COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Poland Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Poland, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 19 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Poland  Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)  Third River Basin Management Plans Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
y
n
a
r
V
n
a
p
e
t
S

|

m
o
c
s
l

.

e
x
e
P
©

Country specific staff working document 

Poland 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 4 

1. General info, member state characterisation ............................................................................................................. 5 

2. Horizontal aspects ................................................................................................................................................................... 12 

2.1 Governance ......................................................................................................................................................................... 12 

2.2 Characterization of River Basin District .............................................................................................................. 13 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 17 

3.1 Surface Water: what is their ecological status or potential .................................................................... 17 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 19 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 20 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 21 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 22 

3.6 What Poland is doing for abstractions and water scarcity ...................................................................... 23 

3.7 Adaptation to climate change .................................................................................................................................. 24 

4. Policy elements contributing to zero pollution ........................................................................................................ 25 

4.1 Surface Water: what is their chemical status ................................................................................................. 25 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 27 

4.3 What Poland is doing to combat pollution from agriculture .................................................................. 28 

4.4 What Poland is doing to combat pollution from other sectors ............................................................. 29 

4.5  What  Poland  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 29 

5. Exemptions and economics ............................................................................................................................................... 30 

5.1 To what extent are exemptions applied in Poland ....................................................................................... 30 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 31 

6. WFD recommendations ........................................................................................................................................................ 32 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 36 

7. Flood risk management under floods directive (FD) ............................................................................................ 37 

7.1 Flood hazard and risk maps ...................................................................................................................................... 37 

7.2 Flood risk management plans .................................................................................................................................. 38 

8. FD recommendations ............................................................................................................................................................ 40 

2 

 
 
 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
 
 
1. General info, member state characterisation

Poland is the fifth largest country in the EU with a surface area of 307 thousand square kilometres1. 
Its territory stretches from the Baltic Sea in the north to the Carpathian Mountains in the south. The 
northern part of the country is mainly lowlands with lake districts, whilst the most southern part is 
mountainous. The renewable freshwater resources are scarce with less than 60 000 million cubic 
metres annually2. 

The Polish economy has been growing steadily for decades, except the  short drop in 20203. More 
than half of Poland’s population is living in urban areas (22.5 million out of 37.8 million inhabitants)4. 
The densest areas are in and round the largest cities Warsaw-Lodz, Krakow-Katowice, and Wroclaw, 
as well as Gdansk-Sopot-Gdynia. While these areas have the highest economic activity, the agri-food 
sector,  however,  plays  nationally  a  great  importance  with  1.3  million  farms  (14%  of  EU  total)5. 
Agricultural is the dominating land use in Poland exceeding to 59% of total surface area6. Yet, the 
share of organic farming is very low, around 3.5%, well below the EU average of 9% in 2020. 

1 Eurostat – Area by NUTS 3 region (not including territorial waters): 
https://ec.europa.eu/eurostat/databrowser/bookmark/fabcfca6-4abb-4a84-ac1c-7bb335af436a?lang=en  
2 Eurostat – Water statistics: https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Water_statistics  
3 Eurostat - GDP and main components (output, expenditure and income): 
https://ec.europa.eu/eurostat/databrowser/bookmark/53d10133-3a33-4401-8c7a-ee9d0268e655?lang=en  
4 Sytuacja demograficzna Polski do roku 2022: https://stat.gov.pl/obszary-tematyczne/ludnosc/ludnosc/sytuacja-
demograficzna-polski-do-roku-2022,40,3.html  
5 Eurostat, Farms and farmland in the European Union – statistics: https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Farms_and_farmland_in_the_European_Union_-_statistics#Farms_in_2020  
6 OECD Country fact sheet Poland: https://www.oecd.org/regional/regional-policy/land-use-Poland.pdf  

4 

 
 
Poland has nine River Basin Districts (RBDs). It must be highlighted that all RBDs are transboundary 
meaning that they are shared with other countries, and all its rivers end up into the Baltic Sea except 
for the rivers in the Danube and Elbe RBDs. Two RBDs – Vistula and Oder – play a dominating role 
since they cover 97% of the country. 

In total, there are 4 240 surface water bodies out of which three quarters are rivers and one quarter 
are lakes. There are only few transitional and coastal water bodies and no territorial waters. In total, 
there are 174 groundwater bodies. 

Poland  remains  a  highly  biodiversity  rich  country  and  considering  both  Natura  2000  and  other 
nationally designated protected areas, Poland legally  protects around 40% of its terrestrial  areas 
and 22% of marine areas7. However, the share of habitats in bad conservation status has increased 
to  35%  and  that  of  assessments  for  species  in  bad  conservation  status  has  remained  stable  at 
around 13%. 

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By September 2023 Poland have not submitted full electronic reporting. Therefore, the assessment 
is based on the data mining of the pdf RBMPs. However, Poland reported electronically in 2024 and 
this information has been partially used in this assessment report. 

Despite the cut off dates for the production of this report, reporting continued, and, for the State of 
Water report, the EEA aggregated the results available, including Poland’s e-electronic reporting, by 
July 2024 in their products and dashboards available at WISE Freshwater web portal.

7 Biodiversity information system for Europe – Poland: https://biodiversity.europa.eu/countries/poland  

5 

 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

The total number of SWBs has decreased since the 2nd RBMPs, from 5 649 to 4 240. 75% of SWBs are rivers and they have the highest drop in the number of water bodies from 4 586 to 3 
161. 

ECOLOGICAL 
STATUS 

The surveillance and operational monitoring cover together 97% of river water bodies and reservoirs, 79% of lake water bodies and 100% of 
transitional and coastal water bodies. There is more complete monitoring data compared to the 2nd RBMPs, comprising all applicable biological 
quality elements. 68% of river water bodies, 67% of lake water bodies and 100% of transitional and coastal water bodies are classified using 
monitoring data. 

Worryingly, the proportion and the number of water bodies in good or better status or potential has decreased from 31% to 8.4%. 
Prominently, none of the transitional and costal water bodies are in good ecological status. 

6 

 
 
CHEMICAL 
STATUS 

There is more complete monitoring data compared to the 2nd RBMPs, covering 45% of SWBs and including all 45 priority substances. It is not 
clear if monitoring of priority substances only includes water matrix or also biota and sediments. 

The graph shows chemical status including ubiquitous substances. Only 24.8% of all SWBs are in good chemical status, up to 53.5% are in 
poor chemical status, and 21.7% are in unknown status. Compared to the 2nd RBMPs, the number of water bodies in good chemical status has 
significantly dropped from 3 331 to 1 150. The failure to achieve good chemical status is primarily because of uPBT substances, particularly 
PAH, PBDE, and PFOS. 

Regarding the exemptions for both ecological and chemical status, Article 4(4) has been applied to 19% of SWBs on the grounds of technical feasibility and / or disproportionate costs and to 
76% of SWBs on grounds of natural conditions. Furthermore, Article 4(5) has been applied to 52% of SWBs on the grounds of technical feasibility and / or disproportionate costs and to 12% 
of SWBs on grounds of natural conditions. There is a total of 254 investment projects meeting the conditions for exemptions according to Article 4(7). 

Ground 
Water 
Bodies 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

The number of GWBs has increased by 2 since the 2nd RBMPs from 172 to 174. 

7 

 
 
 
QUANTITATIVE 
STATUS 

It is not clear how many groundwater bodies are covered by quantitative monitoring. 

The number of GWBs in poor quantitative status has increased from 13 to 15 since the 2nd RBMPs. Subsequently, in total, 26 GWBs are at 
risk of failing to meet quantitative objectives in the Oder and Vistula RBDs.  

CHEMICAL 
STATUS 

All GWBs and all substances causing risk of deterioration in chemical status are subject to monitoring. It is not clear, if all WFD core 
parameters i.e., nitrates, ammonium, pH, electrical conductivity, and oxygen are included in monitoring of groundwaters in all RBDs. 

The number of GWBs in poor chemical status has decreased from 14 to 9 since the 2nd RBMPs. Subsequently, in total, 32 GWBs are at risk 
of failing to meet chemical objectives in the Oder and Vistula RBDs. The main reason for the failure of good chemical status is the diffuse 
pollution from urban and mining activities, as well as due to saline intrusion, caused by ingress or upwelling of saline waters from drained 
groundwater layers.  

8 

 
 
 
 
Regarding the exemptions for both quantitative and chemical status, Article 4(4) has been applied to 6% of GWBs on grounds of natural conditions (none on grounds of technical infeasibility 
and / or disproportionate costs). Furthermore, Article 4(5) has been applied to 7% of GWBs on the grounds of technical feasibility and / or disproportionate costs and to 5% of GWBs on 
grounds of natural conditions. 

9 

 
 
2. Horizontal aspects 

2.1 Governance 

Poland has two large River Basin Districts (RBDs) which cover almost 97% of the country: Vistula 
(PL2000) and Oder (PL6000). Additionally, there are further seven RBDs which cover only very small 
areas in the territory of Poland: Danube (PL1000), Świeża (PL3000), Jarft (PL4000), Elbe (PL5000), 
Pregoła (PL7000), Nemunas (PL8000), and Dniester (PL9000). More information is provided in Table 
1. 

Table 1. Overview of Poland’s RBDs 

RBD 

RBD Name 

Size (km2) 
(% of RBD in Poland) 

Countries sharing RBD 

PL1000 

Danube 

385 (less than 1%) 

DE, SK, UA, AT, BG, CZ, HR, HU, RO, IT, MD, ME, RS, SI, BA, 
AL, CH, MK 

PL2000 

Vistula 

183 492 (app. 59%) 

BY, RU, UA, SK 

PL3000 

Świeża 

161 (less than 1%) 

PL4000 

PL5000 

PL6000 

Jarft 

Elbe 

Oder 

238 (less than 1%) 

CZ, DE, AT 

210 (less than 1%) 

118 499 (app. 38%) 

RU 

RU 

CZ, DE 

RU 

PL7000 

Pregoła 

7 522 (app. 2.5%) 

PL8000 

Nemunas 

2 515 (less than 1%) 

BY, LT (RU) 

PL9000 

Dniester  

233 (less than 1%) 

UA (MD) 

Source: 2nd RBMPs WISE reporting 

Poland has organised the implementation of the Water Framework Directive (WFD) mainly through 
the  Directors  of  the  Regional  Water  Management  Boards8  (16  in  total)  and  the  National  Water 
Management Authority. Many RBDs are managed by multiple Regional Water Management Boards, 
and for example, the Vistula RBD is within the jurisdiction of seven different boards, while the Oder 
RBD is managed by five boards. At regional level, the Voivodships and municipalities have mainly a 
role in the implementation of measures. 

All nine RBDs are transboundary and the cooperation with other countries varies depending on the 
RBD.  For  the  Danube  RBD,  Elbe  RBD  and  Oder  RBD,  an  international  agreement,  permanent 
cooperation body and international RBMP are in place. For the Oder RBD, the coordination is carried 
out  under  International  Commission  for  the  protection  of  the  Odra  River  against  pollution 
(MKOO/IKSO)9. For Danube RBD and Elbe RBD, there are similar international commissions as in the 
Oder  RBD10.  As  regards  the  Vistula  RBD,  Poland  has  a  bilateral  commission  with  Slovakia. 
Furthermore, there is a bilateral agreement with Belarus, Russia (Kaliningrad) and Ukraine concerning 

8 Polskie Gospodarstwo Wodne Wody Polskie (PGW WP): https://www.wody.gov.pl/  
9 International Commission for the protection of the Odra River against pollution: https://www.mkoo.pl/index.php?lang=EN  
10 Danube RBD: https://www.icpdr.org/ and Elbe RBD: https://www.ikse-mkol.org/  

10 

 
 
Vistula  and  other  smaller  RBDs.  Finally,  Poland  is  a  contracting  party  of  the  Cooperation  for  the 
Protection of the Marine Environment of the Baltic Sea (HELCOM)11. 

The River Basin Management Plans (RBMPs) for Vistula and Oder are very long, almost 47 thousand 
and almost 35 thousand pages, respectively. The overwhelmed length and the absence of aggregated 
data related to e.g., coverage of water bodies by monitoring or the number of water bodies for each 
measure,  impede  the  transparent  overview  of  impacts  of  the  plan.  Subsequently,  it  discourages 
stakeholders and the public to give their reasoned opinions and suggestions. 

The work programme, timetable, consultation plan and the draft RBMPs have been subject to public 
consultation for six months. However, the overview of the significant water management issues was 
not presented for consultation. A total of 1 529 comments were submitted through the consultation, 
59% of them concerned the Vistula RBD, 38% concerned the Oder RBD, and 0.7% concerned the 
Pregoła RBD, and less than 0.3% for the remaining RBDs.  

Poland conducted joint consultations with the Flood Risk Management Plans (FRMPs) under the Floods 
Directive;  however,  no  joint  consultation  has been  carried  out  for  the  Marine Strategy  Framework 
Directive (MSFD). The authorities organised online consultation meetings in 15 cities, and an online 
conference to summarise the update in the preparation of the RBMPs and the FRMPs12. 

Poland did not adopt and publish its RBMPs in accordance with the WFD timetable.  

2.2 Characterization of River Basin District 

Poland has delineated a total of 4 240 surface water bodies and 174 groundwater bodies in the 3rd 
RBMPs. The surface waters include lakes (7 types), rivers (20 types), transitional waters (5 types) and 
coastal waters (2 types). Subsequently, Poland has delineated reservoirs which are addressed in the 
RBMPs as a separate water category13. There are no territorial waters.  

Table 2. Number of river and lake water bodies, transitional and coastal water bodies, and groundwater 
bodies. 

RBD 
(Index) 

Danube 
(PL1000)  
Vistula 
(PL2000)  
Świeża 
(PL3000)  
Jarft 
(PL4000) 
Elbe 
(PL5000)  
Oder 
(PL6000) 
Pregoła 
(PL7000)  

Rivers 

Lakes 

Transitional 
Waters 

Coastal 
Waters 

Groundwater 
Bodies 

5 

1 745 

3 

1 

8 

1 291 

82 

0 

499 

1 

0 

0 

427 

105 

0 

5 

0 

0 

0 

2 

0 

0 

2 

0 

0 

0 

2 

0 

2 

94 

1 

1 

5 

66 

2 

11 Cooperation for the protection of the marine environment of the Baltic Sea: https://helcom.fi/  
12 Notification by the Ministry of Infrastructure, 6 May 2022: https://www.gov.pl/web/infrastruktura/projekty-ii-aktualizacji-
planow-gospodarowania-wodami-na-obszarach-dorzeczy---raport-z-konsultacji-spolecznych  
13 Subsequent information provided electronically by Poland features reservoirs included in the category rivers. 

11 

 
 
 
Nemunas  
(PL8000)  
Dniester  
(PL9000)  
TOTAL 

24 

2 

3 161 
Source: WISE electronic reporting 

36 

0 

1 068 

0 

0 

7 

0 

0 

4 

2 

1 

174 

Compared to the 2nd RBMPs, the number of river water bodies has decreased significantly by over 
30% (from 4 586 to 3 161). This is due to a change in methodology, and Poland explains that changes 
in hydrographic divisions of catchment areas have resulted to many changes in the surface water 
bodies14. This change has a bearing in the comparability of data between the 2nd and 3rd RBMPs and 
the establishment of trends.  

The level of human intervention is considerable, though in total, 80% of surface water bodies are 
natural  (3 413)  comprising  all  transitional  and  coastal  waters  (Figure  1).  The  number  of  heavily 
modified  water  bodies  (HMWBs)  is  753  (633  river  water  bodies  and  120  lake  water  bodies)  and 
artificial water bodies (AWBs) is 74 (all of them are rivers or reservoirs). 

Figure 1. The proportion of natural, heavily modified, and artificial water bodies by water category and 
total. 

Source: WISE electronic reporting 

The water consumption has decreased steadily since early 2000’s, and in 2020 it counted around 
8 400 million cubic metres, with industry being the major user (71%)15. 

Poland  has  established  type-specific  reference  conditions  for  all  relevant  quality  elements  for  all 
water  body  types  across  all  water  categories.  According  to  the  latest  update  of  intercalibration 
exercise in 202416, the intercalibration of biological quality elements has been accomplished in all 
water categories.  

For the Oder RBD, the uniform characteristics could not be agreed in some cases of transboundary 
water bodies, and therefore, these water bodies continue to be presented on the maps of the Water 
Management Plan for the International Oder River Basin District in different ways, according to the 
methodology and classification applicable in individual countries. 

14 Subsequent comments provided in March 2024 from the Ministry of Infrastructure 
15 Atlas of Environment: https://stat.gov.pl/en/topics/environment-energy/environment/atlas-of-environment,6,1.html  
16 Intercalibration gaps, update March 2024: https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-
9964bbe8312d/library/588d243a-a12f-4d1f-9bf5-f5e31d352f37/details  

12 

 
 
 
Poland shares water information via Hydroportal and via service of Chief Inspectorate of 
Environmental Protection. 

The  Hydroportal17  is  a  map-based  service  providing  detailed  information  of  the  status  of  water 
bodies, including type of the water body, monitoring stations, status of water and classification of 
quality elements as well as protected areas. The map service can be used by public and experts. A 
second map service18 provided by the Polish Chief Inspectorate of Environmental Protection provides 
tools to illustrate on the map the ecological status / potential and chemical status of surface water 
bodies. The latter functions as a viewer and do not give detailed information of single water bodies. 
Figure 2 shows a screenshot of both services. 

Figure 2. Hydroportal map service provided by Polish Waters (left) and the map service provided by the 
Chief Inspectorate of Environmental Protection (screenshot of the services). 

Source: Hydroportal and Portal jakości wód powierzchniowych 

Multiple significant pressures are impacting surface and groundwaters in Poland. 

Agriculture in Poland is characterised by a large diversity and fragmentation of the holdings19, yet 
the average size is smaller than the EU average20, with a pesticide consumption considerably lower 
than other large farming European countries (Spain, France, Germany, and Italy), despite the very low 
share of organic farming. Based on the reporting under the Nitrates Directive, we can conclude that 
nitrogen from agriculture has in general less significant effect on eutrophication of inland surface 
waters  compared  to  the  impact  of  phosphorus21.  Nitrogen  is  showing  only  slight  increase  in 
concentrations; however, no information is provided on the trend of phosphorus concentrations. 

In terms of coverage of wastewater treatment, Poland sees a positive trend through years. According 
to the latest reporting under the Urban Waste Water Treatment Directive, the purification is mainly 
based  on  biological  treatment  (63%),  however,  additional  nitrogen  and  phosphorus  removal  are 
widely spread (34%)22. Still, there are some wastewater plants with only primary treatment.  

17 Hydroportal: https://wody.isok.gov.pl/imap_kzgw/?gpmap=gpPGW  
18 Portal jakości wód powierzchniowych: https://wody.gios.gov.pl/pjwp/  
19 Size Structure Transformation of Polish Agricultural Farms in 2010–2020 by Typological Groups of Voivodeships 
(Badach et al. 2023): https://doi.org/10.3390/agriculture13091789  
20 Eurostat: Farms and farmland in the European Union – statistics: https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Farms_and_farmland_in_the_European_Union_-_statistics  
21 The Nitrates Directive Reporting 7 (2016-2019), Poland: 
https://water.jrc.ec.europa.eu/arcgis/rest/services/nid/msNidReporting7/MapServer/2/1034/attachments/191  
22 WISE – country profiles on urban waste water treatment – Poland: 
https://water.europa.eu/freshwater/countries/uwwt/poland 

13 

 
 
 
 
Surface waters 

Industry and municipal wastewater are the main point source pressures, and agriculture is the main 
diffuse pressure. Dewatering of mines and changes in flow and river bed, as well as existing dams 
and other structures are causing hydromorphological pressure. In the Oder and Vistula RBDs, over 
90%  of  river  water  bodies  and  60-70%  of  lake  water  bodies  are  at  risk  not  achieving  the 
environmental objectives because of these anthropogenic pressures. 

The  excess  of  nutrients  discharged  into  the  surface  waters  leads  to  eutrophication  causing 
proliferation  of  algae  blooms  and  oxygen  depletion  in  both  lakes  and  coastal  waters.  Under  the 
Nitrates Directive reporting, Poland indicated that many monitoring points across the country show 
surface waters as eutrophic or at risk of becoming eutrophic (Figure 3). 

Figure 3. Map of the monitoring points showing eutrophication assessment in  Poland, according to the 
reporting of the Nitrates Directive23 

HELCOM has calculated that the annual input of total nitrogen and total phosphorus in 1997-2003 
from  the  river  basins  of  Oder  and  Vistula  was  in  total  161 512  tonnes  and  10 284  tonnes, 
respectively24. The input ceiling for annual total nitrogen and total phosphorus has been estimated 

23 NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) – trophic status: 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa   

24 The revised nutrient input ceilings to the BSAP update. HELCOM (2021): 
https://helcom.fi/wp-content/uploads/2021/10/Nutrient-input-ceilings-2021.pdf  

14 

 
 
 
to be 124 105 tonnes and 3 904 tonnes, respectively. This translates to a 23% and 62% reduction 
needs  for  nitrogen  and  phosphorus,  respectively.  However,  the  Polish  RBMPs  did  not  include  any 
estimation of reduction needs. 

Regarding hydropower, while the country is rich of hydropower plants amounting 771, 99 % of them 
are small (capacity less than 10 MW)25. Three largest pumped hydropower plants cover more than 
half of the produced capacity. According to the information provided by electronic reporting, up to 
108 river water bodies (ca. 6 000 km) are significantly affected by hydropower. 

Subsequently, the pressure of invasive alien species (IAS) on waters has not been assessed. In total, 
there are 18 aquatic species of EU concern in Poland26. While no concrete measures are introduced 
to combat IAS, the national catalogue of measures, however, is taking into account the treatment of 
areas impacted with IAS by particular measures e.g., removing vegetation in lake shores or planning 
buffer zones. 

Groundwaters  

Groundwaters  in  Poland  are  impacted  by  municipal  and  industrial  landfills,  industrial  sewage, 
wastewater, agricultural pollution, and road transport, as well as dewatering of mines. In the Oder 
and  Vistula  RBDs,  20-30%  of  groundwater  bodies are  at  risk  of  failing  to  achieve  environmental 
objectives because of these anthropogenic pressures. Strikingly, despite poor quantitative status of 
some GWBs, water abstraction is generally not identified as a significant pressure and it is not given 
a lot of attention. 

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring  

Little  information  is  provided  on  the  assessment  methodologies  to  classify  water  bodies  for 
ecological status. From the very extensive pdf-documents provided, which did not include electronic 
reporting, it was not possible to evaluate how different monitoring programmes are covering surface 
water bodies and comprising the obligatory quality elements. In the Oder and Vistula RBDs, there are 
altogether 3 697 monitoring sites for ecological status. According to the available data in the pdf-
documents, the surveillance and operation monitoring27 together cover 97% of river water bodies 
and reservoirs, 79% of lake water bodies and 100% of transitional and coastal water bodies. Despite 
the very high monitoring coverage, less than 70% of lakes and rivers are classified on the basis of 
monitoring data, which raises the question why not all monitoring data are used for classification. 

According to Polish authorities, all required biological quality elements are monitored14, although the 
information provided in the RBMPs is not clear enough to find evidence of monitoring of biological 
quality  elements  (BQEs)  for  rivers  and  lakes.  For  BQEs  in  transitional  and  coastal  waters,  Poland 
indicates  that the monitoring  of macroalgae (seaweed  such  as  kelps),  phytoplankton  (algae),  and 
angiosperms are not applicable.  

25 The hydropower sector in Poland: Historical development and current status: https://doi.org/10.1016/j.rser.2022.112150 
26 EASIN - European Alien Species Information Network: https://easin.jrc.ec.europa.eu/easin/  
27 There are two types of monitoring: i) operational monitoring to determine the status and which covers all water bodies 
at risk and ii) surveillance monitoring aimed rather at identifying impacts and long-term changes. 

15 

 
 
Status assessment 

No information could be found on the methods developed for the classification of ecological status 
for hydromorphological and physico-chemical quality elements, and whether they are compliant with 
the  WFD  or  linked  to  good  status  for  the  relevant  biological  quality  elements.  However,  Poland 
conveyed  that  the  reference  conditions  for  physico-chemical  quality  elements  in  the  definition  of 
good ecological potential are listed in the regulation of the Ministry of Infrastructure28. 

Equally, we note with concern that it is not clear whether Poland has identified river basin specific 
pollutants (RBSPs),  how  they  are  monitored,  and  whether  they  have  affected  the  classification  of 
surface water bodies. No information could be found on the worse RBSPs that cause the failure to 
achieve good ecological status. 

No positive development in the status of surface water bodies can be observed. Based on electronic 
reporting, Figure 4 shows that over 90% of surface water bodies do not reach good ecological status 
/ potential in the 3rd RBMPs. In fact, regrettably, the proportion of water bodies in good ecological 
status has considerably decreased, and only 8 water bodies are in high ecological status. Moreover, 
we note with concern that the proportion of water bodies in the two lowest classes (poor and bad) 
has considerably increased. The lakes have the highest proportion of water bodies in bad ecological 
status; and it seems that none of the transitional and coastal water bodies reach good ecological 
status either.  

Figure 4. Ecological status or potential of surface water bodies (SWBs) in Poland in the 1st, 2nd, and 3rd 
RBMPs. 

Source: WISE electronic reporting 

28 Rozporządzenie w sprawie klasyfikacji stanu ekologicznego, potencjału ekologicznego i stanu chemicznego oraz 
sposobu klasyfikacji stanu jednolitych części wód powierzchniowych, a także środowiskowych norm jakości dla substancji 
priorytetowych (25 June 2021): https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20210001475  

16 

 
 
 
Indeed, 94% of river water bodies in the Vistula RBD and 95% in the Oder RBD are subject to such 
significant changes caused by anthropogenic pressures that they are at risk of failing to achieve the 
environmental objectives. 61% of lake water bodies in the Vistula RBD and 71% in the Oder RBD are 
at risk of not achieving the environmental objectives. More information about the type of pressures 
has been presented in section 2.2. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

Not much is given by the RBMPs regarding the methodology of designation of heavily modified water 
bodies and artificial water bodies in the Oder and Vistula RBMPs. The methodology for the designation 
of heavily modified water bodies is developed at national level and addresses the significant adverse 
effects of mitigation and restoration measures on the current use and the wider environment. It also 
assesses  the  other  means  to  achieve  the  same  beneficial  objective  served  by  the  current 
modifications.  It is  worth noting  that  Poland  has  developed  a  hydromorphological  index for  rivers 
which measures the degree of deviation from the natural conditions with respect to hydrological and 
morphological alterations. Similar indices exist for lakes, transitional and coastal water bodies but 
these indices were not explained in more detail. Regarding hydromorphological pressures, only dams 
are  mentioned  causing  physical  alteration,  and  they  are  associated  with  hydropower  and  flood 
protection. 

In its comments29, Poland describes in more detail the method to define good ecological potential 
(GEP), but this information was not provided in the RBMPs or in the reported background documents.  

According to WISE electronic reporting, only 8% of HMWBs and AWBs are in good ecological potential 
while 92% are in less than good ecological potential or unknown as follows: 319 in moderate, 192 in 
poor, and 114 in bad ecological potential; the status of 139 HMWBs / AWBs is unknown. Figure 5 
shows the ecological potential of HMWBs and AWBs by water categories. Regrettably, the proportion 
of water bodies with unknown ecological potential is very high (in average 20%) and it is not clear 
what are the reasons for flawed classification. 

Figure 5. The ecological potential of heavily modified water bodies (HMWBs) and artificial water bodies 
(AWBs) by water categories. 

29 Subsequent comments provided in March 2024 from the Ministry of Infrastructure. 

17 

 
 
 
Source: WISE electronic reporting 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Because of lack of aggregated data in the RBMPs, it is not clear how many water bodies are covered 
by quantitative monitoring and how many monitoring sites have been used. The methodology for 
groundwater  quantitative  status  assessment  is  described  in  the  3rd  RBMPs  and  considers  the 
assessment of water balance, long-term groundwater level trends and pressure head, as well as the 
assessment of impacts on groundwater dependent terrestrial  ecosystems and the assessment of 
saline or other intrusions. However, Poland has not identified any Natura 2000 areas associated (see 
section 3.4)  with groundwaters which leaves uncertainty how impacts on groundwater dependent 
terrestrial  ecosystems  has  been  assessed.  The  Polish  quantitative  status  assessment  includes 
therefore uncertainties, especially in regions with Natura 2000 areas. 

Despite of the large proportion (91%) of groundwater bodies in good quantitative status (see Figure 
6), there are still 15 groundwater bodies not meeting the objective of good quantitative status. There 
seems to be a deterioration compared to the 2nd RBMPs, as there is an increase of two groundwater 
bodies in poor quantitative status. Subsequently, 21% of groundwater bodies in the Vistula RBD and 
32% in the Oder RBD are at risk of failing to achieve environmental objectives.  

According to the 3rd RBMPs of the Oder RBD (PL6000) and Vistula RBD (PL2000), the main reason for 
the failure of good quantitative status is lowering of groundwater levels as a result of drainage for 
mining or as a result of water abstraction for public water supply and industry. There are also cases 
where drainage and overabstraction lead to negative impacts on groundwater dependent terrestrial 
ecosystems, as well as to saline intrusions, due to ingress or upwelling of saline waters from drained 
groundwater layers. 

Figure 6. Quantitative status of groundwater bodies (GWBs) in Poland in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

18 

 
 
3.4 Protected Areas (identification, monitoring, objectives and measures) 

There  are  several  reasons  why  certain  water  bodies  are  protected  under  the  EU  legislation.  For 
surface water bodies, protected areas have been designated under the Drinking Water, Bathing Water, 
Habitats  and  Birds  Directives  as  well  as  for  areas  designated  for  the  protection  of  economically 
significant aquatic species (e.g. aquaculture). Additionally, Nitrates Vulnerable Zones/Nitrate Sensitive 
Areas are designated under the Nitrates Directive and the Urban Waste Water Treatment Directive. 
For groundwaters, protected areas are designated under the Drinking Water and the Habitats and 
Birds Directives.  

Poland  has  identified  all  types  of  protected  areas  which  are  associated  with  surface  waters  and 
groundwaters (Table 3). Since the 2nd RBMPs, there have been some changes in the number of water 
bodies associated with protected areas. The most significant changes concern the Natura 2000 areas 
where we see an increase from 189 to 3 789 water bodies, and Bathing Water Directive, increase 
from  123  to  517  bathing  waters.  Unfortunately,  no  information  could  be  found  to  explain  these 
changes. 

Table 3. Number of water bodies included to the protected areas listed in Annex IV to the WFD which are 
associated with surface and groundwaters in the 3rd RBMPs. 

Areas with special protection  

Drinking Water Protection Zones 

Bathing Waters 

Natura 2000; Birds and Habitats Directives 

Nitrate Vulnerable Zones 

Protection of economically significant aquatic species 

Source: Data mining of the 3rd RBMPs 

Number of water bodies associated with 

Surface water  

Groundwater  

179 

517 

3 789 

4 240 

180 

174 

0 

0 

0 

0 

As regarding groundwaters, all 174 water bodies are associated with the drinking water protected 
areas. Surprisingly, there are no Natura 2000 areas associated with the groundwaters, despite the 
high proportion of land designated as Natura 2000 in the country. This entails that no groundwater 
dependent  terrestrial  ecosystems  seem  to  have  been  considered  in  the  assessment  of  the 
quantitative status of groundwaters. 

As many other Member States, Poland has designated all its territory as a Nitrate Vulnerable Zone 
or  Nitrate  Sensitive  Area  according  to  the  Nitrates  Directive  and  Urban  Waste  Water  Treatment 
Directive, respectively.  

No detailed information is provided about additional objectives for protected areas, nor information 
can  be  found  regarding  additional  measures  set  for  protected  areas.  There  are  general  mentions 
about non-deterioration requirement of water quality for water bodies designated as drinking water 
protection zones, as well as environmental objectives for water bodies related to Natura 2000 areas 

19 

 
which are based on the requirements of these areas. These are very general objectives and do not 
give a sufficient picture of improvement of status of water bodies related to protected areas. 

3.5 What is being done to prevent/reduce hydromorphological pressures 

As  an  outstanding  approach,  Poland  shall  be  praised  for  its  methodology  of  ranking  measures 
according  to  socio-economic  effect 
in  the  Oder  RBD.  The  actual  measures  to  tackle 
hydromorphological pressures include e.g., fish ladders, habitat restoration, and building spawning 
and  breeding  areas.  However,  specific  measures  to  improve  lateral  connectivity  by  restoring 
floodplains and river banks could not be found. It is also not clear if there are measures to improve 
hydrological conditions of surface waters. It seems that ecological flow has been partially defined 
and  implemented  for  water  bodies  located  in  protected  areas;  however,  work  is  still  on-going  to 
update  the  definition  by  including  biological  aspects.  In  its  comments14,  Poland  states  that 
environmental flow is considered in the permitting as a minimal flow to ensure the preservation of 
the protected areas.  

Poland  has  introduced  in  2020  a  national  handbook30  which  sets  the  objectives  for  restoration 
measures, provides practical aspects to the restoration process, and introduces restoration examples, 
including nature-based solutions to mitigate floods and droughts. The programme concludes that all 
surface  water  bodies  in  Poland  require  restoration  measures  to  improve  hydromorphological 
conditions including river and floodplain retention, restoration of wetlands and peatlands, restoration 
of longitudinal continuity and diversity of water bodies. Poland considers that some measures can 
be classified as nature-based solutions and they provide social and economic benefits, but it is not 
clear how nature-based solutions are prioritised. 

No  aggregated  data  is  provided  on  the  number  of  water  bodies  subject  to  measures  to  tackle 
hydromorphological pressures. Despite listing measures at water body level in the RBMPs, Poland 
fails to provide any estimation of the effect of measures on biological and other quality elements 
and only introduces an overall assessment of measures rating environmental, social, and economic 
effects.  

In terms of basic measures, there is an authorisation and / or permitting regime in place to control 
physical modifications according to WFD. No information can be found on the permitting of water 
impoundments (reservoirs, dams, etc.) in the reported RBMPs. It is not clearly described how permits 
related  to  hydromorphological  alteration  of  surface  waters  are  reviewed.  However,  it  is  said  that 
permits might be revoked for water bodies at risk not meeting the environmental objectives. Poland 
has an index for barriers and other dam constructions which can be envisaged as a register, but this 
register is not mentioned to include other structures altering hydromorphological characteristics of 
surface waters. 

3.6 What Poland is doing for abstractions and water scarcity 

Water abstraction is not identified as a significant pressure in Poland. The current estimation of the 
annual Water Exploitation Index Plus (WEI+) in Poland varies between 5.5 and 10.5 for the period 
2000-201931,  while  water  scarcity  is  generally  considered  to  occur  when  the  ratio  of  water 
abstraction to long-term average available water resources exceeds 20. Yet, as mentioned earlier, 

30 Podręcznik dobrych praktyk renaturyzacji wód powierzchniowych: https://www.gov.pl/web/wody-polskie/krajowy-
program-renaturyzacji-wod-powierzchniowych  
31 Water exploitation index, plus (WEI+) from 2009 to 2019: 
https://ec.europa.eu/eurostat/databrowser/bookmark/8e6c6e33-3a7c-4c9a-b6c7-11710a1fbba0?lang=en 

20 

 
 
renewable freshwater resources in Poland are quite scarce and seem to point to water stress given 
the large demands of users.  

In 2016-2021, the average annual water abstraction in Poland was approximately 10 billion cubic 
metres of which over 75% amounts of surface waters and 25% of groundwaters32. The main users 
are cooling of electricity production, public water supply and agriculture. According to the 3rd RBMPs, 
water abstraction is mainly estimated based on available permit data, while abstractions exceeding 
the  permitted  volumes  or  non-permitted  abstractions  are  missing,  most  likely  causing  an 
underestimation of abstracted volumes. 

The RBMPs are not showing how many groundwater bodies are subject to significant pressure from 
abstraction.  Poland  lists  each  water  body  and  its  pressures  in  annexes  to  the  RBMPs,  but  no 
aggregated data is available of number of water bodies which are subject to significant abstraction. 
According  to  the  electronic  reporting,  there  are  5  river  water  bodies  and  51  groundwater  bodies 
identified with significant pressures of abstraction. 

There is an authorisation and / or permitting regime to control surface and groundwater abstractions, 
and furthermore, there is a register of abstractions from both surface water and groundwater. Poland 
requires an authorisation for any abstractions except for ordinary water use33 and permits are limited 
in time. 

3.7 Adaptation to climate change 

There is limited information on the impacts of climate change on water management in the RBMPs, 
and  some measures  are  indicated  to  be  adaptation  measures.  Not much  is included  in the  plans 
regarding risk assessment and analysis of the impacts of climate change on environmental objectives 
of water bodies. An analysis of the impacts of drought on the ecological / chemical status of surface 
water bodies has been included in the Oder RBMP which shows that droughts could potentially lead 
to the deterioration of 13.4% of water bodies from good to less than good. 

Poland  defines  the  prolonged  drought  as  “a  phenomenon  consisting  of  the  occurrence  of 
a hydrological or hydrogeological drought at the local, subregional or regional level […] which may 
result in limitations in the possibility of using water, access to water services or the possibility of 
agricultural  or  forestry  production.”  Indeed,  drought  is  a  regular  phenomenon  in  Poland,  and  it  is 
expected in the future that water will be scarce more frequently and longer compared to previous 
decades34.  However,  the  Oder  and  Vistula  RBMPs  indicate  insignificant  changes  to  availability  of 
surface and groundwater resources in the short (2050) and long term (2100) which is a contradiction 
with the  assessment  of  droughts  potentially leading  to  deterioration  of  water  bodies  in the Oder 
RBMP.  

It is welcomed that, in 2021, Poland adopted a national plan to counteract drought impacts34 with 
four  specific  objectives:  effective  management  of  water  resources  to  increase  available  water 
resources;  increasing  water  retention  (storage);  drought  education  and  coordination  of  drought-
related activities; and creating mechanisms for the implementation and financing of activities aimed 
at  counteracting  the  effects  of  drought.  However,  according  to  the  analysis  commissioned  by  the 

32 Eurostat - Annual freshwater abstraction by source and sector (not considering leakages or evaporation from the 
surfaces of reservoirs and canals after abstraction): https://ec.europa.eu/eurostat/databrowser/bookmark/766ea785-adc5-
48cc-bbd7-299ee3e66074?lang=en  
33 The “ordinary water use” allows the land owner to abstract up to 5 cubic metres of surface or groundwater daily, Art. 
33(4)(1) of Water Law: https://isap.sejm.gov.pl/isap.nsf/download.xsp/WDU20170001566/U/D20171566Lj.pdf  
34 Plan przeciwdziałania skutkom suszy: https://dziennikustaw.gov.pl/D2021000161501.pdf  

21 

 
 
European  Commission35,  the  Polish  plan  primarily  focuses  on  water  retention  infrastructure 
measures, and it does not concretely suggest organisational, operational and follow-up measures for 
drought event crisis management, e.g., water allocation priorities, relief / response measures. 

While the River Basin Management Plans do not include a lot of information on possible impacts of 
climate change, in the Vistula RBMP, 95 measures are assigned as adaptation measures, including 
protection of habitats / species; wastewater management; controls of fish migratory; and reduction 
of pollutant runoff. In the Oder RBMP, 25 of measures are  linked to the climate change; however, 
there is a lake reclamation measure included in the RBMP which decreases the retention area and 
hence might indicate maladaptation to climate change. 

Flood management 

The Floods Directive requires to consider the impacts of climate change on the occurrence of floods, 
and therefore in the preparation of Flood Hazard and Risk Maps (FHRMs) and Flood Risk Management 
Plans (FRMPs). More information on these can be found in Section B. However, considering the close 
relationship  between  overall  water  management  and  floods  management  and  the  importance  of 
climate change on both, consideration climate change is jointly addressed in this section.  

The second FHRMs, similarly to the first FHRMs, took climate change into account only for coastal 
flooding and as a factor affecting rising water levels in its calculations. The rise in sea level along the 
Polish Baltic seacoast as a result of climate change was factored into the model for calculating the 
level of water with a specified likelihood of exceedance. An increase for 2011-2030 of 5 cm was 
considered  for  the  flood  hazard  maps.  Results  from  the  CLIMATE  project36,  which  in  turn  used 
scenarios  developed  by  the  Intergovernmental  Panel  on  Climate  Change  (IPCC),  were  used  in  the 
methodology37. 

The  FRMPs  review  projected  impacts  of  climate  change  on  flooding.  The  FRMPs  explain  that  the 
impact of climate change on flood occurrence was considered at the stage of comparing the planning 
scenarios;  in  particular,  potential  changes  in  high  water  flows  in  the  period  2021-2050  were 
considered. The FRMPs do not, however, refer to EU or national climate adaptation strategies. On the 
other  hand,  they  state  that  long-term  developments,  including  climate  change,  were  taken  into 
account during the assessment of alternative sets of actions for the “problem areas”38. Climate model 
projections indicate a future increase in mean annual precipitation for Poland, although there will be 
changes in the temporal distribution: precipitation will increase most in winter (with an increasing 
share of rain and a decreasing share of snow), while in spring and autumn precipitation will increase 
to a lesser extent. The projections of summer precipitation do not agree, however, whether overall 
there will be less or more precipitation. Climate change is nonetheless expected to exacerbate flood 
risks due to increased intensity and volume of rainfall events. 

35 Schmidt et al., (2023). Stock-taking analysis and outlook of drought policies, planning and management in EU Member 
States: https://op.europa.eu/s/zicm  
36 https://klimat.imgw.pl/ 
37 A team of IMGW-PIB (Institute of Meteorology and Water Management - National Research Institute) experts developed 
scenarios of sea level changes for the main mareographic stations for selected greenhouse gas emission scenarios (B1, 
A1B, A2), for the years 2011-2030 and 2081-2100, taking into account the influence of the circulation factor and 
expected changes in global sea level according to the IPCC. The project duration was from 2007 to 2013. 
38 A problem area is an area at risk of flooding for which the average annual potential flood losses are exceptionally high 
and therefore require urgent intervention. 

22 

 
 
4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

Poland has improved the coverage of monitoring for assessing chemical status since the 1st and 2nd 
RBMPs. In the 3rd RBMPs, the monitoring is already covering 42% of river water bodies, 60% of lake 
water  bodies,  and  100%  of  transitional  and  coastal  water  bodies.  All  45  priority  substances  are 
included  in  the  monitoring  programmes.  For  the  priority  substances  that  tend  to  accumulate  in 
sediment and / or biota, Poland has addressed the monitoring frequencies and methodologies of all 
relevant substances in their regulation39. In the RBMPs no aggregated data is available of the number 
of monitored water bodies. 

Status assessment – Evolution of chemical status of surface water bodies since the 2nd 
RBMPs 

The  ubiquitous,  persistent,  bioaccumulative  and  toxic  substances  identified  in  Poland  are 
(PBDEs), 
polyaromatic  hydrocarbons 
hexabromocyclododecane,  heptachlor  and  heptachlor  epoxide,  and  perfluorooctane  sulphonic  acid 
(PFOS). Based on electronic reporting, Figure 7 shows the proportion of surface water bodies affected 
by top-10 substances which are causing the failure to achieve good chemical status. 

(PAHs),  mercury,  polybrominated  diphenyl  ethers 

Figure 7. The top-10 Priority Substances causing failure to achieve good chemical status in surface water 
bodies in Poland with addition of one new priority substance. 

Note: The new priority substance according to the 2008/105/EU as amended by 2013/39/EU40 is marked with asterisk (*). 

Source: WISE electronic reporting 

Figure 8 depicts that overall, 24.8% of all surface water bodies (1 050) are in good chemical status, 
53.5% (2 268) are in poor chemical status and a considerable share of 21.7% (992) are with unknown 

39 Rozporządzenie Ministra Infrastruktury z dnia 13 lipca 2021 r. w sprawie form i sposobu prowadzenia monitoringu 
jednolitych części wód powierzchniowych i jednolitych części wód podziemnych: 
https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20210001576  
40 Directive 2008/105/EC as amended by Directive 2013/39/EU added 12 new substances i.e. numbered 34 to 45 to the 
priority substance list. For the 3rd RBMP, Member States have only had the obligation to monitor them. Compliance with 
the Environmental Quality Standard values for these 12 new priority substances will be assessed in 2027. 

23 

 
 
 
status. Strikingly, the number of unknowns has increased compared to the 2nd RBMPs, i.e., from 829 
to  992.  Equally,  it  is  noted  with  concern  that  compared  to  the  2nd  RBMPs,  there  is  a  significant 
deterioration, as the number of water bodies in good chemical status has dropped from 3 331 to 
1 050. It is not clear whether this drastic change is due to improved monitoring, to changes in the 
delineation of water bodies, or to increased chemical discharge/pressure. Poland has estimated the 
proportion of water bodies, which are in good chemical status by 2027, is exceeding to 50%. 

Figure 8. Chemical status of surface water bodies (SWBs) in Poland in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

Poland  has  included  all  groundwater  bodies  into  the  monitoring  for  chemical  status,  and  all 
substances  causing  risk  of  deterioration  are  mentioned  to  be  monitored.  The  coverage  of  both 
surveillance and operational monitoring has improved. However, it is not clear, if substances causing 
risk of deterioration41 of chemical status are subject to monitoring of groundwaters in all RBDs. 

Status assessment 

In its status assessment, Poland has considered also the groundwater associated aquatic ecosystems 
and  groundwater  dependent  terrestrial  ecosystems.  It  has  established  thresholds  to  assess  the 
impact on these ecosystems. However, Poland has not identified any Natura 2000 areas associated 
with  groundwaters  (see  section  3.4)  which  leaves  uncertainty  how  impacts  on  groundwater 
dependent terrestrial ecosystems has been assessed. Nonetheless, the intrusion of saline and other 
pollutants has been also considered. 

41 Substances in GWD Annex I and Annex II (Part B) and core parameters in WFD Annex V section 2.4.2  

24 

 
 
 
It is noted very positively that, according to the data provided, almost all groundwater bodies are in 
good chemical status, i.e., 95% of all groundwater bodies (165). Figure 9 depicts that since the 2nd 
RBMPs, the chemical status of groundwaters has improved from earlier 14 to 9 groundwater bodies 
in poor chemical status. For the Vistula and Oder RBDs, Poland explains that the main reason for the 
failure of good chemical status is diffuse pollution from urban and mining activities, as well as saline 
intrusion caused by ingress or upwelling of saline waters from drained groundwater layers. 

The  top  5  pollutants  causing  failure  to  achieve  good  chemical  status  of  groundwater  bodies  are 
mentioned to be potassium, nitrates, chloride, sodium, and iron. However, on one hand, potassium, 
sodium, and iron are not among those pollutants which are used for the assessment of chemical 
status of groundwaters, but on the other hand, they affect the conductivity which is an indicative 
parameter of saline or other intrusions. 

Figure 9. Chemical status of groundwater bodies (GWBs) in Poland in the 1st, 2nd, and 3rd RBMPs. 

Source: WISE electronic reporting 

4.3 What Poland is doing to combat pollution from agriculture 

As mentioned earlier, agriculture plays a great role in the Polish economics, and it is exerting pressure 
on the status of both surface waters and groundwaters. This has led the country to designate the 
whole territory as a Nitrates Vulnerable Zone. Poland indicates that the measures to tackle pollutants 
from agriculture are implemented in the action plan defined by the Nitrates Directive42. Poland has 
not assessed the need for reduction of nutrient loads or pesticide use from agriculture and has not 
introduced  the  measures  to  bridge  these  gaps  to  achieve  the  environmental  objectives  of  WFD. 
Moreover, not all measures from the 2nd RBMPs have been implemented due to financial constraints 
and lack of knowledge. 

42 Programu działań mających na celu zmniejszenie zanieczyszczenia wód azotanami pochodzącymi ze źródeł rolniczych 
oraz zapobieganie dalszemu zanieczyszczeniu: https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20200000243  

25 

 
 
 
The measures described in the 3rd RBMPs are very general  and do not allow to conclude to what 
extent  they  will  reduce  agricultural  emissions.  Among  the  measures,  Poland  mentions  control 
activities to reduce diffuse pollution from agriculture; educational and advisory activities for farmers; 
control  activities  to  the  use  of  pesticides;  and  voluntary  application  of  actions  for  improving 
agricultural  practices.  The  Polish  CAP  strategic  plan  2023-2027  is  focussing  on  soil  health  and 
protection of wetlands and peatlands which will have positive effects and the related water bodies 
and on water infiltration and retention43. Wetting peatlands will also reduce the nitrogen emissions 
related to oxidation of the peat exposed to air. Poland aims to almost double its present low share 
of organic farming from 2.5% to 4.5% by 2030.44 Subsequently, there is a list of national measures 
and specific measures in the RBMPs. One concrete measure is setting buffer strips for lakes but even 
here no information is provided on how many lake water bodies are subject to this measure. Poland 
provides no further measures to tackle hydromorphological impacts by agriculture. 

To  improve  quantitative  status  of  groundwater,  Poland  mentions  measures  to  reduce  water 
consumption, foster water-saving irrigation techniques, improve retention of rainwater, and slowing 
the  run-off  from  the  catchment  area.  However,  there  is  no  further  description  of  what  specific 
measures are implemented and what can be expected to be achieved. 

4.4 What Poland is doing to combat pollution from other sectors 

Poland  indicates  that  several  basic  measures  related  to  reduction  of  emission  from  industry, 
wastewater treatment, urban areas, tourism, and transportation are needed to tackle pollution not 
related to agriculture. However, the measures are mentioned in general terms with no details of the 
concrete actions or no information of the expected results to be achieved by the measures. It is also 
not clear how many water bodies are subject to measures. 

According to reporting of the UWWTD in 2018, 87% of urban wastewater is treated in line with EU 
legislation in Poland and there is still room for improvement in collecting and treating wastewater45. 

Poland has not provided a gap assessment to estimate how much pollution needs to be reduced in 
order to achieve the WFD objectives. It is also unclear whether Poland is working on reducing pollution 
loads by means of revising existing water pollution permits. It is a paramount to address remaining 
persistent pollution challenges that will worsen due to climate change. Doing so would also be in line 
with the findings of the EU analysis report of the 2022 ecological disaster in the Oder River46. The 
report recommended to review existing permits for industrial emissions and wastewater discharges 
to lower pollutant loads and introduce obligations to temporarily suspend or limit discharges in case 
of emergencies. 

4.5 What Poland is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

Overall, a total of 171 various national measures have been included in the Vistula and Oder RBMPs; 
115 are basic measures and 56 supplementary measures. For surface waters, the measures have 

43 Mapping and analysis of CAP strategic plans (2023-2027): https://agriculture.ec.europa.eu/common-agricultural-
policy/cap-overview/cmef/regulation-and-simplification/mapping-and-analysis-cap-strategic-plans_en 
44 At a glance: Poland’s CAP Strategic Plan: https://agriculture.ec.europa.eu/document/download/7716493a-28a0-4a7c-
a66d-e54803e42bdd_en?filename=csp-at-a-glance-poland_en.pdf  
45 WISE – country profiles on urban waste water treatment – Poland: 
https://water.europa.eu/freshwater/countries/uwwt/poland 
46 An EU analysis of the ecological disaster in the Oder River of 2022: 
https://publications.jrc.ec.europa.eu/repository/handle/JRC132271  

26 

 
 
been assessed at a water body level by using a cost-effectiveness analysis including effectiveness 
criteria, feasibility, number of pressures to be reduced, and the time for the action to be effective. 
However,  similar  information  is  not  provided  for  groundwaters.  Subsequently,  Poland  does  not 
indicate the number of water bodies for each measure. There is no aggregated information on how 
many water bodies, in less than good status, have been linked to the Programme of Measures. 

Regarding the costs of measures, a total of PLN 22.7 billion is estimated for Poland. 

The planning of measures takes into consideration several aspects, such as Flood Risk Management 
Plans, Surface Water Restoration Programmes, etc., without explicitly indicating the relative priority 
of these aspects. The measures are linked with the significant pressures in Vistula and Oder RBDs, 
and in terms of rivers and groundwaters, in all RBDs. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Poland 

As the good status has not been achieved in all water bodies by 2015, Poland has applied several 
exemptions. Figure 10 shows the use of exemptions according to Art. 4(4) and 4(5) and Table 4 shows 
in more detail the number of exempted groundwater bodies and surface water bodies, per type of 
exemption  applied.  However,  no  aggregated  information  is  provided  to  distinguish  the  number  or 
percentage of water bodies exempted for ecological status, chemical status, or quantitative status. 
Unfortunately,  the  data  provided  does  not  suffice  to  compare  the  number  or  proportion  of  water 
bodies exempted compared to the 2nd RBMPs. 

For exemptions under Art. 4(4) and 4(5), Poland introduces in its RBMPs a step-by-step approach to 
support the decision. It is worth noting that the detailed and quite comprehensive justifications for 
the use of exemptions under Art. 4(4) and 4(5) WFD are introduced in Annex 18 to the RBMPs at 
water body level and exemptions under Art. 4(7) WFD are introduced in Annex 10 to the RBMPs at 
project level with indications of all affected water bodies.  

Figure 10. The use of exemptions according to Art. 4(4) and 4(5) WFD in surface water bodies (SWBs) and 
groundwater bodies (GWBs) in Poland. 

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

4(4) SWBs

4(4) GWBs

4(5) SWBs

4(5) GWBs

technical feasibility, other means and / or disproportionate costs

natural conditions

Source: Data mining of the 3rd RBMPs 

27 

 
 
Table 4. The use of exemptions in Poland in the 3rd RBMPs. 

Article  Groundwater bodies (GWBs) 

Surface water bodies (SWBs) 

4(4) 

0 GWBs (0% of all GWBs) on grounds of technical 
infeasibility and / or disproportionate costs 

825 SWBs (19% of all SWBs) on grounds of technical 
infeasibility and / or disproportionate costs 

10 GWBs (6%) on grounds of natural conditions 

3 320 SWBs (76%) on grounds of natural conditions 

4(5) 

13 GWBs (7%) on grounds of other means and / or 
disproportionate costs 

2 209 SWBs (52%) on grounds of other means and / 
or disproportionate costs 

9 GWBs (5%) on grounds of natural conditions 

503 SWBs (12%) on grounds of natural conditions 

4(6) 

Not applied 

Not applied 

4(7) 

In total 254 investment projects (no aggregated data about the number of affected water bodies) 

GWD 
6(3) 

Not applied 

Source: Data mining of the 3rd RBMPs 

- 

5.2 Use of economic analysis and water pricing – cost recovery 

The  largest  RBMPs  mention  or  refer  to  items  in  the  economic  analysis  which  is  reported  in  an 
elaborate background study, together with the cost recovery rate calculations. However, the RBMPs 
do not provide a summary on the key data and also remains rather unclear on the progress made in 
the economic analysis since the 2nd RBMP.  There are some concerns that the analysis may not have 
taken into account the new rules on the water service’ tariffication applicable since 2018.  

Poland  defines  a  range  of  water  services,  such  as  public  water  supply,  sanitation  services, 
impoundments, and water storage, and also a variety of other water uses. The RBMPs mention future 
water  supply  and  demand,  respectively  differentiated  over  sources  and  water  user  sectors,  but 
without any quantitative forecasts. Poland has not evaluated the current investments nor estimated 
the investment needs in the future. The only available information about water tariffs is that there is 
a  single  price  for  the  joint  provision  of  public  water  supply  and  sanitation  services, differentiated 
across regions and user sectors, i.e., households and industry. There is no explicit account on whether 
the water pricing policy provides adequate incentives to use water efficiently. 

The  RBMPs  introduce  two  cost  recovery  figures  for  each  of  the  three  broad  water  user  sectors 
households, agriculture, and industry, one with only financial costs and one also taking environmental 
costs on board; all figures pertain to the year 2018. However, no information can be found about the 
methodology. Public water supply and wastewater sanitation is reported as profitable with  revenues 
exceeding  financial  costs with  5.1%. However,  the  overall  financial  cost  recovery  rate  amounts to 
19.5% and 100% for agriculture sector and industry, respectively. The RBMPs do not seem to explain 
which mitigation factors justify the much lower cost recovery for agriculture. It also remains unclear 
how the reported losses on provisions of water supply and sanitation in some areas in Poland are 

28 

 
addressed. The disparity is even more pronounced for the the broader cost recovery rate (i.e. with 
environmental costs). A total national average cost recovery rate of 97.4% is reported for the public 
water supply and sanitation, and 82.6% for industry (in 2017), while the corresponding rate for the 
agricultural sector is only 2.7%, taking into account both environmental costs and unpaid fees for 
water  abstraction.  Indeed,  the  pollution  mitigation  measures  in  agriculture  are  subsidised  mainly 
through  the  CAP.  The  Polluter-Pays-Principle  is  mentioned,  but  only  in  the  form  of  a  general 
assurance, that it is applied.  The RBMPs do not provide an account whether the broad water user 
sectors provide an adequate contribution to the recovery of water services’. 

6. WFD recommendations 

For the preparation of the European Semester 2025, a proposal for a Council recommendation notes that Poland 
should take action in 2024 and 2025 to “improve policies related to the protection and sustainable use of water 
resources to ensure the long-term sustainability of sectors that rely on ecosystem services”47. 

Moreover, Poland should: 

1.  Address the identified lack of compliance of achieving good status by increasing the level of ambition and 

reducing the compliance gap as much as possible until the next reporting cycle; 

2. 

3. 

Increase  the  investments  and  ensure  adequate  financing  in  prevention  and  restoration  to  ensure 
achievement of good status as required by the Directive e.g., by making better use of the ‘polluter-pays 
principle’  and  by  eliminating  environmental  harmful  subsidies  whilst  ensuring  affordable,  just  and 
implementing fair pricing mechanisms for all water users in line with Article 9 WFD. This should be based 
on  a  robust  economic  evaluation  of  measures  to  improve  the  cost-effectiveness  analysis  and  the 
prioritisation of measures as well as a better estimation of the investments applied as well as the funding 
needs; 

Identify and put in place all basic measures and necessary supplementary measures to reduce existing 
persistent  environmental  challenges  (pressures)  preventing  the  achievement  of  good  status  as  those 
pressures  will  be  aggravated  by  climate  change  (e.g.,  pollution  concentrates  in  times  of  less  water 
availability). 

This implies, for example: 

a)  Reduction of nutrient pollution including the setting and achievement of maximum nutrient loads in all 
river  basin  districts  to  achieve  the  objectives  of  WFD,  MSFD  and  ND  with  particular  focus  on  the 
vulnerability of the Baltic Sea; 

b)  Addressing pesticide pollution by reducing their use and phasing out unsustainable practices as well as 
the  emissions  of  most  relevant  priority  substances  and  rivers  basin  specific  pollutants  (namely 
polyaromatic  hydrocarbons 
(PBDEs), 
hexabromocyclododecane,  heptachlor  and  heptachlor  epoxide,  and  perfluorooctane  sulphonic  acid 
(PFOS)); 

(PAHs),  mercury,  polybrominated  diphenyl  ethers 

c)  Further prevention and reduction of point source pollution to address nutrients and priority substances 
and  river  specific  pollutants  e.g.,  by  reviewing  existing  permits  for  point  source  emissions  to  lower 

47 Recommendation for a COUNCIL RECOMMENDATION on the economic, social, employment, structural and budgetary 
policies of Poland, dated 19 June 2024: https://commission.europa.eu/document/download/cc8db0cb-8fa3-4dfb-98d5-
7751a0f6f5c8_en?filename=com_2024_621_1_en.pdf  

29 

 
 
pollutant  loads  or  introduce  obligations  to  temporarily  suspend  or  limit  discharges  in  case  of 
emergencies (like the low flow conditions during the Oder ecological disaster); 

d)  Expanding the efforts on nature-based solutions including re-naturalisation and ecosystem restoration 
which will reduce the hydromorphological pressures on its water bodies (e.g., reducing pressures from 
agricultural drainage); 

e)  Stepping up efforts to improve river continuity, ensuring minimum ecological flows, improve the general 

hydrological conditions also in cooperation with neighbouring countries; 

f)  As considering increased dry periods and the risk of over-abstraction, a wide use of abstraction permits 
and  fees  for  all  water  users, monitoring  the  actual  abstracted  amounts,  and  harmonisation  of  the 
inconsistent use of exemptions from water fees with the aim to ensure a balance between abstraction 
and recharge of water bodies in which withdrawals take place, with the aim of good quantitative status 
of groundwaters and good hydrological conditions of surface waters; 

g) 

Including a clear provision on periodical review of abstraction and impoundment permits as well as 
other permits related to hydromorphological changes and describing how this review is implemented 
in the following RBMPs; 

h)  Setting specific measures to achieve the additional objectives for all protected areas under relevant 

Directives and ensuring their link to the WFD implementation. 

4.  Enhance the consideration of climate change in all RBMPs and / or develop regional drought management 
plans  where  droughts  are  foreseen  to  causing  problems  to  the  economics  and  society.  Although  not 
explicitly  required  by  the  Directive,  failure  to  do  so  will  make  it  increasingly  difficult  to  achieve  the 
Directive’s objective and, in some case, even lead to a deterioration of waters where progress has been 
achieved. 

5. 

Improve  further  governance  and  better  coordinate  between  the  different  administrative  levels  and 
authorities dealing with the implementation of the WFD and other related pieces of legislation. This also 
includes  removing  obstacles  identified  in  the  implementation  of  measures,  such  as  insufficient 
administrative capacities and resources. 

Moreover, Poland should: 

a)  Public consultation of the significant water management issues as stipulated in Article 14 WFD; 

b) 

Improving the work on international River Basin Management Plans, especially, for the Oder River Basin 
to achieve and retain the good status of surface waters and groundwaters; 

c)  Aspiration  to  achieve  agreement  with  neighbouring  countries  to  uniform  the  characterisation  of 

transboundary water bodies; 

d) 

Improving the comparability of status assessment with other EU countries, specifically regarding the 
assessment of physico-chemical and hydromorphological conditions related to their sensitive biological 
quality elements. 

6.  Ensure that the application of sufficiently justified exemptions is regularly reviewed for each water body 
which cannot meet the objectives of Article 4(1) and ensure that the application of exemptions is regularly 
reviewed. 

7. 

Further close knowledge gaps and improve data availability, access to data, as well as data quality and 
comparability by harmonising methods and electronically collected data across river basin districts and 
marine regions, on monitoring, assessments, projections, economic assessment, etc. and make all data 

30 

 
 
openly available through timely publication in line with the requirements of the Open Data Directive and 
INSPIRE Directive. 

This implies immediate actions: 

a)  Strengthening the monitoring of surface waters by covering all relevant quality elements and chemicals 
in all water categories. An increased level of monitoring should lead to a lower dependence on expert 
judgment for the classification of ecological status / potential and chemical status; 

b)  Developing  chemical  status  monitoring  programmes  to  ensure  all  relevant  priority  substances 

(including mercury) and River Basin Specific Pollutants are identified;  

c)  Providing a detailed quantitative assessment of the additional need for measures to address nutrients, 

pesticides, and pollution from all the sectors in all RBDs; 

d)  Assessing how the planned measures will close the gaps to good status. This will allow to address all 

point pollutions with concrete measures and better prioritise its measure at water body level. 

This also implies actions for the next RBMPs: 

e)  Assessing the impacts of climate change on the status of the biological and other quality elements at 
water body level in all RBDs and introduction of possible measures to tackle or mitigate the adverse 
impact of climate change; 

f)  Better assessing the achieved and expected effects of the measures in previous cycles providing more 

details related to pollution from pesticides at water body level; 

g)  Further develop the methods to assess ecological potential to include the sensitive biological quality 

elements in the assessment; 

h)  Assess  how  the  planned  measures  will  close  the  gaps  to  good  status  /  potential  due  to 

hydromorphological pressures; 

i) 

Improved assessment of the impact of abstraction on both surface water bodies and groundwater 
bodies; 

j)  Providing a sound justification for the deterioration in status of waters e.g., the acute drop in the number 

of water bodies in good chemical status;. 

k) 

Improving the methodology for establishing ecological flow; 

l)  Clarification of the prioritisation of nature-based solutions; 

m)  Including territorial waters; 

n)  Designation of all appropriate Natura 2000 areas associated with groundwaters and linked to Habitats 

and Birds Directives; 

8. 

Improve the transparency and useability of the RBMPs and the communication in the preparation of the 
RBMPs. 

In particular,  

a)  Aggregated data of the number of groundwater bodies subject to quantitative monitoring, and number 

of surface water bodies subject to surveillance and operational monitoring; 

b)  Aggregated data of the number of water bodies subject to measures and the expected implications of 

the measures; 

31 

 
c)  Clear information of the use of exemptions with thorough justifications according to Articles 4(4), 4(5), 
4(6)  and  4(7)  from  achieving  the  objectives  of  Art.  4(1):  ecological  status,  chemical  status,  and 
quantitative status of surface waters and groundwaters. Furthermore, to better introduce an overview 
of using exemptions, RBMPs should include aggregated data of water bodies subject to exemptions; 

d)  A clear description of the methodology of designating heavily modified and artificial water bodies as 

well as the methodology of defining good ecological potential; 

e)  A clear summary of the economic analysis and the cost recovery calculations, mentioning key figures 
as well as the underlying methodology. Report more clearly on the adequacy of price incentives and of 
the contributions of the various water user sectors to the costs of water services provision. 

9. 

Improve the reporting of RBMPs to comply with the WFD timetable and maximise the efforts to ensure 
electronic reporting of WFD data, to facilitate comparisons between implementation cycles and allow for 
easier monitoring of progress; 

32 

 
 
 
SECTION B: 
FLOODS DIRECTIVE 

33 

 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State to scan its territory for flood risks, assess the potential 
adverse  consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic  activity,  identify  the  significant  risks,  map  the  flood  extent  and  the  potential  adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. 

There are nine Units of Management (UoMs) in Poland, which are the same as the Water Framework 
Directive’s River Basin Districts (RBDs). Fluvial, pluvial, groundwater, sea water, and artificial water 
bearing infrastructure types of floods are considered as potentially significant sources of flooding in 
Poland. Poland designated 914 Areas of Potential  Significant Flood Risk (APSFRs). The impacts of 
climate  change  on flood  risk  have  been  considered in  Poland  for  all the  UoMs  at the  time  of  the 
second preliminary flood risk assessment. For fluvial floods due to natural exceedance and floods due 
to damage to flood dikes, a change in the projected high flow Q90 trend in 2021-2050 was assigned. 
Data were obtained from CHASE-PL project ‘Assessment of the consequences of climate change for 
selected  sectors  in  Poland’.  For  winter  floods  due  to  ice  accumulation,  forecasts  of  long-term 
developments, including climate change, were not carried out due to methodological obstacles. For 
pluvial floods, an analysis of trends of frequency of precipitation of above 20 and 30 mm was made 
based on data precipitation data in the selected cities. For sea water floods, a new methodology was 
developed. The analysis of the frequency of storms occurring at the Polish coast indicated that in 
recent decades, the frequency of storms has increased. 

7.1 Flood hazard and risk maps 

Poland is using online map service48 as well as pdf maps49 for their FHRMs. FHRMs were prepared at 
the national level. Maps for floods with low probability (1/500 years), with medium probability (1/100 
years) and with high probability (1/10 years) are provided.  The maps show flood extent, indicative 
number of potentially affected inhabitants, type of economic activity, IED and IPPC installations and 
potentially affected protected areas50. 

As a result of the review and update of the PFRA, additional areas at risk of flooding were identified, 
for which new FHRMs were developed. For river flooding alone, approximately 14 800 km of rivers 
were indicated for the development of new FHRMs. For coastal flooding, the updates and development 
of new FHRMs covered approximately 200 km of coastal areas and river mouths. For floods from 
damming structures new FHRMs included 26 locations51. The new regulation on the development of 
flood hazard maps and flood risk maps introduced changes to the scenario concerning the damage 
or destruction of a flood embankment52 establishing that the designation of areas prone to flooding 

48 Hydroportal: https://isok.gov.pl/hydroportal.html 
49 Maps in pdf format (both FHMs and FRMs) can be accessed directly by the hydroportal service: 
https://wody.isok.gov.pl/imap_kzgw/?gpmap=gpPDF 
50 Protected areas according to Annex IV(1)(i), (iii) and (v) to Directive 2000/60/EC. 
51 Report on the review and update of the flood hazard maps and flood risk maps version nr. 2.00 („Raport z wykonania 
przeglądu i aktualizacji map zagrożenia powodziowego i map ryzyka powodziowego” wersja nr. 2.00), Warszawa 2022, 
https://powodz.gov.pl/pl/mapy  
52 Methodology for preparing flood hazard maps and flood risk maps in the 2nd planning cycle („Metodyka opracowania 
map zagrożenia powodziowego i map ryzyka powodziowego w II cyklu planistycznym”), Warszawa 2022, 
https://powodz.gov.pl/pl/mapy 

34 

 
 
in the event of damage to or destruction of an embankment shall take into account the complete 
destruction of the embankment, thus taking a more conservative approach. 

In terms of changes of contextual information (i.e. the way in which information about the maps is 
conveyed  to  the  public)  since  the  first  FHRMs,  overall,  a  significant  change  compared  to  the  first 
FHRMs  is  that  Poland’s  second  FHRMs  are  available  in  an  online  map  viewer,  rather  than  as  a 
collection  of  individual  PDF  documents.  There  is  a  disclaimer  addressing  the  consequences  of 
potential misuse of the maps and the legal responsibility of the publishing authority. INSPIRE services 
are now mentioned. A short user manual is provided. 

In  terms  of  changes  in  methodologies  used  to  prepare  flood  hazard  maps  since  the  first  FHRMs, 
changes to improve the process of map preparation, publication and reporting concern in particular53: 
1)  updating  the  input  data  for  the  development  of  the  FHRMs;  2)  the  methodology  of  hydraulic 
modelling; 3) the way flood risk areas are determined; 4) the elements of the cartographic version of 
the FHRMs depicted on the maps. 

In  terms  of  changes  in  methodologies  used  to  prepare  flood  risk  maps,  regarding  the  adverse 
consequences associated with the flood scenarios, the same elements are mapped as in the  first 
FHRMs. 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’. 

7.2 Flood risk management plans 

The FRMPs can be downloaded  from a government web page54. The FRMPs are also available for 
download  on  the  website  of  Polish  Waters,  which  provides  both  links  to  the  plans  and  additional 
summary information about their contents and the process of their preparation and adoption55. 

The FRMPs identify three main objectives for both fluvial and coastal floods, eleven sub-objectives 
for fluvial floods, and six sub-objectives for coastal floods. The second FRMPs describe a review of 
the sub-objectives set in the first FRMPs to assess their continued relevance. The FRMPs also list 
eight strategic environmental objectives and refer to an overall objective in Poland’s Water Law. One 
of the strategic environmental objectives calls for the protection of human health and safety. Also, 
protection of cultural heritage is listed as one of the eight strategic environmental objectives. The 
FRMPs also cite Poland’s Water Law, which calls for reducing the negative impacts of flooding on 
human life and health, on economic activity, on the environment and on cultural heritage. One of the 
sub-objectives for both fluvial and coastal floods calls for reducing the vulnerability of communities 
and facilities to floods. Another sub-objective calls for increasing effectiveness of flood forecasting 
and warning, improvement of the effectiveness of post-flood analyses and increasing awareness and 
knowledge and awareness about sources of flood hazard and risk. 

The  FRMPs  present  a  common  catalogue  of  national  measure  types  and  then  ‘actions’  for 
implementation based on these measure types. Poland reported 2 974 measures to EIONET. Poland 
identified  priorities  for  all  its  measures  reported  to  EIONET.  For  EIONET  reporting,  there  are  five 
categories of measure prioritisation ranging from critical to low, and Poland has reported measures 

53 Report on the review and update of the flood hazard maps and flood risk maps version nr. 2.00 („Raport z wykonania 
przeglądu i aktualizacji map zagrożenia powodziowego i map ryzyka powodziowego” wersja nr. 2.00), p. 92, Warszawa 
2022, https://powodz.gov.pl/pl/mapy 
54 https://stoppowodzi.pl/rozporzadzenia-przyjmujace-plany-zarzadzania-ryzykiem-powodziowym/  
55 https://www.wody.gov.pl/nasze-dzialania/plany-zarzadzania-ryzykiem-powodziowym. 

35 

 
 
under each of these categories: 694 measures (23 % of all measures) are categorised as critical, 
1 486 (50 %) as very high priority, and 534 (18 %) as high. Measures that fall under the moderate 
to low categories make up 196 (7 %) and 64 (2 %) of the total measures, respectively. The FRMPs 
provide several methods for the prioritisation of different categories of actions. The FRMPs provide 
two sets of indicators to monitor the progress of the actions. Annual updates will be published. Poland 
identified the progress status for all the measures reported to EIONET. The second FRMPs provide an 
overview of the achievement of indicators for actions implemented under the first FRMPs (see below). 
The actions are linked to the measure types, which are in turn linked to the sub-objectives. Poland 
reported in EIONET 105 measures (4 % of the total reported) as ‘completed’. A further 194 measures 
(7  %  of  the  total)  are  reported  as  ongoing  construction.  225  Measures  (8  %)  are  reported  as  ‘in 
preparation’. One protection measure in the Oder UoM is reported in on-going maintenance (recurrent 
e.g. maintenance works). The majority of measures (56 %) are classed as ‘abandoned/ interrupted’, 
and these are seen in three UoMs: the Vistula, where 1 439 measures (60 % of the UoM’s measures) 
are reported as abandoned/interrupted; and the Oder and Pregoła, where 40 % of the measures in 
each UoM are reported  as abandoned/interrupted. For prevention measures, 76%  are reported as 
abandoned/interrupted, compared to 59 % of protection measures, 33 % of preparedness measures, 
and 16 % of recovery and review measures. Among measures not started, 79 % of recovery and 
review measures are reported as not started, compared to 61 % of preparedness measures, 21 % 
of protection measures, and only 13 % of prevention measures. Relative to Poland’s reporting for the 
first FRMPs, when only 1 % of measures are reported as completed, the second FRMPs have a small 
increase in the share of measures that completed, reaching 4 %. 

The  FRMPs  assessed  do  not  explain  why  a  large  share  of  the  measures  reported  to  EIONET  are 
classified as ‘abandoned/interrupted’, however Poland subsequently clarified that there are financial, 
organisational,  legislative and  other  reasons  for  this.  The  second  FRMPs  for the  Vistula  and Oder 
UoMs, in the section devoted to coastal floods, mention that a large proportion of the actions in the 
first FRMPs had a focus that was not primarily for flood protection56. Among these measures, there 
are actions concerning the construction and reconstruction of port infrastructure and the protection 
of  the  coast  against  erosion  and  seawater  floods.  Their  implementation  would  contribute  to  the 
reduction and prevention of erosion along the seashore and to increased port security. However, they 
would not lead to a reduction of the flood hazard areas. Therefore, these types of actions  are not 
included in the second FRMPs. 

The  FRMPs  provide  information  on  the  results  of  the  actions  undertaken  under  the  first  FRMPs. 
Examples of progress indicators for the Vistula FRMP include the following: for fluvial floods, indicator 
PA4 – the increase in the length of flood embankments protecting APSFRs – reached 8.1 % of the 
target value.57 For coastal floods, indicator PA6 – the increase of the length of seacoast embankments 
– the actions under the first FRMPs achieved 71.4 % of the target value. The FRMPs state that for 
some indicators, estimation of the values achieved was difficult – for example for PA11, it was not 
possible to estimate the number of citizens who received training in flood protection. 

The FRMPs provide the total cost of their measures, and Poland indicated the costs of 93 % of the 
measures  reported  to  EIONET.  The  FRMPs  assessed  indicate  that  the  main  funding  sources  are 
national budget, self-government budgets at various levels (regional and local), and National Fund 
for  Environmental  Protection  and  Water  Management.  Additional  sources  identified  include  EU 
funding and loans from international financial institutions. Background reports describe cost-benefit 
analysis (CBA) and multi-criteria analysis (MCA) methods used to assess ‘planning scenarios’, groups 

56 Section 4.2, p. 47 of the for the Vistula FRMP; section 4.2, p. 47 for the Oder FRMP. 
57 FRMP for Vistula, p. 44. 

36 

 
 
of measures for flood risk areas. The catalogue of measures has measure types for natural water 
retention in forests, wetlands, agricultural land and urban areas, and the FRMPs assessed include 
actions  for  these  measure  types.  Measure  types  also  refer  to  structural  water  retention  projects. 
Poland reported to EIONET that the WFD’s objectives were considered in all UoMs. The FRMPs for the 
Vistula and Oder UoMs describe activities undertaken to assess the coherence of actions with the 
WFD’s objectives. The FRMPs cite the Strategic Environmental Assessments (SEAs), which assessed 
impacts on nature and did not identify ‘significant negative impact’ on Natura 2000 areas. The plans 
note that where necessary, the administrative process for actions will include a detailed study of 
environmental  impacts.  Poland  has  reported  174  prevention  measures  to  EIONET.  Poland  has 
reported 2 459 protection measures to EIONET, representing 83 % of all measures. Poland reported 
161 preparedness measures to EIONET. The FRMPs include actions for restrictions of development 
and construction bans in areas prone to high risk of flooding. 

Governance 

The FRMPs refer to international cooperation via international river commissions and their working 
groups for specific activities, including flood risk. The FRMPs also refer to cooperation under bilateral 
water agreements with neighbouring Member States and third countries on joint water management. 

The public consultation lasted nine months. Among the places where the documents were available, 
was the main office of the Ministry of Infrastructure58. Information on the draft FRMPs (and later, the 
updated plans) was also provided via a public awareness campaign entitled “Stop the Flood”59, whose 
website60 provided the draft FRMPs and related documents. There was joint consultation of the draft 
FRMPs and RBMPs. 

Consideration of climate change 

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘adaptation to climate change’. 

Progress identified in the second FRMPs 

The second FRMPs present a detailed process for reviewing and revising the sub-objectives set in the 
first  FRMPs.  Moreover,  three  of  the  second  FRMPs  present  indicators  showing  progress  since  the 
corresponding first FRMPs. In addition, the process of prioritisation of measures is clearly presented 
in the FRMP and the accompanying methodological report. A description of the measures is provided 
in all the FRMPs under assessment, including the FRMPs for Pregoła, Nemunas and Elbe (in addition 
to Vistula and Oder, for which a description was already provided in the first FRMPs). In addition, the 
methodology for monitoring, in particular the approach for indicators, has been strengthened. Climate 
change was included in the process of determination of types of activities of the FRMPs. The second 
FRMPs describe in more detail how cooperation in international river basins functions. 

8. FD recommendations 

Based on the reported information and the FHRMs and FRMPs assessed, Poland should: 

58 FRMP for Elbe, p. 94; FRMP for Nemunas, p. 92; FRMP for Oder, p. 179; FRMP for Pregoła, p. 87; FRMP for Vistula, p. 410, 
http://dziennikustaw.gov.pl/. 
59 FRMP for Elbe, p. 95; FRMP for Nemunas, p. 93; FRMP for Oder, p. 180; FRMP for Pregoła, p. 88;FRMP for Vistula, p. 411, 
http://dziennikustaw.gov.pl/. 
60 Stop Powodzi: www.stoppowodzi.pl 

37 

 
 
• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Consider pluvial flooding in the FHRM; 

Consider the impact of climate change on other sources of flooding in the FHRM, beyond 2030; 

Clearly consider, in the FHRM, the potentially affected protected areas identified in Annex IV(1)(i), (iii) and 
(v) to Directive 2000/60/EC; 

Consolidate  the  information  sources  in  the  FHRM  (including  the  pdf  and  geoinformation  versions)  and 
improve the user friendliness; 

Include, in the FRMP, the conclusions drawn from the totality of FHRMs; 

Provide, in the FRMP, detail on how the FHRM was used in the choice of objectives and measures; 

Clearly explain, in the FRMPs, how the flood risk “problem areas” relate to the PFRA/ APSFRs and to the 
FHRMs; 

Consider insurance as a measure for adaptation to climate change; 

Better explain, in the FRMP, the use of cost-benefit assessment (CBA) and the methodology behind it; 

Provide, in the FRMP, detail on the comments received during the public consultation and how they were 
taken into account; 

Consider, in the FHRM, flow velocity or relevant water flow (Poland already does for settlements with over 
100 000 inhabitants) and the FRMP flood conveyance routes, as these are relevant to emergency response. 

38