imports extra EU, kg/capita) 
 
 
                                                 
       
 
Graph A9.2: Treatment of municipal waste 

Source: Eurostat 

The  built  environment  system  continues  to 
exacerbate  the  depletion  of  resources.  The 
recovery rate of construction and demolition waste 
has decreased since 2016 and remains well below 
the EU average (74% vs 89%). There is scope for 
of 
renovating 
constructing  new  ones,  as  well  as  for  increasing 
the  share  of  secondary  raw  materials  used  in 
resource  efficiency 
construction.  Energy  and 

buildings 

existing 

instead 

renovations  of  buildings  are  among  the  priorities 
of  the  Polish  recovery  and  resilience  plan  and 
cohesion  policy  programmes  for  2021-2027.  As 
stipulated  in  the  Partnership  Agreement  with 
Poland, solutions supporting CE are to be deployed 
in renovation projects wherever reasonable. 

to 

is 
As  for  the  agri-food  system,  there 
composting  and 
increase 
potential 
digestion  and  to  boost  development  of 
organic  farming.  Poland’s  composting  and 
anaerobic  digestion  per  head  has  doubled  since 
2016,  but  still  remains  far  below  the  EU  average 
in  2021  at  48  kg  per  head  vs  100  kg.  Increasing 
composting  could  enhance  Poland’s  potential  for 
producing  organic  fertilisers  and  hence  support 
organic  farming,  which  remains  under-developed. 
With 3.52% of land under organic farming, Poland 
ranked 23rd out of 27 EU Member States in 2020.  

There remains a financing gap in the circular 
economy, 
including  waste  management.  
Additional  investments  will  be  required  to 
address  growing  needs.  The  financing  gap  was 
estimated at EUR 789 million/year between 2014 
and 2020. Over this period, investment needs were 
estimated  to  be  at  least  EUR  2  billion/year  while 
investment  baselines  were  EUR  1.2  billion/year 
(see Annex 6). 

Table A9.1: Overall and systemic indicators on circularity 

(1) Persons employed in the circular economy only tracks direct jobs in selected sub-sectors of NACE codes E, C, G and S; (2) the 
circular material use rate measures the share of material recovered and fed back into the economy in overall material use, 
including composting and digestion; (3) the recovery rate of construction and demolition waste includes waste which is prepared 
for reuse, recycled or subject to material recovery, including through backfilling operations; (4) soil sealing: 2016 column refers to 
2015 data; (5) food waste includes primary production, processing and manufacturing, retail and distribution, restaurants and 
food services, and households. 
Source:  Eurostat, European Environment Agency 

47 

3073153293363463620100200300400500201620172018201920202021Kg per capita Difference waste generated/treatmentLandfill/disposalTotal incineration (including energy recovery)Composting and digestionMaterial recyclingEU-27AREA201620172018201920202021EU-27 Latest year EU-27Overall state of the circular economyMaterial footprint (tonnes/capita)16.718.119.018.617.6-13.72020YoY growth in persons employed in the circular economy (%)10.0-0.5 -0.9 2.8--2.92019Water exploitation index plus (WEI+) (%)10.56.45.88.7--3.62019IndustryResource productivity (purchasing power standard (PPS) per kilogram)1.21.21.21.31.41.42.32021Circular material use rate (%)210.29.99.810.37.59.111.72021Recycling rate (% of municipal waste)34.833.834.334.138.740.349.62021Built environmentRecovery rate from construction and demolition waste (%)391.0-84.0-74.0-89.02020Soil sealing index (base year = 2006)4108.7-114.2---108.32018Agri-foodFood waste (kg per capita)5----106.0-131.02020Composting and digestion (kg per capita)21.022.027.030.042.048.0100.02021 
 
       
 
      
 
ANNEX 10: DIGITAL TRANSFORMATION 

transformation  by  2030, 

Digital  transformation  is  key  to  ensuring  a 
resilient and competitive economy. In line with 
the  Digital  Decade  Policy  Programme,  and  in 
particular  with  the  targets  in  that  Programme  for 
digital 
this  Annex 
describes  Poland’s  performance  on  digital  skills, 
digital 
the 
digitalisation  of  businesses  and  public  services. 
Where relevant, it makes reference to progress on 
implementing  the  Recovery  and  Resilience  Plan 
(RRP).  Poland  allocates  21%  of  its  total  RRP 
budget to digital (EUR 7.5 billion) (88). 

infrastructure/connectivity 

and 

The  Digital  Decade  Policy  Programme  sets 
out a pathway for Europe’s successful digital 
transformation  by  2030.  The  Programme 
provides  a  framework  for  assessing  the  EU’s  and 
Member States’ digital transformation, notably via 
the  Digital  Economy  and  Society  Index  (DESI).  It 
also  provides  a  way  for  the  EU  and  its  Member 
States  to  work  together,  including  via  multi-
country  projects,  to  accelerate  progress  towards 
the  Digital  Decade  digital  targets  and  general 
objectives (89).  More  generally,  several  aspects  of 
digital  transformation  are  particularly  relevant  in 
the current context. In 2023, the European Year of 
Skills, building the appropriate skillset to make full 
use of the opportunities that digital transformation 
offers  is  a  priority.  A  digitally  skilled  population 
increases the development and adoption of digital 
technologies  and  leads  to  productivity  gains (90). 
Digital  technologies,  infrastructure  and  tools  all 
play  a  role  in  the  fundamental  transformation 
needed to adapt the energy system to the current 
structural challenges (91). 

The  low  level  of  basic  digital  skills  is  a  key 
challenge  for  Poland  in  the  human  capital 
dimension.  Poland  scores  below  the  EU  average 
on  the  proportion  of  its  population  with  at  least 

(88)  The share of financial allocations that contribute to digital 
objectives has been calculated using Annex VII of the RRF 
Regulation. 

(89)  The Digital Decade targets as measured by DESI indicators 
and complementary data sources are integrated to the 
extent currently available and/or considered particularly 
relevant in the MS-specific context.  

(90)  See for example OECD (2019): OECD Economic Outlook, 

Digitalisation and productivity: A story of complementarities, 
OECD Economic Outlook, Volume 2019 Issue 1 | OECD 
iLibrary (oecd-ilibrary.org). 

(91)  The need and possible actions for a digitalisation of the 
energy system are laid out in the Communication 
‘Digitalisation the energy system – EU action plan’ 
(COM(2022)552. 

48 

basic digital skills. Also, ICT specialists account for 
a  lower  percentage  of  the  workforce  in  Poland 
than  the  EU  average.  The  percentage  of  female 
ICT  specialists  is  also  below  the  EU  average.  The 
low  share  of  digital  specialists  in  the  Polish 
workforce is exacerbated by only average rates of 
enrolment  and  graduates  in  ICT-related  studies. 
The  RRP  measures  that  aim  to  introduce  more 
digital  themes  in  education  and  to  provide  the 
digital  equipment  in  schools  are  expected  to 
contribute  to  increase  the  level  of  digital  skills  if 
their  implementation  is  based  on  sound  and  well 
consulted strategies. 

for 

Poland  has  a  mixed  performance  on  the 
indicators 
digital 
infrastructure/connectivity.  The  very  high 
capacity network (VHCN) coverage matches the EU 
average,  while  overall  5G  coverage  is  at  63%, 
considerably  below 
the  EU  average.  No 
harmonised radio spectrum for 5G deployment has 
been  yet  assigned.  For  instance,  the  3.4-3.8  GHz 
spectrum  band,  which  is  essential  for  enabling 
advanced  applications  requiring  large  spectrum 
bandwidth,  is  not  available  for  providing  services 
to  the  citizens.  The  RRP 
includes  significant 
investments supporting the roll-out of connectivity 
infrastructure  and  as  well  as  some  relevant 
legislative  action.  Swift  execution  of  the  5G 
spectrum  auction  is  of  utmost  importance  as  it 
would  enable  investment,  both  private  and  also 
from RRP funds. The delay in spectrum assignment 
constitutes a major risk for the implementation of 
the RRP investment supporting the 5G rollout.  

Poland  is  still  far  below  the  EU  average  for 
most 
indicators  on  the  digitalisation  of 
businesses. The proportion of SMEs with at least 
a basic level of digital intensity is much lower than 
the  EU  average.  The  adoption  of  advanced  digital 
technologies  is  also  considerably  below  the  EU 
average  for  big  data  solutions,  cloud  computing, 
and artificial intelligence. The RRP includes several 
measures  to  support  the  adoption  of  digital 
technologies  by  SMEs,  which  are  expected  to 
improve performance in this area. 

Poland  is  still  performing  below  the  EU 
average 
in  the  digital  public  services 
dimension  of  DESI.  Poland  scores  below  the  EU 
average  on  the  availability  of  digital  public 
services.  Poland  has  two  electronic  identification 
(eID)  means  notified  under  the  Public  Electronic 
Identification  System.  The  e-ID  system  (called 
‘Trusted Profile’ - Profil Zaufany) is being used by 

 
 
                                                 
 
more than 16 million people, in particular through 
the  mObywatel  app  that  provides  access  to  a 
number of public services. The same app provides 
also access to the patient’s online account that is 
needed  for  the  mandatory  e-prescriptions  system 
and enables interacting with the health system on 
other administrative issues.  In terms of access to 
e-health records, Poland scores well above the EU 
average with a score of 86 out of 100.  

Table A10.1: Key Digital Decade targets monitored by DESI indicators 

(1) The 20 million target represents about 10% of total employment. 
(2) The Fibre to the Premises coverage indicator is included separately as its evaluation will also be monitored separately and 
taken into consideration when interpreting VHCN coverage data in the Digital Decade. 
(3) At least 75 % of Union enterprises have taken up one or more of the following, in line with their business operations: (i) cloud 
computing services; (ii) big data; (iii) artificial intelligence.   

Source: Digital Economy and Society Index 

49 

EUDigital Decade target by 2030 DESI 2021DESI 2022DESI 2023DESI 2023(EU)Digital skillsAt least basic digital skillsNA43%43%54%80%% individuals2021202120212030ICT specialists (1)3.4%3.5%3.5%4.5%20 million% individuals in employment aged 15-7420202021202120212030Digital infrastructure/connectivityFixed Very High Capacity Network (VHCN) coverage65%70%71%73%100%% households20202021202220222030Fibre to the Premises (FTTP) coverage (2)45%52%60%56%-% households20202021202220222030Overall 5G coverage10%34%63%81%100%% populated areas202020212022202220305G coverage on the 3.4-3.8 GHz spectrum bandNANA0%41%-% populated areas202220222030Digitalisation of businessesSMEs with at least a basic level of digital intensityNANA61%69%90%% SMEs202220222030Big data (3)9%9%9%14%75%% enterprises20202020202020202030Cloud (3)NA19%19%34%75%% enterprises2021202120212030Artificial Intelligence (3)NA3%3%8%75%% enterprises2021202120212030Digitalisation of public servicesDigital public services for citizensNA576077100Score (0 to 100)2021202220222030Digital public services for businessesNA707384100Score (0 to 100)2021202220222030Access to e-health recordsNANA8671100Score (0 to 100)202320232030Poland 
 
  
 
 
 
 
 
 
 
ANNEX 11: INNOVATION 

This  Annex  provides  a  general  overview  of  the 
performance  of  Poland’s  research  and  innovation 
system,  which  is  essential  for  delivering  the  twin 
green and digital transition. 

is 

an 

‘emerging 

innovation 
Poland 
performer’,  slowly  bridging  the  gap  between 
the  EU  average. 
its  performance  and 
Innovation 
According  to  the  2022  European 
Scoreboard (92),  Poland  has  been  increasing  its 
innovation  score  continuously  since  2015,  though 
important progress is still needed, as its innovation 
the  average  EU 
score 
performance. 

just  60.5%  of 

is 

Graph A11.1: R&D intensity in Poland over time 

Source: European Innovation Scoreboard, 2022 

R&D 

investment 

Business 
and 
entrepreneurial  dynamism  contribute  to  the 
catching-up  process,  but  several  emerging 
bottlenecks  might  impede  its  continuation.  A 
key driver for the caching-up process is the growth 
of  R&D  intensity (93)  (1.44%  of  GDP  in  2021) (94), 
entirely due to the strong increase in business R&D 
investment  over 
(business 
intensity (95)  reached  0.91%  in  2021,  compared 
with  0.19%  in  2010).  Several  indicators  highlight 

last  decade 

the 

(92)  2022 European Innovation Scoreboard (EIS), Country profile: 
Poland https://ec.europa.eu/assets/rtd/eis/2022/ec_rtd_eis-
country-profile-pl.pdf. The EIS provides a comparative 
analysis of innovation performance in EU countries, including 
the relative strengths and weaknesses of their national 
innovation systems (also compared to the EU average). 

(93)  Defined as gross domestic expenditure on R&D as a 

percentage of GDP. 

(94)  Source: Eurostat. 

(95)  Defined as business spending on R&D as a percentage of 

Poland’s  entrepreneurial  dynamism:  the  share  of 
start-up  companies  in  total  employer  enterprises 
almost  doubled  from  2012  (17.3%)  to  2019 
(34.9%)  and  the  share  of  employment  in  high-
growth  enterprises  in  the  most  innovative  sectors 
was 6.7% in 2019, above the EU average of 5.5%. 
However,  the  sustainability  of  this  catching-up 
process is threatened by several major bottlenecks 
in  the  research  and  innovation  (R&I)  ecosystem 
such  as  a  weak  propensity  to  innovate  among 
small  and  medium-sized  enterprises 
(SMEs), 
emerging  skills  shortages  and  the  weaknesses  of 
the public science base (96). 

to 

Development  and  diffusion  of  innovative 
technologies  and  solutions  across  the  Polish 
economy,  in  particular  among  SMEs,  remain 
very  limited,  hindering  the  green  and  digital 
transitions.  According 
the  Community 
Innovation  Survey,  only  23.7%  of  Polish  firms 
reported  innovation  activities,  one  of  the  lowest 
rates  in  the  EU.  The  gap  between  Poland  and  the 
EU  average  is  much  bigger  for  SMEs  than  for 
larger  companies:  In  Poland  only  22%  of  SMEs 
were  considered  innovative  in  2018,  compared 
with the EU average of 49%; for large companies, 
the figures are 60.4% for Poland and 77% for the 
EU  average (97).  Such  a  narrow  innovation  base 
restricts  the  country’s  capacity  to  perform  the 
green and digital transition. Additionally, the share 
of  environment-related  patents  is  lower  than  the 
EU average. 

in 

Polish 

competitiveness 

Shortages of skills in science and engineering 
limit 
new 
innovative  sectors.  The 
technologies  and 
number  of  new  graduates 
in  science  and 
engineering  per  thousand  population  aged  25  to 
34  decreased  significantly,  from  15.9  in  2010  to 
12.0  in  2020.  Moreover,  the  Polish  education 
system trains few doctorate graduates. In terms of 
new  doctorate  graduates  in  STEM  per  1000  of 
population, Poland’s figure is just 25.8% of the EU 
(by  11.4%) 
average 
compared to 2021 (98) (99). 

in  2022,  down  sharply 

Public research must improve qualitatively in 
in  the  R&I 
order  to  play  a  full  role 

(96)  The public science base is the research ecosystem funded by 

the public sector. 

(97)  Source: Community Innovation Survey 2018. 

(98)  Source: European Innovation Scoreboard 2022. 

GDP. 

(99)  More information on education and skills in Annex 15. 

50 

0.00.20.40.60.81.01.21.41.6201020112012201320142015201620172018201920202021As % of GDPR&D IntensityPublic expenditure on R&D (Government intramural expenditure on R&D +Higher education expenditure on R&D)Business enterprise expenditure on R&D (Business expenditure on R&D) 
 
  
                                                 
                                                 
 
Table A11.1: Key innovation indicators 

(1) EU average for the latest available year or the year with the highest number of country data. 
Source: Eurostat, OECD, DG JRC, Science-Metrix (Scopus database and EPO’s Patent Statistical database), Invest Europe 

With  a  direct  budget  of  EUR 1.51 billion,  the 
national  RRP  helps  tackle  some  of  Poland’s  main 
innovation challenges. The RRP includes measures 
to  improve  science-business  links,  such  as  a 
research 
reform  allowing  universities  and 
institutes  to  become  shareholders  in  companies. 
Furthermore,  the  RRP 
includes  a  number  of 
investments  to  modernise  research  infrastructure 
in  public  laboratories  and  research  institutes.  The 
RRP  also  includes  measures  to  incentivise  the 
uptake of digital technologies in the private sector, 
and  to  support  the  development  and  diffusion  of 
breakthrough  technologies,  particularly 
in  the 
fields  of  the  circular  economy  and  unmanned 
aviation.  Additionally, 
features  a 
EUR 273 million  investment  to  support  activities 
linked  to  innovation  spaces  such  as  incubators  in 
the  biomedical  sector.  Spillovers  in  other  sectors 
will benefit the whole Polish innovation ecosystem.  

the  RRP 

linkages  remain 
ecosystem.  Science-business 
limited,  as  shown  by  several  indicators:  both  the 
share of public-private scientific co-publications as 
a  share  of  all  scientific publications  and  the level 
of  business  financing  for  public  R&D  remain  well 
below  the  EU  average.  Public  research’s  low 
attractiveness  for  potential  business  partners 
reflects  its  weak  capabilities.  Both  public  R&D 
intensity, which has stagnated at around 0.53% of 
GDP  since  2010,  and  the  quality  of  the  public 
science  base  (as  measured  by  the  share  of 
scientific  publications  within  the  top  10%  most 
cited publication worldwide) remain well below the 
EU  average,  though  the  measure  has  been 
improving significantly, overall, since 2010 (100). 

Poland’s  national  recovery  and  resilience 
plan (RRP) contains measures to enhance its 
public  research  capabilities,  improve  public-
private research cooperation, and strengthen 
the  development  and  diffusion  of  innovative 
technologies  for  the  green  and  digital 
transitions.  

(100) Source: Science-Metrix, May 2021. 

51 

EUaverage (1)R&D intensity (GERD as % of GDP)0.721.001.321.391.442.26Public expenditure on R&D as % of GDP0.530.530.490.510.530.76Business enterprise expenditure on R&D (BERD) as % of GDP0.190.470.830.870.911.49Scientific publications of the country within the top 10% most cited publications worldwide as % of total publications of the country 2.94.25.0::9.8Patent Cooperation Treaty patent applications per billion GDP (in PPS)0.50.70.5::3.3Public-private scientific co-publications as % of total publications3.33.94.94.94.97.1Public expenditure on R&D financed by business enterprise (national) as % of GDP0.0240.0190.016::0.054New graduates in science & engineering per thousand pop. aged 25-3415.916.513.812.0:16.0Total public sector support for BERD as % of GDP0.0300.0820.170::0.194R&D tax incentives: foregone revenues as % of GDP000.018::0.100Share of environment-related patents in total patent applications filed under PCT (%)12.114.410.3::13.3Venture capital (market statistics) as % of GDP0.0070.0060.0120.0180.0220.074Employment in fast-growing enterprises in 50% most innovative sectors6.35.86.7::5.520212020Poland201020152019Finance for innovation and economic renewalKey indicators Quality of the R&I systemAcademia-business cooperationHuman capital and skills availabilityPublic support for business enterprise expenditure on R&D (BERD)Green innovation  
                                                 
 
 
 
 
  
 
ANNEX 12: INDUSTRY AND SINGLE MARKET 

Higher investment rates, in particular private 
investment,  could  boost  Poland’s  long-term 
growth  and  facilitate  the  shift  toward  a 
greener  growth  model.  Poland’s  investment-to-
GDP reached 17% in 2021, considerably below the 
EU average (22.5%, see Graph A12.1) and that of 
peer countries (Hungary: 27.4%, Czechia: 26%).  

regulatory  environment, 
legislative  process 
the 

Investment performance is negatively  affected by 
the 
a  burdensome 
deterioration 
that 
in 
increases  uncertainty  for  investors,  a  low  degree 
of  automation  and  robotisation  in  Polish  industry 
and  skills  mismatches  and  labour  shortages  (see 
Table A12.1) that result in rising labour unit costs.  

Moreover, in recent months high global commodity 
prices  and  energy  costs  have  depressed  business 
sentiment. Poland has one of the lowest shares of 
investment  in  intangible  assets (101).  Delays  in 
delivering  on  the  commitments  in  the  country’s 
Rrecovery  and  Resilience  Plan,  related  to  rule  of 
law issues, risk a further delay in the disbursement 
of  Next  Generation  EU  funds,  affecting  business 
confidence,  especially  among  foreign  investors, 
and  dampening  the  outlook  for  both  public  and 
private investment growth. 

Graph A12.1: Investment, % GDP 

Source: Eurostat 

Polish  industry  accounts  for  25.1%  of  total 
gross  value  added  and  22.5%  of  total 
employment, significantly above EU averages 
(20%  and  15.7%,  respectively).  As  manufacturing 
contributes to over 90% of exports, the long-term 
competitiveness  of  the  Polish  economy  is  heavily 
dependent  on  reducing  the  emissions  of  the 
industrial  firms.  Poland  is  still  one  of  the  most 

energy and emission-intensive countries in the EU, 
particularly  in  the  energy  and  manufacturing 
sectors (over 40% of total emissions are related to 
in  2022  are 
industry).  Rising  energy  prices 
affecting 
industry, 
particularly in energy-intensive ecosystem.  

competitiveness  of 

the 

Throughout  2022,  industrial  confidence  indicators 
have  been  the  lowest  in  the  EU,  as  managers’ 
assessments of the current level of overall orders 
and  the  production  trend  observed  in  recent 
months keep deteriorating. During the second half 
of  2022,  some  fertiliser  and  ceramics  firms  in 
Poland  have  already  announced  decreases  in 
production.  Although  supply  chain  issues  at  times 
affected 
(11%  of 
industrial  production  and  3.4%  of  GDP),  Poland’s 
diversified industrial base has diluted their impact. 
Poland  is  also  a  crucial  link  in  a  supply  chain  for 
several  critical  raw  materials,  especially  coking 
coal for steel-making processes (providing 24% of 
EU supply), copper, silver and elemental sulphur. 

the  automotive 

industry 

governance 

quality 
in 
Deterioration 
government 
including 
indicators, 
effectiveness and regulatory quality, has the 
potential to impact growth. Polish firms report 
more obstacles to climate investment than the EU 
average,  with  uncertainty  about  taxation  and 
regulation  cited  most  frequently (102).  Also,  the 
perceived  level  of  effectiveness  of  investment 
protection  by  the  law  and  courts  is  very  low 
among  companies (103).  Only  25%  of  companies 
are very or fairly confident that investment will be 
protected  effectively  in  Poland,  whereas  62%  of 
companies  are  either  fairly  unconfident  or  very 
unconfident (against a 39% EU average).  

The  main  reasons  invoked  by  companies  in  that 
respect  are  frequent  changes  in  legislation  or 
concerns  about  the  quality  of  the  law-making 
process, as well as unpredictable, non-transparent 
administrative  conduct  and  difficulty  to  challenge 
administrative decisions in courts. Concerns about 
the  quality,  efficiency  and  independence  of  the 
justice system also play a role in this respect. 

The  lack  of  adequate  public  consultation 
weighs  on  the  stability  and  predictability  of 
the  business  environment,  substantially 
lowers the quality of legislation, and hinders 

(101) EIB Investment Survey, Poland overview, 2022. 

(103) For more information please see: EU Justice Scoreboard. 

(102) EIB, European Firms and Climate Change 2020/2021, 2021. 

52 

0510152025303520082009201020112012201320142015201620172018201920202021PL BusinessPL GovernmentPL HouseholdsPL Total investmentEU-27 Total investmentHU Total investmentCZ Total investment 
 
   
                                                 
                                                 
 
 
already  low  investment.  Significant  reforms 
continue  to  be  frequently  adopted  by  by-passing 
procedures  that  require  adequate  consultation:  in 
2022, 21% of the laws passed were passed using 
the alternative track and 42% of the laws passed 
using the regular track had no documented public 
consultation (104).  

This inconsistency, together with a deterioration in 
the  quality  of  the  social  dialogue,  is  increasingly 
weighing on the quality of the resulting legislation 
and consequently on the business environment.  

The  Polish  Recovery  and  Resilience  Plan  (RRP) 
includes  some  reforms  to  strengthen  the  role  of 
consultations by the social partners and the role of 
public consultations in the legislative process, and 
to limit the use of fast-track procedures, with  the 
goal of having a better and more stable regulatory 
framework. 

Labour  productivity  growth  has  been  among 
the fastest in the EU for several years, but it 
is  still  substantially  lower than  in  the  EU  as 
a  whole.  Nominal  labour  productivity  per  hour 
worked  amounted  to  66.8%  of  the  EU  average  in 
2022 (see Graph A12.2). This difference in labour 
productivity is not only caused by lower efficiency 
of  production,  but  also  by  the  lower  value  of  the 
products  manufactured  (also,  according  to  the 
OECD,  the  gap  between  large  and  small  firms 
remains one of the largest in the EU).  

companies  also  matters 

Poland’s  exports  are  concentrated  in  lower  value-
added  agriculture,  textiles,  and  metals.  The  size 
for 
structure  of 
productivity:  in  Poland,  more  than  one-third  of 
employees work in micro companies (compared to 
only  one-fifth  in  Germany)  and  just  30%  of  the 
labour  force  is  employed  in  large  companies  with 
more than 250 employees (41% in Germany) (105). 

Access to finance has substantially improved 
in  Poland  in  the  last  years.  More  than  half  of 
firms in Poland (51%) had financed at least some 
of  their  investment  through  external  finance  (EU 
average:  45%),  with  bank  finance  the  most 

(104) Grant Thornton. Barometr prawa. Analiza stabilności 

otoczenia prawnego w polskiej gospodarce Edycja 2022, 
https://barometrprawa.pl/wp-
content/uploads/2022/03/Barometr-prawa-2022-RAPORT-
Grant-Thornton-16-03-2022.pdf. 

(105) World Bank, The Green Transformation in Poland, Country 

important  source  of  financing  for  around  80%  of 
Polish firms (106).  

Lack  of  creditworthiness  or  lack  of  collateral 
remained the reasons for potential  credit refusals 
in approximately 55% of cases. By mid-2022, loan 
growth  had  increased  by  27.6%  annually,  related 
to  a  rise  in  large  companies’  financing  needs  due 
to  fast  growth  in  prices  of  commodities  and 
production components.  

On  the  other  hand,  SMEs  are  starting  to  have 
some  financial  problems,  as  65%  of  Polish  SMEs 
have  experienced  late  payments  in  the  last  6 
months (see Table A12.1). Also, there was a sharp 
increase 
in  the  payment  gap  (the 
difference between payment terms and the actual 
payment)  in  both  business  and  public  sector 
transactions (see Table A12.1) (107).  

in  2022 

simplified 

introduction  of 

Although  the  number  of  bankruptcy  declarations 
decreased  by  28.7%  in  2021  and  7.2%  in  2022 
(thanks to public support during the pandemic and 
the 
restructuring 
proceedings), the solvency of Polish firms could be 
impacted  by  the  slowdown  in  Poland’s  external 
economic  environment,  heightened  exchange  rate 
volatility  and  the  lagging  effects  of  the  National 
Bank of Poland interest rate hikes, constraining the 
availability of credit and raising its cost. 

Graph A12.2: Nominal labour productivity per hour 
worked (EU=100) 

Source: Eurostat 

Tackling  structural  weaknesses, 
including 
restrictive  regulations  in  services  and  public 
procurement competitiveness, would improve 
productivity.  Poland´s  overall  performance  on 
public  procurement  is  below  the  EU  average: 
despite  expectations,  the  new  public  procurement 
law  that  entered  into  force  in  January  2021  did 

(106) EIB, Investment Survey, CESEE overview, 2023. 

Economic Memorandum, 2022. 

(107) 2022 European Payment Report, Intrum. 

53 

5055606570758085201120122013201420152016201720182019202020212022PolandCzechiaHungarySlovakia 
                                                 
   
                                                 
not  immediately  address  the  key  weaknesses  in 
public procurement in Poland.  

The public procurement system still suffers from a 
low  number  of  companies  submitting  tender 
offers,  resulting  in  a  high  share  of  single  offers, 
which  has  remained  for  years  at  an  exceptionally 
high level (52% in 2022).  

selected 

in 
  This 

Regulatory restrictiveness of regulated professions 
in  important  business  services  is  high  in  Poland, 
according  to  the  Commission’s  assessment  of 
restrictiveness 
professional 
services (108). 
is  notably  the  case  for 
architects,  civil  engineers,  tax  advisers,  lawyers 
and patent agents. As regards retail, the regulatory 
environment has been made stricter over the past 
years  with  the  introduction  of  a  retail  tax  and  a 
complete ban on shops opening on Sundays (109). 

Graph A12.3: Business environment and 
productivity drivers 

Source: 1) % of GDP, 2021 Eurostat;  
2) composite indicator, 2021 European Investment Fund 
access to finance index;  
3) average payment delay in number of days, 2022 Intrum;  
4) % of firms in manufacturing facing constraints, 2022 
European Commission business consumer survey;  
5) proportion of contracts awarded with a single bidder, 2022 
Single Market Scoreboard. 

(108) COM(2021) 385 final. 

(109) Retail Restrictiveness Indicator, European Commission (2022 

update), forthcoming. 

54 

1) Businessinvestments2) EIF access tofinance index3) Payment gap- G2B3) Payment gap- B2B4) Materialshortage4) Labourshortage5) Single bidsEuropean UnionPoland 
   
 
                                                 
Table A12.1: Industry and Single Market 

(1) last available year  
Source: (1) AMECO, (2) Eurostat, (3) ECFIN BCS, (4) Eurostat, (5) COMEXT and Commission calculations, (6) Eurostat, (7) Eurostat, 
(8) OECD, (9) Single Market Scoreboard, (10) EIB survey, (11) Eurostat: (12) Intrum, (13) SAFE Survey, (14) EIF SME Access to 
Finance Index 

55 

POLICY AREAINDICATOR NAME20182019202020212022EU27 average (*)Net private investment, level of private capital stock, net of depreciation, % GDP (1)55.64.43.93.93.7Net public investment, level of public capital stock, net of depreciation, % GDP (1)2.422.11.820.4Real labour productivity per person in industry (% yoy)(2)4.34.9-0.31.26.71.4Cost competitive-nessNominal unit labour cost in industry (% yoy)(2)1.83.32.45.82.22.9Material shortage (industry), firms facing constraints, % (3)13147203047Labour shortage using survey data (industry), firms facing constraints, % (3)677061636328Vacancy rate (business economy)(4)1.41.20.71.21.23.1Concentration in selected raw materials, Import concentration index based on a basket of critical raw materials (5)0.20.180.180.190.210.18Installed renewables electricity capacity, % of total electricity produced (6)20.721.220.522.1n.a.50.9Single Market integrationEU trade integration, % (7)36.135.735.139.242.245.8RestrictionsEEA Services Trade Restrictiveness Index (8)0.050.050.050.050.050.05Public procurement Single bids, % of total contractors (9)515151505229Investment obstaclesImpact of regulation on long-term investment, % of firms reporting business regulation as major obstacle (10)34.434.135.534.334.629.6Bankruptcies, Index (2015=100)(11)79.978.571.751.147.486.8Business registrations, Index (2015=100) (11)108.2105.192.1103.5108.3121.2Payment gap - corporates B2B, difference in days between offered and actual payment (12)5017101713Payment gap - public sector, difference in days between offered and actual payment (12)702082115Share of SMEs experiencing late payments in past 6 months, % (13)n.a.71.866.365.565.243EIF Access to finance index - Loan, Composite: SME external financing over last 6 months, index values between 0 and 1 (14)0.810.650.690.65n.a.0.46EIF Access to finance index - Equity, Composite: VC/GDP, IPO/GDP, SMEs using equity, index values between 0 and 1 (14)0.070.10.20.24n.a.0.23BUSINESS ENVIRONMENT - SMEsBusiness demographyLate paymentsAccess to financeHEADLINE INDICATORSEconomic StructureRESILIENCEShortagesStrategic dependenciesSINGLE MARKET 
 
   
 
ANNEX 13: PUBLIC ADMINISTRATION 

reforms. 

This  Annex  outlines  the  performance  of 
is 
Poland’s  public  administration,  which 
essential for providing services and carrying 
administrative 
out 
rank 
to 
effectiveness 
significantly  below  the  EU  average (110).  The 
downward trend may be linked to increasing levels 
of  politicisation  in  the  senior  civil  service  and  to 
the restructuring of the judiciary (111).  

Overall, 
in  Poland  continues 

is 

on 

and 

these 

frequent 

performance 

impact  assessments 

Poland’s 
regulatory 
governance  is  around  the  EU  average  (Graph 
A13.2). Recent changes aimed to strengthen public 
consultations  and 
for 
government  policy  proposals.  The  implementation 
of 
rather 
requirements,  however, 
formalistic, and their added value is diminished by 
changes 
over-regulation 
to 
legislation.  Almost  60%  of 
local  government 
officials give a poor assessment of the quality  of 
law  and  its  impact  on  the  functioning  of  local 
government.  Just  5%  consider  it  to  be  of  good 
quality.  The  vast  majority  claim  that  they  have 
difficulties  in  implementing  legal  changes  in  their 
offices (112). Parliament, which initiated about 21% 
of the laws passed between 2017 and 2020, does 
not  apply  the  regulatory  requirement  set  for  the 
public administration (113). The Polish recovery and 
resilience plan contains a set of actions to further 
improve  the  law-making  process  and  expand  the 
public’s input. 

The  scope  of  activities  of  Poland’s  Supreme 
Audit  Office  only  covers  part  of  the  typical 
tasks of an independent fiscal institution. For 
example,  it  does  not  cover  macroeconomic  or 
budgetary  forecasting.  Its  performance  on  the 
national  medium-term  budgetary  framework,  and 
the  strength  of  its  fiscal  rules  indices,  are  clearly 
below the EU average. 

Poland  continues  to  score  below  the  EU 
average  on  digital  public  administration 
(Graph A13.1 and Annex 10). The gaps concern the 
availability  of  public  services  for  citizens  and 
businesses  that  may  be  completed  online (114). 
Digitalisation  remains  one  of  the  key  priorities  of 
the government, with more than 21% of measures 
recovery  and 
resilience  plan 
in  Poland’s 
contributing 
transition.  These 
the  digital 
measures are expected to improve the delivery of 
public  services  and  speed  up  the  digitalisation  of 
the public administration. 

to 

Graph A13.1: Poland. E-government maturity and 
e-government users 

The  Polish  civil  service 
is  among  the 
youngest  in  the  EU.  The  share  of  public 
administration employees with higher education is 
among  the  highest  (Poland:  70.5%,  EU-27:  52%). 
The  negative  trend  in  gender  parity  in  senior  civil 
service  positions 
is  getting  worse,  with  the 
absolute difference between the share of men and 
women rising from 1.8% in 2017 to 12% in 2022.  

(110) Worldwide Governance Indicators, 2021.  

(111) Mazur S., Możdżeń M. and Oramus M. (2018). ‘The 

Instrumental and Ideological Politicisation of Senior Positions 
in Poland’s Civil Service and its Selected Consequences’. 
NISPAcee Journal of Public Administration and Policy, Vol.11 
(Issue 1), pp. 63-89. 

(112) ‘Legal and local government LEXOMETR 2022. Local 

government units in the era of crises’ 
(https://www.wolterskluwer.com/pl-
pl/solutions/informacje/lexometr-prawno-samorzadowy-
2022). 

(113) OECD, 2022, Better Regulation Practices across the European 

Union 2022 

(1) 2022 data for the e-government maturity indicator and 
2021 data for the e-government users indicator. 
Source: E-government benchmark report and Eurostat 

The  judicial  system  faces  challenges  to  its 
independence.  The  overall  performance  of 
ordinary  and  administrative  courts 
remains 
stable (115).  In  ordinary  courts,  while  the  time 

(114) Digital Economy and Society Index 2022 (https://digital-
strategy.ec.europa.eu/en/policies/countries-digitisation-
performance). 

(115) For a more detailed analysis of the performance of the 
justice system in Poland, see the 2023 EU Justice 
Scoreboard (forthcoming) and the country chapter for Poland 
in the 2023 Rule of Law Report (forthcoming). 

56 

0102030405060708090100UsercentricityTransparencyKey enablersCross-border servicesTotalE-government maturityE-govt.usersPLEU-27 
 
                                                 
   
                                                 
 
Table A13.1: Public administration indicators 

(1) High values denote a good performance, except for indicator # 6. (2) 2022 value. If not available, the 2021 value is shown. 
(3) Measures the user centricity and transparency of digital public services as well as the existence of key enablers for the 
provision of those services. (4) Defined as the absolute value of the difference between the percentage of men and women in 
senior civil service positions. Flags: (b) break in time series; (d) definition differs; (u) low reliability. 
Source:  ICT use survey, Eurostat (# 1); E-government benchmark report (# 2); Open data maturity report (# 3); Labour Force 
Survey, Eurostat (# 4, 5, 7), European Institute for Gender Equality (# 6); Fiscal Governance Database (# 8, 9); OECD Indicators of 
Regulatory Policy and Governance (# 10). 

needed to resolve civil, commercial, administrative 
and  other  cases  fell  from  110  days  in  2020  to 
107  days  in  2021,  an  opposite  trend  is  seen  in 
litigious  civil  and  commercial  cases,  with  an 
increase  from  317  days  on  average  in  2020  to 
330  days  in  2021.  The  overall  quality  of  the 
level  of 
is  good,  and 
justice  system 
digitalisation  is  advanced.  Gaps  remain  in  online 
the 
access 

judgments  and 

to  published 

the 

in 

judicial 

prosecution 

service.  Serious 

availability  of  electronic  communication  tools  in 
the 
concerns 
independence  persist  as 
regarding 
underlined  in  the  Commission’s  Rule  of  Law 
Reports.  Poland  also  committed  to  milestones 
related  to the independence of the judiciary in its 
recovery and resilience plan.  

Graph A13.2: Poland. a) Regulatory impact assessment, b) Stakeholder engagement and c) Ex post 
evaluation of legislation 

Source:  Indicators of Regulatory Policy and Governance Surveys 2017 and 2021, (http://oe.cd/ireg). 

57 

PL201720182019202020212022EU-27(2)139.544.849.349.554.7n/a64.82n/an/an/a58.054.962.272.93n/a0.70.80.91.01.00.8467.067.667.969.470.0 (b)70.552.057.311.4 (b)8.57.013.1 (b)18.816.961.84.89.69.69.612.011.073.13.13.23.13.1 (b)3.11.580.50.50.50.40.4n/a0.791.21.21.21.21.3n/a1.5101.72n/an/an/a1.76n/a1.7Medium term budgetary framework indexIndicator (1)E-government and open government dataShare of individuals who used the internet within the last year to interact with public authorities (%)E-government benchmark overall score (3) Open data and portal maturity indexEducational attainment level, adult learning, gender parity and ageingShare of public administration employees with tertiary education (levels 5-8, %)Participation rate of public administration employees in adult learning (%)Gender parity in senior civil service positions (4)Ratio of 25-49 to 50-64 year olds in NACE sector OPublic financial management Strength of fiscal rules indexEvidence-based policy makingRegulatory governance0.000.501.001.502.002.503.0000.511.522.53PL2017PL2021PL2017PL2021Primary lawsSecondary lawsb) Stakeholder engagement MethodologyOversightSystematic adoptionTransparencyEU-270.000.501.001.502.002.503.0000.511.522.53PL2017PL2021PL2017PL2021Primary lawsSecondary lawsc) Ex-postevaluation of legislationMethodologyOversightSystematic adoptionTransparencyEU-270.000.501.001.502.002.503.0000.511.522.53PL2017PL2021PL2017PL2021Primary lawsSecondary lawsa) Regulatory impact assessmentMethodologyOversightSystematic adoptionTransparencyEU-27 
 
 
   
 
     
FAIRNESS 
ANNEX 14: EMPLOYMENT, SKILLS AND SOCIAL POLICY CHALLENGES IN LIGHT OF 
THE EUROPEAN PILLAR OF SOCIAL RIGHTS  

The European Pillar of Social Rights is the compass 
for  upward  convergence  towards  better  working 
and living conditions in the EU. This Annex provides 
an overview of Poland’s progress in implementing 
the  Pillar’s  20  principles  and  EU  headline  and 
national  targets  for  2030  on  employment,  skills 
and poverty reduction. 

Table A14.1: Social Scoreboard for Poland 

average  of  74.9%.  The  unemployment 
rate 
decreased by 0.5 percentage points (pps) between 
2021  and  2022to  2.9%  and  remains  one  of  the 
in  the  EU  (EU:  5.9%) (116).  The  high 
lowest 
proportion of temporary contracts continues to be 
a challenge for the Polish labour market, with the 
share  still  higher  than  the  EU  average  (14.9%  vs 
13.5%  in  Q4-2022  for  people  aged  15-64)  and 
over one third of young people (aged 15-29) under 
such  contracts  in  Q4-2022  (34.2%,  which  was  in 
line  with  the  EU  average  of  34.6%) (117).  At  13%, 
the coverage of collective bargaining is one of the 
lowest  in  the  EU (118).  Social  dialogue  remains 
of 
unbalanced,  with 
involvement  of  social  partners  in  consultations  of 
legal acts. Poland reported the highest number of 
displaced  people  from  Ukraine  in  the  EU  with  1.5 
million (119)  registered.  Around  200 000  of  them 
are  working  at  present;  this  is  about  30%  of  the 
working-age  Ukrainians  who  have  arrived  (mostly 
women). 

insufficient 

quality 

Persons  with  disabilities,  women  and 
vulnerable groups continue to face obstacles 
to labour market participation. At 34.2 pps, the 
disability employment gap is one of the highest in 
the EU (EU average: 23 pps) and has been showing 
an  increasing  trend  in  recent  years.  The  activity 
rate  of  persons  with  disabilities  (around  50%)  is 
on the rise, but still well below the EU average of 
61.6% (120). The employment rate for women aged 
20-64  continued  to  grow,  and  in  2021,  it  was 
higher than the EU average for the first time since 
2012  (68.4%  vs  67.7%  in  the  EU)  and  it  rose 
further  to  70.2%  in  2022.  However,  the  gender 
employment  gap  (12.9  pps  in  2022)  remains 
above  the  EU  average  of  10.6  pps.  This  gap  is 
mainly due to the low employment rate of women 
aged  55-64  (44.6%  vs  56.3%  in  the  EU  in 
2022) (121). This is largely a result of the different 

(116) Source: Eurostat, online data codes: LFSI_EMP_Q, and 

UNE_RT_Q 

(117) Source: Eurostat, online data code: LFSQ_ETPGA 

(118) OECD and AIAS (2021), Institutional Characteristics of Trade 
Unions, Wage Setting, State Intervention and Social Pacts, 
OECD Publishing, Paris, OECD/AIAS ICTWSS database - OECD. 

(119) Social Insurance Institution (ZUS) data as of January 2023. 

(120) European comparative data on Europe 2020 and persons 
with disabilities - Publications Office of the EU (europa.eu) 

(121) Source: Eurostat, online data code: LFSI_EMP_A 

Update of 27 April 2023. Members States are classified on 
the Social Scoreboard according to a statistical methodology 
agreed with the EMCO and SPC Committees. It looks jointly at 
levels and changes of the indicators in comparison with the 
respective EU averages and classifies Member States in seven 
categories. For methodological details, please consult the 
Joint Employment Report 2023. Due to changes in the 
definition of the individuals' level of digital skills in 2021, 
exceptionally only levels are used in the assessment of this 
indicator.  
NEET: neither in employment nor in education and training; 
GDHI: gross disposable household income. 
Source: Eurostat 

The  Polish  labour  market  made  a  robust 
in  2022,  but  some  challenges 
recovery 
persist, 
risks  stemming  from 
including 
Russia’s  war  of  aggression  against  Ukraine. 
The  employment  rate  of  people  aged  20-64 
recovered  from  the  COVID-19  crisis,  reaching  a 
record  high  of  76.7%  in  2022,  above  the  EU 

58 

4.842.9310.912.94.0376.72.90.9146.3516.816.535.6534.25.717.22.7Critical situationTo watchWeak but improvingGood but to monitorOn averageDynamic labour markets and fair working conditionsEmployment rate(% of population aged 20-64, 2022)Unemployment rate(% of active population aged 15-74, 2022)Long term unemployment(% of active population aged 15-74, 2022)GDHI per capita growth                                                              (2008=100, 2021)Social protection and inclusionAt risk of poverty or social exclusion rate                                            (% of total population, 2021)At risk of poverty or social exclusion rate for children                       (% of population aged 0-17, 2021)Impact of social transfers (other than pensions) on poverty reduction (% reduction of AROP, 2021)Disability employment gap(percentage points, 2021)Housing cost overburden(% of total population, 2021)Children aged less than 3 years in formal childcare(% of population under 3-years-old, 2021)Self-reported unmet need for medical care(% of population 16+, 2021)Better than averageBest performersPolicy areaHeadline indicatorEqual opportunities and access to the labour marketEarly leavers from education and training(% of population aged 18-24, 2022)Share of individuals who have basic or above basic overall digital skills (% of population aged 16-74, 2021)Youth NEET rate(% of population aged 15-29, 2022)Gender employment gap(percentage points, 2022)Income quintile ratio(S80/S20, 2021) 
 
 
 
  
 
                                                 
 
(NEET) 

from  working 

statutory retirement ages for men (65 years)  and 
women  (60  years).  The  participation  of  children 
aged less than 3 years in formal childcare is much 
lower than the EU average (17.2% vs 36.2% in the 
EU).  However,  since  2020  the  rate  has  increased 
by  6 pps,  mainly  thanks  to  EU  funding.  In  Poland, 
76%  of  crèches  are  private,  which  results  in  high 
costs  for  parents (122).  The  social  allowances 
system  for  caregivers  of  persons  with  disabilities 
prevents  carers 
(while  being 
insufficient  to  avert  the  risk  of  poverty).  In  2022, 
the share of Polish young people not in education, 
(10.9%)  was 
employment  or  training 
slightly  below  the  EU  average  (11.7%) (123).  Youth 
unemployment remains low (6.8% vs 11.3% in the 
EU in 2022 in the age group 15-29) (124), reflecting 
the fact that the number of economically inactive 
young  people  within  the  NEET  group  has  been 
increasing. The employment rate of older workers, 
especially those with low skills, lags behind the EU 
average.  In  Poland,  older  people  aged  55  to  64 
make  up  more  than  32%  of  the  economically 
inactive  working-age  population 
(15-64  yrs, 
2021) (125).  The  European  Social  Fund  Plus  (ESF+) 
will  support  measures  to  improve  access  to 
for  young  people, 
employment,  particularly 
women,  older  people, 
long-term  unemployed 
people and other disadvantaged groups. Several of 
the  country’s  recovery  and  resilience  plan  (RRP) 
reforms  are  expected  to  be  adopted  in  2023  to 
improve 
and 
services. 
strengthen 
employment 
Addressing 
these  challenges  would  support 
progress  towards  the  national  employment  rate 
target of 78.3% by 2030. 

labour  market 

participation 

public 

for 

The low level of individuals’ digital skills and 
low  adult 
learning  participation  remain 
challenges  to  be  tackled,  which  is  also 
the  green  and  digital 
necessary 
transitions. Digital skills have improved in recent 
years,  but,  as  shown  in  the  EU  Digital  Economy 
and  Society  Index  (EU  DESI),  Poland  is  one  of  the 
EU countries with the lowest performance in terms 
of  digital  skills.  Only  43%  of  people  had  at  least 
basic  digital  skills  in  2021,  compared  to  54%  in 
the  EU.  Adult  participation  in  learning  (over  the 

past 4 weeks) is still far below the EU average of 
10.8%  despite  its  increase  from  4.8%  to  5.4% 
between  2019-2021.  The  RRP  and  the  ESF+  will 
support training measures to strengthen the green 
and digital transitions. 

Table A14.2: Situation of Poland on 2030 
employment, skills and poverty reduction targets 

(1) Adult Education Survey, adults in learning in the past 12 
months. 
(2) Number of persons at risk of poverty or social exclusion 
(AROPE), reference year 2019. 
Source: Eurostat, DG EMPL. 

Poland  is  experiencing  an  increase  in  labour 
shortages  and  skills  mismatches.  Labour 
shortages  as  reported  by  employers  increased 
rapidly  during  the  post-pandemic  recovery  and 
reached  levels  that  are  comparatively  high  in  the 
EU,  yet  do  not  exceed  pre-pandemic  levels.  On 
average, 
in  2021 81%  of  employers  had 
difficulties  filling  open  positions (126)  and  91%  of 
companies reported skills shortages, however 73% 
admitted  that  they  do  not  invest  in  skills (127) .  In 
2022, shortages started to taper off, while in Q4-
2022,  36%  of  employers  in  industry,  25%  in 
services  and  31%  in  construction  still  stated  that 
the availability of labour was a factor that limited 
production.  Macroeconomic  skills  mismatches 
improved in the last decade due to the increase in 
the  average  skills 
level  of  the  working-age 
population. In the 2021-2027 period, the ESF+ will 
reskilling 
upskilling 
support 
opportunities.  These  measures  will  contribute  to 
reaching  the  national  target  of  having  at  least 
51.7% of all adults participating in education and 
training every year by 2030. 

flexible 

and 

Social  indicators  in  Poland  are  still  broadly 
stable,  but  some  challenges  remain.  In  2021, 

(122) https://stat.gov.pl/obszary-tematyczne/dzieci-i-

rodzina/dzieci/zlobki-i-kluby-dzieciece-w-2020-roku,3.8.html 

(123) https://ec.europa.eu/eurostat/web/european-pillar-of-social-

rights/indicators/social-scoreboard-indicators  

(124) Source: Eurostat, online data code: UNE_RT_A   

(125) Source: Eurostat, online data code: LFSA_IGAN  

(126) ManpowerGroup Employment Outlook Survey Q3 2021 

Poland Results. 

(127) Dębkowska, K., Kłosiewicz-Górecka, U., Szymańska, A., 
Ważniewski, P., Zybertowicz, K. (2022), Kompetencje 
pracowników dziś i jutro, Polski Instytut Ekonomiczny, 
Warszawa, https://pie.net.pl/wp-
content/uploads/2022/04/Kompetencje-pracow-20.07.2022-
kopia.pdf 

59 

IndicatorsLatest dataTrend            (2015-2022)National target by 2030EU target by 203076.7(2022)20.9(2016)-283(2021)Adult learning1 (%)5260Employment (%)7878Poverty reduction2 (thousands)-1 500-15 000 
                                                 
 
   
 
                                                 
the  share  of  people  at  risk  of  poverty  or  social 
exclusion  in  the  total  population  (16.8%)  and 
children  (16.5%)  stood  below  the  EU  averages. 
However,  the  at-risk-of-poverty  rate  is  much 
higher  for  people  in  non-standard  forms  of  work 
(15.8%)  than  in  standard  forms  of  work  (4.1%). 
Material  and  social  deprivation  is  the  highest 
among  part-time  workers  and  self-employed 
people  (14.3%  vs  10.6%  in  the  EU).  Older  people 
are  at  a  slightly  higher  risk  of  poverty,  especially 
women  (22.1%  vs  13.2%  for  older  men).  A  fast 
ageing  population,  combined  with 
low 
statutory  and  effective  retirement  age,  will  likely 
cause  pension  benefits 
raising 
concerns  on  pension  adequacy,  especially  for 
women.  Further  social  policy  action  would  help 
Poland reach the national target of having at least 
1.5  million  fewer  people  at  risk  of  poverty  by 
2030. 

to  decrease, 

the 

care 

(LTC) 

system 

long-term 

is 
The 
inadequate  to  meet  the  needs  of  the  ageing 
population.  Quality  and  access  to  professional 
LTC remains very limited. The share of population 
aged 65 and over with LTC needs exceeds the EU 
average (35.9% vs 26.6% in the EU in 2019). The 
unmet needs for LTC are also high, with 46.7% of 
people  aged  65  and  over  reporting  a  lack  of 
assistance in personal care or household activities. 
Only  18.8%  of  the  population  aged  65  and  over 
with LTC needs use home-care services, compared 
to  28.6%  in  the  EU  in  2019.  Publicly  provided  or 
funded  home-care  services  for  the  population 
aged  65  and  over  are  also  below  the  EU  average 
(3.4%  vs  5.8%  in  the  EU  in  2019).  LTC  quality 
assurance  is  fragmented  between  the  healthcare 
and  social  sectors.  Public  spending  on  LTC  is 
among the lowest in the EU (0.8% vs 1.7% in the 
EU in 2019). Workforce levels and salaries are also 
low. In 2019, there were only 0.6 LTC workers per 
100 people aged 65 and over (OECD-32 average: 
5.2).  Poland  has  a  very  low  number  of  LTC  beds 
per  100  000  inhabitants  (194.4).  The  ESF+  will 
finance  training,  psychological  help  and  respite 
care for informal carers and support the provision 
of  home  and  community-based  LTC.  There  is  a 
further  need  to  assess  working  conditions,  skills 
informal 
requirements,  and  challenges  facing 
carers. 

60 

 
ANNEX 15: EDUCATION AND TRAINING 

This  Annex  outlines  the  main  challenges  for 
Poland’s education and training system in light of 
the  EU-level 
targets  and  other  contextual 
indicators  under  the  European  Education  Area 
strategic framework, based on the 2022 Education 
and Training Monitor. 

teaching  profession  has 

Teacher shortages are a major challenge (128). 
The 
faced  many 
challenges over the past years, leading to teacher 
demotivation  and  shortages  although  the  number 
of  students  was  also  falling  prior  to  2022 due to 
statistics (129) 
trends.  National 
demographic 
confirm  shortages  in  many  counties,  mainly  in 
large  cities,  and  among  teachers  of  vocational 
education  and  training  (VET),  early  childhood 
education  and  care  (ECEC),  science,  technology 
engineering and mathematics (STEM), and foreign 
languages,  and  teachers  with  a  background  in 
special needs education. Teacher salaries in Poland 
are among the lowest in the EU, in particular those 
teachers (130), (131),  and  are  not 
of  beginner 
attractive  to  young  graduates  in  Poland.  Around 
40%  of  teachers  are  50  or  older,  while  the 
proportion  of  those  below  30  ranges  from  less 
than 5% to 6%. 

Graph A15.1: Age profile of teachers in Poland 

Source: OECD statistics 

Local  governments 
in 
financing educational tasks, the major share 
of which constitute teacher salaries (132).  This 

face  difficulties 

(128) Supreme Audit (2022) Financing education by local 

governments. https://www.nik.gov.pl/aktualnosci/edukacja-i-
nauka/wciaz-za-malo-pieniedzy-na-szkoly-i-
przedszkola.html 

(129) https://barometrzawodow.pl/en/module/forecasts-on-maps;. 

(130) European Commission/EACEA/Eurydice, 2021. Teachers' and 
School Heads' Salaries and Allowances in Europe – 2019/20. 

(131) OECD (2022), Education at a Glance 2022: OECD indicators. 

https://doi.org/10.1787/3197152b-en  

(132) Supreme Audit (2022), Financing education by local 

governments. https://www.nik.gov.pl/aktualnosci/edukacja-i-
nauka/wciaz-za-malo-pieniedzy-na-szkoly-i-
przedszkola.html 

than 

leads  to  reduced  investments  in  both  educational 
infrastructure  and  extracurricular  activities.  The 
central  government  subsidy  for  education 
is 
increasing  more 
education 
slowly 
expenditure:  in  2021,  local  governments  covered 
almost  46%  of  spending  on  ECEC  and  school 
education, in contrast to 2012, when it was around 
20% (133).  Teacher  minimum  statutory  salary 
increases  in  2022  and  2023  (by  7.8%  from 
January) did not cover the increased cost of living 
and are below the growth in wages in the private 
sector.  The  Supreme  Audit  recommended  carrying 
out  an  in-depth  analysis  of  the  problems  and 
developing  a  comprehensive  approach  to  address 
teacher  supply  issues  and  the  needs  of  local 
governments in financing education. 

Participation of children in ECEC continues to 
increase,  but  some  provision  gaps  persist.  In 
2020, the rate reached 90.8%, up by 0.5 pps from 
2019.  The  participation  of  3-year-olds  (78.5%)  is 
still  below  the  EU  average.  The  rate  continues  to 
be  low  in  rural  areas,  where  provision  has  been 
insufficient,  and  in  some  regions  (Warminsko-
Mazurskie, Kujawsko-Pomorskie). 

education 

School 
facing  multiple 
is 
challenges, affecting the educational process 
and deepening inequalities. The Supreme Audit 
found negative impacts of remote teaching during 
the  pandemic  on  the  educational  process,  leading 
to  deepened  inequalities,  learning  losses,  and  a 
deterioration 
teacher  well-
in  student  and 
being (134). In addition to the challenges related to 
the  implementation  of  the  2016  reform,  upper 
secondary  schools,  mainly  in  cities,  struggle  with 
overcrowding  due  to  an  increased  cohort,  by 
around  50%,  of  primary  school  graduates  in 
2022/23.  Also 
in  2022/23,  almost  188.000 
displaced  children  from  Ukraine  are  enrolled  in 
kindergartens  and  schools,  however,  still  around 
55% of school-aged children from Ukraine remain 
outside 
system. 
Stakeholders and  the  Ombudsman (135)  indicate  a 

schooling 

Polish 

the 

(133) https://stat.gov.pl/en/topics/education/education/education-

in-the-20212022-school-year,1,18.html 

(134) Supreme Audit (2022), Schools in pandemic times. 

https://www.nik.gov.pl/aktualnosci/edukacja-i-nauka/szkoly-
w-czasach-pandemii.html 

(135) Centre for Civic Education, 2022. https://ceo.org.pl/wp-

content/uploads/2022/11/CEO_uczniowie_uchodzczy_pazdzi
ernik_2022-fin-1.pdf; The Ombudsman, 2022.  
https://bip.brpo.gov.pl/pl/content/rpo-edukacja-ukraina-dzieci-
rekomendacje-mein-odpowiedz 

61 

0%10%20%30%40%50%60%70%80%90%100%tertiarysecondaryprimaryunder 3030-39 years40-49 years50 and over 
 
  
                                                 
                                                 
 
Table A15.1:EU-level targets and other contextual indicators under the European Education Area 
strategic framework 

Source: (1,3,4,5,7,8,9,10,11) = Eurostat; 2 = OECD (PISA); 6 = European Commission (Joint Research Centre).  Notes: Data is not 
yet available for the remaining EU-level targets under the European Education Area strategic framework, covering 
underachievement in digital skills and participation of adults in learning. The equity indicator shows the gap in the share of 
underachievement in reading, mathematics and science (combined) among 15-year-olds between the lowest and highest quarters 
of socio-economic status. 

need  for  better  systemic  solutions,  in  particular 
support for teachers. 

Poland’s  tertiary  educational  attainment 
rate  has  dropped  below  the  EU  average;  the 
higher education institutions (HEI) evaluation 
process  needs  improvement.  In  2022,  the 
tertiary  educational  attainment  rate  of  people 
aged 25-34 was 40.5% (EU 42%), similar to 2021 
(40.6%), but lower by 1.9 pps compared with 2020 
and  3  pps  compared  with  2019.  The  reasons  for 
the decrease are not clear. In 2020, the proportion 
of STEM graduates fell to 19.4% (EU 24.9%). The 
proportion of graduates in natural sciences, maths 
and statistics is particularly low at 3.2% (EU 6.2%), 
and that of ICT graduates is slightly below the EU 
average (3.7% vs 3.9%); this is expected to hinder 
innovation  potential  of 
the 
Poland (136). The first evaluation of HEIs resulted in 
disproportionally better results for small HEIs in a 
specific  discipline,  or  those  with  new  faculties, 

research  and 

(136) For more information, see Annex 11, innovation. 

than  for  the  more  experienced  institutions (137), 
which 
process 
reliability (138). 

evaluation 

questions 

the 

Poland plans to develop a digital strategy for 
schools  and  digital  competences;  higher 
education  is  not  digital-ready.  A  digital  divide 
among  students  and  teachers  continues,  and 
teachers  still  lack  training  in  digital  teaching 
methods (139).  In  its  recovery  and  resilience  plan, 
Poland  adopted  a  national  digital  competence 
programme, including training of teachers, and, for 
it  plans  to  develop  a  digitalisation 
schools, 
ICT 
strategy  and  minimum  standards 
equipment.  However,  HEIs  also  lack  sufficient  ICT 
infrastructure  and  skills  for  online  teaching  and 

for 

(137) https://serwisy.gazetaprawna.pl/edukacja/arty 

kuly/8511517,edukacja-uczelnie-ewaluacja-zastrzezenia-
ocena-dzialalnosci.html 

(138) https://oko.press/ewaluacja-nauki-to-porazka-jej-wyniki-nic-

nie-mowia-i-nikomu-nie-sa-potrzebne-wywiad/ 

(139) Supreme Audit (2022), Schools in pandemic times. 

https://www.nik.gov.pl/aktualnosci/edukacja-i-nauka/szkoly-
w-czasach-pandemii.html  

62 

 
                                                 
                                                 
 
  
 
working,  and  a  concept  for  developing  and  using 
digital educational materials in HEIs (140). 

(140) Supreme Audit (2022), Digital Poland? A long way to go. 

https://www.nik.gov.pl/aktualnosci/kompetencje-cyfrowe.html  

63 

 
                                                 
ANNEX 16: HEALTH AND HEALTH SYSTEMS 

A  healthy  population  and  an  effective, 
accessible  and  resilient  health  system  are 
prerequisites  for  a sustainable  economy and 
society.  This  Annex  provides  a  snapshot  of 
population health and the health system in Poland.  

Life  expectancy  in  Poland  is  among  the 
lowest in the EU and in 2021, it fell back to 
the  level  of  13  years  earlier.  This  reflects  the 
increase  in  COVID-19  mortality  in  2021,  (more 
than a doubling compered to 2020 (141)). Mortality 
per  100 000  population  from  preventable  causes 
(deaths that can be mainly avoided through public 
health  and  primary  prevention  measures)  (222, 
versus  160  for  the  EU  overall)  and  treatable 
causes  (144,  versus  92  for  the  EU  overall)  is 
higher  than  the  EU  average.  Diseases  of  the 
circulatory  system  and  cancer  were  the  main 
causes of death before the pandemic, but COVID-
19  has  accounted  for  a  substantial  share  of 
deaths in recent years. 

Graph A16.1: Life expectancy at birth, years 

EU countries in which the share of preventive care 
in total healthcare expenditure decreased between 
2019  (2.1%)  and  2020  (1.9%).  Across  the  EU, 
overall  spending  on  prevention  increased  by  26% 
on average, mostly driven by spending on disease 
response 
detection,  surveillance,  control  and 
programmes as part of the public health response 
to COVID-19.  

is 
The  public  share  of  health  spending 
comparatively  low  (72.3%  in  2020  versus 
81.2%  for  the  EU  overall).  Household  out-of-
pocket  payments  are  relatively  high  (19.6%, 
versus  14.4%  for  the  EU  overall).  Public  spending 
on  health  is  projected  to  increase  by  2.6  pps  of 
GDP  by  2070  (compared  to  0.9  pps  for  the  EU 
overall),  due  to  demographic  pressures  and  a 
substantial increase in public spending from 4.9% 
of GDP in 2019 to 6.0% in 2025 (see Annex 21). 

Graph A16.2: Projected increase in public 
expenditure on healthcare over 2019-2070 

Source: Eurostat 

AWG reference scenario 
Source: European Commission / EPC (2021) 

Health spending  relative  to  GDP  in  Poland  is 
among the lowest in the EU. This said, in 2020, 
total  healthcare  spending  increased  to  6.5%  of 
GDP.  This  is  in  line  with  the  upward  trend  in  all 
Member States in 2020. In Poland, this increase is 
fully  explained  by  the  GDP  contraction  observed 
(by  2%,  compared  to  5.7%  in  the  EU  overall),  as 
nominal  annual  healthcare  spending  moderately 
decreased  from  EUR  34.4  billion  to  EUR  34.1 
billion.  This  is  also  corroborated  by  the  fact  that, 
as  a  share  of  total  public  spending,  health 
spending  decreased  by  0.6  percentage  points 
(pps). 

Spending on prevention decreased, bucking a 
trend  for  increasing  budgets  observed  in  all 
other Member States.  Poland is one of the few 

(141) Based on data provided directly by Member States to ECDC 
under the European Surveillance System (data current as of 
13 April 2023) 

64 

78.077.877.778.076.575.580.980.981.081.380.480.1201620172018201920202021PolandEU6.64.90.92.602468EUPoland% of GDP20192070increase 
 
      
                                                 
     
 
 
Table A16.1: Key health indicators 

Note:  The EU average is weighted for all indicators, except for (*) and (**), for which the EU simple average is used. The simple 
average for (*) uses data for 2020 or most recent year if former not available. Doctors' density data refer to practising doctors in 
all countries except EL, PT (licensed to practice) and SK (professionally active). Nurses' density data refer to practising nurses in all 
countries except FR, PT, SK (professionally active) and EL (nurses working in hospitals only). 
Source: Eurostat; except: ** ECDC 

Poland has the lowest number of doctors and 
nurses in the EU (per 1 000 population), with 
an  ever-increasing  share  of  health  staff  in 
the  higher  age  brackets.  According  to  the 
National Statistical Office, in 2021, the number of 
doctors  and  nurses licensed  to  practice, increased 
in  absolute  terms  compared  to  the  previous  year, 
by 4 063 and 5 300, respectively (142). In 2021, all 
age  groups  of  doctors  saw  a  nominal  increase  in 
numbers  except  the  group  of  40-49  years.  As  in 
previous  years,  those  aged  between  50  and  59 
were  the  most  numerous  group  (almost  32 000), 
accounting  for  20.6%  of  the  total  number  of 
doctors licensed to practice (21.1% in 2020). On a 
positive  note,  with  a  difference  of  3 300,  the 
highest  increase  occurred  in  those  aged  up  to  29 
years. In 2021, this group accounted for 11.7% of 
the  total  of  doctors  licensed  to  practice,  up  from 
9.8%  the  previous  year.  In  2021,  the  number  of 
nurses of doctors licensed to practice increased by 
5 300 to 305 800, with 61% being over 50 years 
old. 

Under  the  Recovery  and  Resilience  Facility, 
Poland  is  using  both  grants  and  loans  for 
investments  in  health,  worth  a  total  of  EUR 
4.2  billion  (12%  of  the  total  budget).  Under 
the  grant  component,  Poland  is  proposing  three 
reforms  (with  four  subsequent  investments).  The 
first  reform  introduces  comprehensive  measures 
to  restructure  public  hospitals.  The  second  reform 
the  match  between  needs  and 
improves 
availability of medical professionals in Poland. The 
third reform improves the quality and efficiency of 
the healthcare system by supporting research and 
development  in  the  medical  and  health  fields. 

Under  the  loan  component,  Poland  is  proposing 
two  reforms  (with  two  subsequent  investments). 
The  first  reform  is  to  support  the  transformation 
of  district  hospitals  into  long-term  care  and 
geriatric  care  units  or  centres.  The  second  reform 
is  to  introduce  a  regulatory  framework  to  help 
attract  the  production  of  medicines  and  active 
pharmaceutical substances to Poland and increase 
this production. 

care  accounts 

Costly  hospital 
for  a 
disproportionate  share  in  total  expenditure, 
with  a  weak  primary  care  system  and  high 
unmet  health  needs.  In  2020,  there  was  a 
decrease in the number of outpatient clinics and a 
decrease  in  the  number  of  medical  practices  that 
provided  advice  under  a  contract  signed  directly 
with the Narodowy Fundusz Zdrowia (the national 
health  fund).  There  were  44  million  (15%)  fewer 
visits  than  in  the  previous  year (143).  However, 
actions  are  being  taken  to  strengthen  the  role  of 
primary care in the health care system. In October 
2022, regulations introducing coordinated care for 
the most common diseases and improving access 
to a specialist doctor came into force. 

The low proportion of hospitals that use electronic 
health  records  (10%)  and  the  low  proportion  of 
primary  care  centres  (30%)  further  hamper  the 
integration of care provision. 

(142) 

See: Statistics Poland / Topics / Health / Health / 

(143) See: Statistics Poland / Topics / Health / Health / Outpatient 

Outpatient health care in 2021. 

health care in 2021. 

65 

20172018201920202021EU average (latest year) Treatable mortality per 100 000 population (mortality avoidable through optimal quality healthcare)132.0133.1133.7144.2NA91.7 (2020)Cancer mortality per 100 000 population290.5291.2283.4279.7NA242.2 (2020)Current expenditure on health, % GDP 6.66.36.56.5NA10.9 (2020)Public share of health expenditure, % of current health expenditure69.371.571.872.3NA81.2 (2020)Spending on prevention, % of current health expenditure 2.42.32.11.9NA3.4 (2020)Acute care beds per 100 000 population485473435437NA387.4 (2019)Doctors per 1 000 population *2.4NANANANA3.9 (2020)Nurses per 1 000 population *5.1NANANANA8.3 (2020)Consumption of antibacterials for systemic use in the community, daily defined dose per 1 000 inhabitants per day (total consumption in CY and CZ) **23.823.022.217.118.814.5 (2021) 
                                                 
                                                 
 
   
 
ANNEX 17: ECONOMIC AND SOCIAL PERFORMANCE AT REGIONAL LEVEL 

This  Annex  showcases  the  economic  and 
social  regional  dynamics  in  Poland  providing 
an  update  on  the  economic,  social  and  territorial 
cohesion  in  the  Polish  regions  compared  with  the 
EU  as  a  whole  and  the  main  regional  economic 
recovery challenges.  

Regional disparities in Poland have remained 
high in last years. However, convergence on the 
EU average has continued. Internal convergence in 
2011-2020  was  hampered  by  the  relatively 
sluggish growth in the less developed regions (144). 
At  the  extreme,  the  average  annual  real  GDP  per 
capita  growth  rate  was  lowest  in  Świętokrzyskie, 
Warmińsko-Mazurskie  and  Lubuskie  all  below 
2.9%  of  the  country  average   (145)  (Graph  A17.1), 
the  EU  average  has 
but  convergence  on 
continued (146).  All  Poland's  regions  had  a  higher 
average annual real GDP per capita increase than 
the EU as a whole. 

Graph A17.1: GDP (PPS) per capita (2010) and GDP 
growth (2010-2020) in Poland 

(1) Bubble sizes correspond to population size 
Source: EUROSTAT, DG REGIO elaboration 

Regional disparities are driven by the labour 
productivity  gaps  within  the  country.  Labour 
productivity,  measured  as  gross  value  added  per 
person  employed,  stands  at  80%  of  the  EU 
average. In the capital city region, productivity was 
139%  of  the  EU  average,  while  it  was  below  the 
EU  average  in  all  other  regions.  It  was  lowest  at 
57-62% in the least developed regions (Lubelskie, 

(144) The terms ‘Less/least developed’ and ‘more/most developed’ 
are comparisons between Poland's regions. These terms 
should not be confused with the classification for cohesion 
policy funds eligibility criteria. 

(145) The lowest growth was in Świętokrzyskie (2.3%), Warmińsko-

Mazurskie (2.4%) and Lubuskie (2.5%). 

(146) GDP per capita was as follows: Lubelskie (52%), 

Podkarpackie (53%), Warmińsko-Mazurskie (54%), 
Świętokrzyskie (55%) and Podlaskie (56%).  

Świętokrzyskie, 
Podkarpackie and Podlaskie (147)). 

Warmińsko-Mazurskie, 

Map A17.1:  Poland GDP per capita (PPS) by NUTS 2 
region, 2020 

All  Polish  regions  except  the  capital  region 
rank  below  the  EU  average  in  terms  of 
competitiveness   (148).  According  to  the 
last 
edition of the Regional Competitiveness Index, the 
competitiveness  of  the  Warsaw  region  is  at 
118.8%  of  the  EU  average.  The  second  most 
competitive region (Slaskie)  is at 96.9% while  the 
least  competitive  one 
(Warmińsko-mazurskie) 
bottoms at 75.8%.  

(147) Labour productivity was as follows: Lubelskie (57%), 
Świętokrzyskie (58%), Warmińsko-Mazurskie (61%), 
Podkarpackie (61%) and Podlaskie (62%).  

(148) 

2022 Regional Competitiveness Index. 

66 

LubuskieWarmińsko-mazurskieŚwiętokrzyskieLubelskiePodkarpackiePodlaskie0.00.51.01.52.02.53.03.54.030507090110130150Annual real GDP per head growth2011-2020 (average % change on the preceding year)GDP (PPS) per head in 2010 (EU = 100)Capital regionOther NUTS2 regionsNational averageEU27 
 
  
                                                 
 
 
 
 
 
                                                 
 
 
Table A17.1: Selected indicators at regional level - Poland 

Source: EUROSTAT 

in 

Regional  disparities 
labour  market 
conditions  remained  high  in  2021.  The  labour 
market  was  stronger  than  in  the  EU  as  a  whole 
and  only  Podkarpackie  had  an  employment  rate 
below  the  EU  average  (68%  versus  73%).  The 
employment  rate  ranged  from  84% in  the  capital 
region to less than the national  average (75%) in 
several regions, including the less developed ones 
(Podkarpackie, 
and 
Lubelskie (149)).  The  unemployment  rate,  which  is 
very  low  in  Poland,  was  lowest  at  2-2.1%  in  the 
Lubuskie and capital regions and was 5.1% in the 
least developed Lubelskie region   (150).  

Warmińsko-Mazurskie 

ranged  from  -0.1%  in  Podlaskie  to  -1.7%  in 
Lubelskie,  although  Podkarpackie  suffered  a 
severe economic drop of -5.5%. 

Unemployment 

The  labour  market  was  resilient  during  the 
COVID-19 pandemic, but the downward trend 
in  some 
in  unemployment  has  reversed 
regions. 
in 
Wielkopolskie,  Opolskie,  Pomorskie,  Lubelskie, 
Podkarpackie and Mazowiecki Regionalny between 
2019 and 2021, while the rate increased most (by 
0.4-0.7  percentage  points) 
in  Małopolskie, 
Kujawsko-Pomorskie,  Śląskie,  Dolnośląskie  and 
Łódzkie.  

decreased 

The  COVID-19  pandemic  caused  the  first 
economic recession in three decades, and the 
economic  fallout  was  distributed  unequally. 
Between 2019 and 2020, GDP per capita dropped 
in  all  Polish  regions  except  Łódzkie  (+1.3%).  The 
impact of the pandemic was particularly severe in 
some  populated  and  prosperous  regions 
like 
Warszawski Stołeczny (-4.7%), Śląskie (-5.5%) and 
Pomorskie  (-4.6%).  It  was  much  milder  in  less 
developed regions, where the fall in GDP per capita 

(149) Podkarpackie (68%), Warmińsko-Mazurskie (73%), 

Lubelskie (73%), Świętokrzyskie (74%) were some of the 
regions with the lowest employment rate (aged 20-64), 
while it reached 76% in the Podlaskie region. 

(150) The unemployment rate was as follows: Lubelskie (5.1%), 
Podkarpackie (4.8%), Świętokrzyskie (4.4%), Warmińsko-
Mazurskie (3.5%) and Podlaskie (3.1%). The national average 
was 3.4%. 

The  social  situation  did  not  deteriorate 
during  the  pandemic  in  most  regions,  but 
high  regional  disparities  in  povery  persist. 
Around a quarter of the population in some of the 
less  developed  regions  (Lubelskie,  Warmińsko-
Mazurskie  and  Podlaskie)  remained  at  risk  of 
poverty or social exclusion (AROPE) in 2021, while 
the  rate  was  below  13%  in  Śląskie,  Pomorskie, 
Dolnośląskie and Warszawski Stołeczny.  

The  large  inflow  of  displaced  people  from 
Ukraine increased demand for public services 
and  housing.  This  created  fiscal  pressures  in the 
short  term including  on  local  government but has 
also  contributed  to  increased  consumption (151).  In 

(151) Source: the World Bank, 2022, EU Regular Economic Report: 
Living up to Potential in the Wake of Adverse Shocks. 

67 

Region NameGDP per head (PPS)Productivity (GVA (PPS) per person employed)Real productivity growthGDP per head growthUnemployment rateR&D expenditureAt risk of poverty or social exclusionRegional Competitiveness Index (RCI)GHG emissionsIndex, EU27 = 100, 2021Index, EU27 = 100, 2020Average % change on the preceding year, 2011-2020Average % change on the preceding year, 2011-2020% of active population, 2021% of GDP, 2019% of population, 2020Index - values range between 0 and 100, 2022tCO2 equivalent per head, 2021European Union100.0100.00.20.67.02.316.6100.07.2Poland77.080.12.33.03.41.317.088.710.9Małopolskie71.073.01.93.23.22.215.194.39.7Śląskie79.083.11.92.52.90.911.496.915.5Wielkopolskie83.082.41.73.32.20.818.184.88.9Zachodniopomorskie64.071.20.32.53.50.615.082.110.4Lubuskie62.068.92.62.52.00.514.282.17.4Dolnośląskie86.089.41.92.94.01.212.789.19.3Opolskie62.070.71.42.52.70.516.383.522.9Kujawsko-Pomorskie62.066.51.32.64.40.719.782.110.8Warmińsko-Mazurskie54.060.61.92.43.50.824.275.87.7Pomorskie75.076.40.92.92.31.712.490.48.5Łódzkie73.073.03.93.44.41.016.486.115.1Świętokrzyskie55.058.23.42.34.40.517.276.712.6Lubelskie52.057.13.72.75.11.126.079.010.9Podkarpackie53.060.82.72.64.81.222.082.77.6Podlaskie56.061.52.42.93.10.824.278.89.9Warszawski Stołeczny166.0138.61.22.92.12.612.8118.85.3Mazowiecki Regionalny67.075.94.03.03.80.524.080.315.4 
                                                 
                                                 
 
  
 
January  2023,  1 515 194  refugees  from  Ukraine 
had registered for temporary protection in Poland, 
mostly  in  Małopolskie,  Mazowieckie,  Dolnośląskie. 
Educational  assistance  is  crucial  for  refugees. 
191 150 
refugee  pupils  from  Ukraine  were 
registered at schools and assigned to primary and 
preparatory  classes  in  Polish  regions,  mostly  in 
Mazowieckie,  Śląskie  and  Dolnośląskie (152).    Civil 
society  has  been  playing  a  significant  role  in 
assisting  the  displaced  persons  fleeing the  war  in 
Ukraine.  

(152) Source: the UN Refugee Agency, 2022, refugees from 

Ukraine registered in Poland by district. 

68 

 
                                                 
MACROECONOMIC STABILITY 
ANNEX 18: KEY FINANCIAL SECTOR DEVELOPMENTS 

Polish  banks  have  a  solid  business  profile 
with limited foreign exposure. With total assets 
equivalent  to  the  country’s  economic  output, 
Poland’s  banking  sector  is  one  of  the  largest  in 
central and eastern Europe and by far the largest 
component  of  the  Polish  financial  sector.  Polish 
banks are a strong pillar of the economy and have 
been  critical  in  supporting  the  country’s  rapid 
economic  growth  in  recent  years.  The  sector  is 
mostly Polish owned, with 56.4% of total banking-
sector  assets  controlled  through  Polish  investors, 
mostly  the  Polish  state.  Local  lenders  are  well 
diversified  and  highly  competitive  –  the  top  five 
lenders  hold  some  57%  of  total  banking-sector 
assets.  Notwithstanding  some  efforts  to  expand 
internationally,  the  sector  has  a  very  limited 
footprint abroad. 

interest 

tightening  has 

loans  at  variable 

The  banking  system  shows  strong  resilience 
but  faces  multiple  challenges.  The  banking 
sector  has  recovered  rapidly  from  the  pandemic, 
buoyed  by  strong  GDP  growth  in  2021  and  early 
2022.  More  recently,  and  given  the  prevalence  in 
Poland  of 
rates, 
monetary-policy 
significantly 
improved the sector’s profitability. However, rising 
interest  rates  have  also  brought  a  sizeable 
increase  in  borrowing  costs  and  considerably 
increased  credit  risk  for  lenders  in  a  context  of 
high 
inflation  and  slowing  economic  growth. 
Moreover, as in previous years, many local lenders 
continue  to  face  significant  legal  risks  associated 
with the legacy portfolio of mortgage loans issued 
in  foreign  currencies.  Polish  lenders  have  built 
substantial  provisions  for  these  mortgages,  and 
proactively  started  various  voluntary  settlement 
programmes  for  foreign-currency  borrowers.  But 
despite  this,  legacy  foreign-currency  mortgages 
will continue to fuel uncertainty. Additionally, wary 
of  the  rapidly  rising  credit  costs  and  repayment 
burden  faced  by  borrowers,  Polish  authorities 
legislated  in  mid-2022  for  a  ‘credit  holiday’  on 
Polish-zloty  mortgage 
loans.  The  bill  allows 
borrowers  to  postpone  up  to  eight  mortgage 
instalments over 2022-2023. The aggregate costs 
(exclusively  born  by  banks)  will  ultimately  depend 
on  uptake,  but  they  are  bound  to  have  a  sizeable 
impact  on 
sector’s  profitability.  Non-
performing  loans  (NPL)  remain  higher  than  the 
European  average  (4.6%  and  1.8%  respectively) 
but have been trending down since 2017.  

the 

cost  of 

Credit growth is faltering as monetary policy 
normalises.  The  central  bank  of  Poland  has 
embarked  on  a  campaign  to  rapidly  tighten 
monetary policy to combat rapidly rising inflation. 
Higher  interest  rates  have  severely  depressed 
demand for credit. Factors such as uncertainty, the 
rising 
the  worsening 
living,  and 
macroeconomic outlook have also played  a major 
role  in  depressing  demand.  Moreover,  stricter 
supervisory  requirements  by  the  Polish  Financial 
Supervision  Authority  have  affected  the  way  in 
which lenders assess clients’ creditworthiness, and 
this has weighed on mortgage lending. In contrast, 
corporate  lending  (mostly  current-account  and 
working-capital  loans),  remained  robust  for  most 
of  2022.  As  firms  returned  to  their  regular 
operations and public pandemic-aid schemes were 
discontinued,  financing  lines  had  to  be  replaced, 
mainly  through  the  use  of  corporate  credit. 
Nonetheless,  despite  robust  GDP  growth,  the 
annualised  growth  rate  of  private-sector  credit 
started  declining  by  mid-2022,  weighed  down  by 
declines  in  household  credit.  The  mortgage-credit 
segment was particularly affected. Poland’s Credit 
Bureau  reported  that  the  number  of  submitted 
applications  for  mortgage 
in 
December  2022  by  over  60%  year-on-year,  and 
was  negative  for  every  single  month  since  the 
beginning of 2022. 

loans  declined 

Graph A18.1: Credit growth 

Source: ECB. 

69 

-10-505101520Total privateNFCHH% 
 
 
  
 
 
 
Table A18.1: Financial soundness indicators 

(1) Last data: Q3 2022. 
(2) Data is annualized. 
Source: ECB, Eurostat, S&P Global Capital IQ Pro 
Source:  

Legal  risks  remain  elevated  as  borrowers 
challenge the validity of legacy loans issued 
in foreign currencies. Over a decade after Polish 
banks  stopped  issuing  Swiss-franc-denominated 
mortgages,  these  legacy  loans  continue  to  create 
financial  stability  risks.  Following  a  set  of  rulings 
favourable  to  Swiss-franc  borrowers  from  the 
Court of Justice of the European Union (CJEU), an 
increasing  number  of  borrowers  are  now 
challenging the validity of their loan agreements in 
Polish 
citing 
courts.  These  borrowers  are 
essentially  the  abusiveness  of  the  indexation 
clauses  embedded 
these  contracts.  The 
remaining  portfolio  is  of  reasonably  high  quality 
and relatively small (worth some PLN 50 bn (EUR 
10.75  bn)by  end-2022,  equivalent  to  about  12% 
of  the  outstanding  value  of  mortgage  loans). 
Nevertheless,  the  legal  risk  associated  with  these 
loans  remains  a  major  financial-stability  risk.  The 
costs  generated  by  this  risk  (mainly  through 
provisions)  will  remain  elevated  over  the  coming 
months  as  banks  need  to  factor  in  various 
outcomes.  This  includes  tail  risks  that  could 
materialise if court rulings are highly unfavourable 
to the banks. In this context, guidance by the CJEU 
will be critically important. 

in 

remains  adequate  but 

lower 
Solvency 
profitability  may 
impact  banks’  capital 
positions. Soundness indicators remain overall at 
safe  levels  and  indicate  that  Polish  banks  are 
conservatively  and  prudently  managing  various 
incoming  risks.  Capital  ratios  were  adversely 
impacted by the decline in the balance-sheet value 
of  government  bonds  (affected  by  the  rising 

70 

intermediate  MREL 

interest rates) in 2022 as well as the phasing in of 
the 
target.  Funding  and 
liquidity  are  solid  and  well  above  regulatory 
minima, and banks are efficient overall with strong 
operational  profitability.  Nevertheless,  banks’ 
financial  results  –  and  therefore  their  capital-
generation  capacity  –  will  come  under  pressure 
from:  (i)  the  large  provisions  for  legacy  foreign-
currency loans; (ii) losses induced by the mortgage 
repayment  holiday;  and  (iii)  the  expected  heavier 
provisioning  for  future  credit  risk,  mainly  in  the 
corporate  and  consumer  loan  segments,  the  two 
segments  heavily  affected  by  the  rapid  rise  in 
interest rates. Lastly, in the current higher interest 
rate  context,  funding  is  also  set  to  become  more 
expensive. 

insurance  sector 

The 
is  coming  under 
pressure.  Domestic  insurers  are  largely  well 
capitalised and are highly solvent according to the 
solvency capital requirement data. They also have 
good  overall  profitability.  Nevertheless, 
the 
resilience  of  local  insurers  can  be  somewhat 
the  unusually  high 
to 
overestimated  due 
proportion  of  expected  profits  included  in  future 
premiums  and  the  double  gearing  of  capital. 
Moreover, the performance of the insurance sector 
may be challenged in the future by: (i) inflation at 
multi-decade  highs  biting  into  households'  real 
disposable  income;  (ii)  large  foreign-exchange 
movements; and (iii) rising operating costs.  

201720182019202020212022EUMedianTotal assets of the banking sector (% of GDP)95.592.592.3102.1100.792.8276.8207.9Share (total assets) of the five largest banks (%)47.549.549.854.356.6--68.7Share (total assets) of domestic credit institutions (%)154.853.354.056.657.456.6-60.2NFC credit growth (year-on-year % change)8.66.62.9-6.44.59.6-9.1HH credit growth (year-on-year % change)6.45.66.51.55.0-4.4-5.4Financial soundness indicators:1        - non-performing loans (% of total loans)6.66.26.16.05.04.61.81.8- capital adequacy ratio (%)18.017.917.819.617.917.018.619.8- return on equity (%)26.97.06.93.14.84.56.16.6Cost-to-income ratio (%)157.256.756.054.254.548.660.651.8Loan-to-deposit ratio (%)193.793.291.980.377.478.088.678.0Central bank liquidity as % of liabilities0.00.40.00.00.00.0-2.9Private sector debt (% of GDP)77.376.774.276.171.4--120.7Long-term interest rate spread versus Bund (basis points)310.3280.2260.0200.8232.0491.2-93.3Market funding ratio (%)48.045.744.648.047.8-50.840.0Green bonds issued to all bonds (%)-0.41.21.31.51.73.92.31-34-1011-1718-2425-27Colours indicate performance ranking among 27 EU Member States. 
 
 
   
 
ANNEX 19: TAXATION  

This  Annex  provides  an 
indicator-based 
overview  of  Poland’s  tax  system.  It  includes 
information on the tax structure (the types of tax 
that Poland derives most of its revenue from), the 
tax  burden  on  workers,  and  the  progressivity  and 
redistributive  effect  of  the  tax  system.  It  also 
provides 
tax  collection  and 
compliance. 

information  on 

from 

consumption 

Poland’s  tax  revenues  are  relatively  low  in 
relation  to  GDP  and  rely  on  consumption 
taxes more than the EU average.  Table A19.1 
shows that Poland’s tax revenues as a percentage 
of GDP were considerably below the EU aggregate 
in  2021,  even  though  they  increased  by  about  5 
percentage  points  (pps)  since  2010.  The  share  of 
labour taxes as a proportion of total tax revenues 
was  significantly  below  the  EU  aggregate,  but 
revenues 
and 
environmental taxes were above the EU aggregate, 
as  a  share  of  both  GDP  and  total  taxation  (see 
Graph A19.1). Revenues from capital and property 
taxes  were  close  to  the  EU  aggregate.  Within 
environmental  taxes,  the  contribution  of  energy 
taxes  was  relatively  high  in  2020  (7.1%  of  tax 
revenue)  when  compared  with  the  EU  average  of 
4.3% (see Graph A19.1). However, transport taxes 
represented  only  0.5%  of  tax  revenue  (the  EU 
average was 1%). This means that there would be 
room to introduce a tax on passenger cars with a 
tax  base  related  to  emissions.  (For  more  on 

taxes 

policies  related  to  environmental  sustainability, 
see Annex 6). 

labour 

tax  burden  was 

Poland’s 
less 
progressive  than  the  EU  average  in  2022. 
Graph A19.2 shows that the labour tax wedge for 
Poland  in  2022  was  below  the  EU  average  for 
single  people  across  levels  of  income.  The  gap  is 
larger for higher levels of income. Second earners 
at  a  wage  level  of  67%  of  the  average  wage, 
whose  spouses  earn  the  average  wage,  were 
subject  to  a  tax  wedge  that  was  below  the  EU 
average. In 2021, the ability of the Polish tax and 
benefit  system  to  reduce  income  inequality  (as 
measured  by 
its  ability  to  reduce  the  GINI 
coefficient)  was  still  comparatively  low  (Table 
A19.1). 

A  major  2022  tax  reform  (‘Polish  Deal’)  is 
expected to reduce the overall tax burden for 
lower  earnings. 
employees,  especially  at 
Effective  in  January  2022,  the  reform  raised  the 
tax-free  amount  to  PLN  30 000,  decreased  the 
lower personal income tax rate from 17% to 12%, 
and increased the threshold to PLN 120 000 from 
which  the  32%  upper  tax  rate  applies.  Universal 
tax  credit  has  been  extended.  The  reform  also 
reduced  the  tax  burden  on  workers  delaying 
creating 
the 
retirement  beyond 
incentives to increase the effective retirement age. 
These  measures  are  estimated  to  have  reduced 

statutory, 

Table A19.1: Taxation indicators 

(1) Forward-looking effective tax rate (OECD). 
(2) A higher value indicates a stronger redistributive impact of taxation. 
(*) EU-27 simple average  
For more data on tax revenues as well as the methodology applied, see European Commission, Directorate-General for Taxation 
and Customs Union, Taxation trends in the European Union: data for the EU Member States, Iceland, Norway and United Kingdom: 
2021 edition, Publications Office of the European Union, 2021, https://data.europa.eu/doi/10.2778/843047 and the Data on 
Taxation webpage, data https://ec.europa.eu/taxation_customs/taxation-1/economic-analysis-taxation/data-taxation_en. 
For more details on the VAT gap, see European Commission, Directorate-General for Taxation and Customs Union, VAT gap in the 
EU: report 2022, Publications Office of the European Union, 2022, https://data.europa.eu/doi/10.2778/109823. 
Source: European Commission, OECD. 

71 

2010201920202021202220102019202020212022Total taxes (including compulsory actual social contributions) (% of GDP)31.635.235.636.837.939.940.040.6Labour taxes (as % of GDP)11.914.214.314.220.020.721.320.9Consumption taxes (as % of GDP)12.512.312.413.510.811.110.711.2Capital taxes (as % of GDP)7.28.68.99.17.18.18.08.5Total property taxes (as % of GDP)1.41.71.71.61.92.22.22.2Recurrent taxes on immovable property (as % of GDP)1.11.11.11.11.11.21.21.1Environmental taxes as % of GDP2.72.52.52.92.42.42.22.2Tax wedge at 50% of average wage (Single person) (*)32.334.333.433.529.433.932.331.932.131.7Tax wedge at 100% of average wage (Single person) (*)34.235.634.834.933.641.040.139.939.739.7Corporate income tax - effective average tax rates (1) (*)15.515.515.519.519.419.1Difference in Gini coefficient before and after taxes and cash social transfers (pensions excluded from social transfers) (2) (*)4.75.34.68.67.78.17.8Outstanding tax arrears: total year-end tax debt (including debt considered not collectable) / total revenue (in %) (*)29.839.931.640.7VAT Gap (% of VAT total tax liability, VTTL)12.711.311.09.1PolandEU-27Tax structureProgressivity & fairnessTax administration & compliance 
 
 
 
   
 
 
 
 
 
 
Graph A19.1: Tax revenues from different tax types, % of total taxation 

Source: European Commission 

the  tax  burden  for  most  groups  of  employees, 
especially  at  lower  earnings  (by  about  3  ppts  for 
those  earning  67%  of  the  average  wage). (153)  At 
the  same  time,  the  tax  burden  for  self-employed 
increased  due 
insurance 
contributions.  

to  higher  health 

Graph A19.2: Tax wedge for single and second 
earners, % of total labour costs, 2022 

extended  to  small  companies.  2019  saw  the 
introduction  of  a  requirement  to  make  split 
payments  (by  which  purchasers  make  parallel 
payments to suppliers’ account and a VAT account) 
and the modernisation of VAT reporting. A system 
of  structured  e-invoices  was  introduced  in  2021 
that  allows  the  issue  and  receipt  of  electronic 
structured invoices via the national invoice system. 
The introduction of an obligation to issue invoices 
through that system is planned for 2024.  

tax 

decreased 

Poland’s  VAT  gap  decreased  significantly  in 
2021.  Poland  has  been  improving  VAT  collection 
since  2015.  Poland  recorded  one  of  the  fastest 
increases  in  VAT  compliance  in  the  EU  between 
2016  and  2018.  In  2020,  the  VAT  gap  (the  gap 
between  revenues  actually  collected  and  the 
theoretical 
by 
liability) 
approximately  1.4  pps  to  11.3  percent  (see  Table 
A19.1). A significant increase of nearly 20% in the 
value  of 
transactions  and  an 
approximately 8.5% decline in the bankruptcy rate 
have  probably  contributed  to  the  increase  in  VAT 
compliance.  Poland  has  not  only  improved  digital 
transformation  by  implementing  and  extending 
SAF-T,  but  has  also  introduced  measures  against 
fraud  and  evasion.  The  policy  gap  increased 
increased  public 
slightly 
expenditure. (154)  

in  2020  due 

electronic 

to 

Second earner tax wedge assumes first earner at 100% of 
the average wage and no children. 
Source: European Commission 

Poland  is  relatively  advanced  in  digitally 
transforming  its  tax  administration,  which 
can  help  reduce  tax  arrears.  Tax  arrears 
currently  amount  to  around  40%  of  total  tax 
revenue (which corresponds to the EU average; see 
Table  A19.1).  Digitalisation  of  Poland's 
tax 
administration  started  in  2016,  when  Poland 
implemented SAF-T (the international standard for 
the  electronic  exchange  of  accounting  data).  The 
corresponding  reporting  obligation  was  initially 
imposed  only  on  large  companies  but  was  later 

(153) Calculations by European Commission, Joint Research Centre, 

based on the EUROMOD model, version I5.0+. 

(154) See: “VAT gap in the EU report 2022”, prepared by CASE – 

Center for Social and Economic Research (project leader) and 
Economisti Associati (consortium leader), p. 110. 

72 

29.431.333.635.537.620253035404550100150Tax wedge, % of total labour costsEarnings as % of the average wageSingle earner - PLSingle earner - EU averageSecond earner -  PLSecond earner -  EU average51.4327.5421.0138.5236.6324.85Tax revenue shares in 2021, Poland (outer ring) and the EU (inner ring)Taxes on labourTaxes on consumptionTaxes on capital7.104.320.491.000.250.192.912.641.562.750246810Poland -environmentaltaxationEU -environmentaltaxationPoland - propertytaxationEU - propertytaxationEnvironmental and property taxation as % of total tax revenue, Poland and the EUEnergy taxesTransport taxesResource/pollution taxesRecurrent property taxesOther property taxes 
 
   
                                                 
                                                 
   
ANNEX 20: TABLE WITH ECONOMIC AND FINANCIAL INDICATORS 

Table A20.1: Key economic and financial indicators 

(1) Domestic banking groups and stand-alone banks, EU and non-EU foreign-controlled subsidiaries and EU and non-EU foreign-
controlled branches. 
(2) Net international investment position (NIIP) excluding direct investment and portfolio equity shares.  
Source: Eurostat and ECB as of 2 May 2023, where available; European Commission for forecast figures (Spring forecast 2023). 

73 

2004-072008-122013-1920202021202220232024Real GDP (y-o-y)5.43.33.9-2.06.95.10.72.7Potential growth (y-o-y)3.74.03.53.73.53.43.73.4Private consumption (y-o-y)4.13.23.5-3.46.13.3-0.12.7Public consumption (y-o-y)4.01.73.34.95.0-2.00.52.7Gross fixed capital formation (y-o-y)12.32.14.3-2.31.25.02.03.1Exports of goods and services (y-o-y)10.04.96.7-1.112.36.22.33.6Imports of goods and services (y-o-y) 12.02.76.4-2.416.16.20.03.1Contribution to GDP growth:Domestic demand (y-o-y)5.72.73.5-1.54.62.30.42.5Inventories (y-o-y)0.7-0.30.1-1.13.42.6-1.1-0.3Net exports (y-o-y)-1.00.80.30.6-1.10.21.40.5Contribution to potential GDP growth:Total Labour (hours) (y-o-y)0.30.50.30.70.70.51.10.7Capital accumulation (y-o-y)1.21.81.41.21.21.21.21.2Total factor productivity (y-o-y)2.21.71.81.81.71.71.41.5Output gap-0.21.40.0-2.90.31.9-1.0-1.7Unemployment rate15.79.36.63.23.42.93.33.2GDP deflator (y-o-y)3.22.91.24.35.311.311.85.8Harmonised index of consumer prices (HICP, y-o-y)2.43.70.73.75.213.211.76.0HICP excluding energy and unprocessed food (y-o-y)1.63.00.94.24.210.310.86.2Nominal compensation per employee (y-o-y)3.06.14.75.34.713.212.78.3Labour productivity (real, hours worked, y-o-y)2.73.33.4-1.30.95.50.02.1Unit labour costs (ULC, whole economy, y-o-y)0.43.11.57.50.48.112.15.8Real unit labour costs (y-o-y)-2.70.20.43.1-4.6-2.90.30.0Real effective exchange rate (ULC, y-o-y)3.0-1.1-0.3-0.2-2.91.46.92.6Real effective exchange rate (HICP, y-o-y)4.1-0.8-0.40.5-0.50.4..Net savings rate of households (net saving as percentage of net disposable income)2.21.92.69.50.7...Private credit flow, consolidated (% of GDP)6.56.93.91.83.81.8..Private sector debt, consolidated (% of GDP)46.370.677.976.171.363.2..of which household debt, consolidated (% of GDP)17.333.235.634.632.226.6..of which non-financial corporate debt, consolidated (% of GDP)29.037.442.341.539.136.6..Gross non-performing debt (% of total debt instruments and total loans and advances) (1)3.95.75.04.03.3...Corporations, net lending (+) or net borrowing (-) (% of GDP)0.84.13.46.42.93.35.75.4Corporations, gross operating surplus (% of GDP)22.422.822.723.424.427.226.926.1Households, net lending (+) or net borrowing (-) (% of GDP)-1.7-2.2-1.24.2-2.2-2.0-1.2-1.0Deflated house price index (y-o-y).-5.42.06.73.7-2.1..Residential investment (% of GDP)3.43.22.42.22.32.2..Current account balance (% of GDP), balance of payments-5.2-5.0-1.52.5-1.4-3.0-0.70.7Trade balance (% of GDP), balance of payments-2.6-2.42.25.73.31.9..Terms of trade of goods and services (y-o-y)1.5-0.50.92.8-2.0-3.43.00.6Capital account balance (% of GDP)0.91.61.61.40.70.3..Net international investment position (% of GDP)-44.2-60.6-60.2-43.9-39.4-33.8..NENDI - NIIP excluding non-defaultable instruments (% of GDP) (2)-10.4-23.1-20.2-4.50.82.3..IIP liabilities excluding non-defaultable instruments (% of GDP) (2)36.852.155.247.243.640.7..Export performance vs. advanced countries (% change over 5 years)69.036.413.334.330.6...Export market share, goods and services (y-o-y)8.90.04.111.3-0.72.2-0.3-0.2Net FDI flows (% of GDP)-3.5-1.8-1.8-2.4-4.1-3.9..General government balance (% of GDP)-3.6-5.4-2.2-6.9-1.8-3.7-5.0-3.7Structural budget balance (% of GDP)..-2.1-5.7-2.2-5.0-4.5-2.9General government gross debt (% of GDP)45.952.151.457.253.649.150.553.0forecast 
 
 
 
     
 
 
 
ANNEX 21: DEBT SUSTAINABILITY ANALYSIS 

This  Annex  assesses  fiscal  sustainability 
risks  for  Poland  over  the  short,  medium  and 
long term. It follows the same multi-dimensional 
approach  as  the  European  Commission’s  2022 
Debt Sustainability Monitor, updated based on the 
Commission 2023 spring forecast. 

1  -  Short-term  risks  to  fiscal  sustainability 
low  overall.  The  Commission’s  early-
are 
detection  indicator  (S0)  does  not  signal  major 
short-term  fiscal  risks  (Table A21.2) (155).  Gross 
financing  needs  are  forecast  to  remain  relatively 
low.  They  are  expected  to  increase  temporarily  to 
around  11%  of  GDP  in  the  short  term  (i.e.  over 
2023-2024)  –  due  to  stock-flow  adjustments 
reflecting  a  mismatch  between  the  payment  and 
deliveries  of  military  investment  –  but  to  remain 
below  the  recent  peak  of  2020  (Table 1  in  this 
annex). Financial markets’ perceptions of sovereign 
risk  are  overall  positive,  as  confirmed  by  the 
ratings of the main agencies. 

2 - Medium-term risks to fiscal sustainability 
are medium overall.  

The  DSA  for  Poland  shows  that,  under  the 
baseline,  the  government  debt  ratio 
is 
projected to increase over the medium term, 
reaching  around  55%  of  GDP 
in  2033 
(Table 1) (156), (157) The assumed structural primary 
balance  (a  deficit  of  0.8%  of  GDP)  contributes  to 

(155) The S0 is a composite indicator of short-term risk of fiscal 
stress. It is based on a wide range of macro-financial and 
fiscal variables that have proven to perform well in the past 
in detecting situations of upcoming fiscal stress.  

(156) The assumptions underlying the Commission’s ‘no-fiscal-
policy-change’ baseline notably comprise: (i) a structural 
primary deficit, before ageing costs, of 0.8% of GDP as of 
2024; (ii) inflation converging linearly towards the 10-year 
forward inflation-linked swap rate 10 years ahead (which 
refers to the 10-year inflation expectations 10 years from 
now); (iii) the nominal short- and long-term interest rates on 
new and rolled over debt converging linearly from current 
values to market-based forward nominal rates by T+10 (as 
for all Member States); (iv) real GDP growth rates from the 
Commission 2023 spring forecast until 2024, followed by 
EPC/OGWG ‘T+10 methodology’ projections between T+3 and 
T+10, i.e. for 2025-2033 (on average 2.4%); (v) ageing costs 
in line with the 2021 Ageing Report (European Commission, 
Institutional Paper 148, May 2021). For information on the 
methodology, see the 2022 Debt Sustainability Monitor 
(European Commission, Institutional Paper 199, April 2023). 

these  developments.  This  position  appears 
relatively  ambitious  compared  with  past  fiscal 
performance,  indicating  that  the  country  only  has 
moderate room for corrective action. At the same 
time,  the  baseline  projection  benefits  up  to  2033 
(although  declining) 
from  a  still  favourable 
snowball  effect,  notably  thanks  to  the  impact  of 
Next  Generation  EU,  with  real  GDP  growth  at 
around  2.4%  over  2025-2033.  Government  gross 
financing  needs  are  expected  to  remain  limited 
over the projection period, at around 9% of GDP in 
2033, below the level forecast for 2024. 

The  baseline  projections  are  stress-tested 
against  four  alternative  scenarios  to  assess 
the  impact  of  changes  in  key  assumptions 
(Graph 1).  For  Poland,  reverting  to  a  historical 
fiscal  position  under  the 
‘historical  structural 
primary balance (SPB)’ scenario would significantly 
worsen the government debt trajectory. If the SPB 
gradually converged its historical 15-year average 
(a  deficit  of  1.8%  of  GDP),  the  projected  debt-to-
GDP ratio would be about 7 pps. higher than in the 
baseline  by  2033.  The  ‘lower  structural  primary 
balance’ scenario (with the SPB level permanently 
1.3 pps. lower than in the baseline) would lead to a 
higher government debt-to-GDP ratio (+11 pps. of 
GDP  by  2033)  compared  with  the  baseline.  A 
the  macro-financial 
permanent  worsening  of 
conditions,  as 
‘adverse 
reflected  under 
interest-growth  rate  differential’  scenario  (with  a 
differential  1  pp.  higher  than  the  baseline)  would 
also  result  in  a  persistently  higher  debt  ratio,  by 
around 4 pps. of GDP by 2033, as compared with 
the  baseline.  A  temporary  worsening  of  financial 
conditions,  as  reflected  in  the  ‘financial  stress’ 
scenario  (with.  a  temporary  increase  of  interest 
rates by 1 pp.), would only marginally increase the 
debt ratio by 2033 compared with the baseline.  

the 

low 

risk 

(Graph 2). (158) 

Additionally,  stochastic  debt  projections 
indicate 
These 
stochastic  simulations  point  to  a  66%  probability 
of  the  debt  ratio  in  2027  being  greater  than  in 
2022,  entailing  low  risk  given  the  initial  low  level 
of  debt.  The  uncertainty  (as  measured  by  the 
difference  between  the  10th  and  90th  debt 
distribution  percentiles)  surrounding  the  baseline 
debt projection is limited. 

(157) Table 1 shows the baseline debt projection and its 

(158) These projections show the impact on debt of 2000 different 

breakdown into the primary balance, the snowball effect (the 
combined impact of interest payments and nominal GDP 
growth on the debt dynamics) and the stock-flow 
adjustment.  

shocks affecting the government’s primary balance, 
economic growth, interest rates and exchange rates. The 
cone covers 80% of all simulated debt paths, therefore 
excluding tail events 

74 

 
 
                                                 
                                                 
 
 
financing  sources 

recent  increase  in  interest  rates,  potential  legal 
costs  associated  with  Swiss  franc-denominated 
loans  and  exposure  to  non-performing  loans.  On 
the other hand, risk-mitigating factors include the 
lengthening  of  debt  maturity  in  recent  years, 
(with  a 
relatively  stable 
diversified  and  large  investor  base)  and  the 
currency  denomination  of  debt  (about  three-
quarters  of  outstanding  debt  is  denominated  in 
local  currency).  In  addition,  the  structural  reforms 
under  the  NGEU/RRF,  if  fully  implemented,  could 
have  a  further  positive  impact  on  GDP  growth  in 
the  coming  years,  and  therefore  help  to  mitigate 
debt sustainability risks. 

3  -  Long-term  risks  to  fiscal  sustainability 
are medium overall (159).  

initial 

increase 

budgetary 

in  ageing-related 

The  S2  sustainability  gap 
indicator  (at 
3.0 pps.  of  GDP)  points  to  medium  risk, 
suggesting  that  Poland  would  need  to 
significantly  improve  its  structural  primary 
balance to ensure debt stabilisation over the 
long term. This result is underpinned both by the 
projected 
costs 
(contribution  of  1.7  pps.  of  GDP)  and  by  the 
unfavourable 
position 
(contribution  of  1.3  pps.  of  GDP)  (Table 2).  Long-
term  developments  in  ageing  costs  are  primarily 
driven by the projected increase in health care and 
long-term  care  expenditure  (joint  contribution  of 
2.5  pps.  of  GDP).  As  a  result,  while  a  number  of 
investments  and  reforms in  the  RRP  contribute to 
supporting  the  efficiency of  the  Polish  health  and 
long-term care systems, additional measures may 
fiscal 
be 
sustainability.  Expenditure  on  public  pensions  is 
projected  to  decline  (contribution  of  -0.8  pp.  of 
GDP),  based  however  on  the  assumption  of  a 
strong decline in the replacement rate.  

required 

improve 

further 

its 

to 

Given  limited  long-term  debt  vulnerabilities, 
as  highlighted  by  the  S1  indicator,  overall 
long-term  risks  are  assessed  as  medium. 
Indeed,  the  S1  sustainability  gap  indicator signals 
that  a  consolidation  effort  of  1.9  pps.  of  GDP 
would be needed to bring debt to 60% of GDP by 
2070  (Table 2).  This  gap  entirely  stems  from  the 
initial  deficit  and the  projected increase in  ageing 
costs  (contributing  1.1  pps.  and  0.9  pp.  of  GDP, 
respectively),  while  debt  already  stands  close  to 
60% of GDP. 

Finally,  several  additional  risk  factors  need 
to  be  considered  in  the  assessment.  On  the 
one hand, risk-increasing factors are related to the 

(159) The S2 fiscal sustainability indicator measures the 

permanent SPB adjustment in 2024 that would be required 
to stabilise public debt over the long term. It is 
complemented by the S1 indicator, which measures the 
fiscal gap in 2024 to bring the debt-to-GDP ratio to 60% in 
the long term. For both the S1 and S2 indicators, the risk 
assessment depends on the amount of fiscal consolidation 
needed: ‘high risk’ if the required effort exceeds 6 pps. of 
GDP, ‘medium risk’ if it lies between 2 pps. and 6 pps. of 
GDP, and ‘low risk’ if the effort is negative or below 2 pps. of 
GDP. The overall long-term risk classification brings together 
the risk categories derived from S1 and S2. S1 may notch up 
the risk category derived from S2 when it signals a higher 
risk than S2. See the 2022 Debt Sustainability Monitor for 
further details. 

75 

 
                                                 
Table A21.1: Debt sustainability analysis - Poland 

Source: Commission services. 

Table A21.2: Heat map of fiscal sustainability risks - Poland 

Source: Commission services. 

76 

Table 1. Baseline debt projections20202021202220232024202520262027202820292030203120322033Gross debt ratio (% of GDP)57.253.649.150.553.052.652.251.952.152.452.853.454.155.0Changes in the ratio11.5-3.6-4.51.42.5-0.4-0.3-0.30.20.30.40.60.70.9of whichPrimary deficit5.60.72.23.01.71.51.21.01.01.01.11.11.11.1Snowball effect0.4-5.3-6.2-3.5-1.9-1.9-1.6-1.3-0.9-0.7-0.6-0.5-0.3-0.2Stock-flow adjustments5.51.0-0.41.92.80.00.00.00.00.00.00.00.00.0Gross financing needs (% of GDP)15.77.67.811.511.48.88.68.48.58.58.68.78.88.9S1S2Overall index  (pps. of GDP)1.93.0of which Initial budgetary position1.11.3Debt requirement-0.1Ageing costs0.91.7of which    Pensions-0.6-0.8     Health care0.91.3     Long-term care0.81.2Others-0.10.0Table 2. Breakdown of the S1 and S2 sustainability gap indicators30354045505560657020202021202220232024202520262027202820292030203120322033Graph 1. Deterministic debt projections Historical SPB scenarioLower SPB scenarioFinancial stress scenarioAdverse 'r-g' scenarioBaseline% of GDPp10p20p40p60p80p90304050607020202021202220232024202520262027% of GDPGraph 2. Stochastic debt projections 2023-2027MedianBaselineBaselineHistorical SPBLower SPBAdverse 'r-g'Financial stressOverallMEDIUMMEDIUMMEDIUMMEDIUMMEDIUMLOWDebt level (2033), % GDP55.062.366.259.455.3Debt peak year20332033203320332033Fiscal consolidation space41%75%85%41%41%Probability of debt ratio exceeding in 2027 its 2022 level66%Difference between 90th and 10th percentiles (pps. GDP)19.2(1)Debtlevelin2033.Green:below60%ofGDP.Yellow:between60%and90%.Red:above90%.(2)Thedebtpeakyearindicateswhetherdebtisprojectedtoincreaseoveralloverthenextdecade.Green:debtpeaksearly.Yellow:peaktowardsthemiddleoftheprojectionperiod.Red:latepeak.(3)Fiscalconsolidtationspacemeasurestheshareofpastfiscalpositionsinthecountrythatweremorestringentthantheoneassumedinthebaseline.Green:highvalue,i.e.theassumedfiscalpositionisplausiblebyhistoricalstandardsandleavesroomforcorrectivemeasuresifneeded.Yellow:intermediate.Red:low.(4)Probabilityofdebtratioexceedingin2027its2022level.Green:lowprobability.Yellow:intermediate.Red:high(alsoreflectingtheinitialdebtlevel).(5)thedifference between the 90th and 10th percentiles measures uncertainty, based on the debt distribution under 2000 different shocks. Green, yellow and red cells indicate increasing uncertainty.Short termMedium term - Debt sustainability analysis (DSA)Long termOverall                               (S0)Overall Deterministic scenariosStochastic projectionsS2S1Overall(S1 + S2)LOWMEDIUMMEDIUMLOWMEDIUM