COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Poland Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Poland, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.7.2025  SWD(2025) 921 final  COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report                           Country Chapter on the rule of law situation in Poland Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report                             The rule of law situation in the European Union {COM(2025) 900 final} - {SWD(2025) 901 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
ABSTRACT 

Significant efforts have been made in Poland towards the implementation of the Action Plan 
on the Rule of Law to address long-standing concerns regarding judicial independence. A law 
is being prepared to address the situation of judges appointed at the request of the National 
Council for the Judiciary in its post-2017 composition, on which the Government committed 
to reconsult the Venice Commission. Plans to amend the structure of the Supreme Court have 
been proposed to  strengthen its independence, including  the dismantling of the Chamber of 
Extraordinary Control and Public Affairs. Acts amending the Law on the National Council for 
the Judiciary and the Act  on the Constitutional  Tribunal  were adopted by the Parliament  to 
address the relevant serious concerns but have not yet entered into force due to their referral to 
the  Constitutional  Tribunal  by  the  President  of  the  Republic.  Further  significant  steps  have 
been made towards separating the office of the Minister of Justice from that of the Prosecutor 
General,  while  a  law  to  that  end  is  yet  to  be  adopted.  The  level  of  perceived  judicial 
independence  in  Poland  continues  to  be  very  low  although  it  has  slightly  increased  among 
companies, while the efficiency of courts remains stable. 

The Polish Government is working to strengthen the legislative framework against corruption 
and  to  improve  coordination  among  investigating  entities.  There  is  no  comprehensive  anti-
corruption strategy in place. Laws combatting corruption are enforced in practice, with large-
scale corruption cases involving public officials and politicians being investigated. The EPPO 
is now fully operational to investigate and prosecute crimes affecting the financial interests of 
the Union. There have been no further steps to address the broad immunities of top executives 
and impunity clauses or to  introduce lobbying rules. Weaknesses remain regarding political 
party financing, but the authorities are starting to address the issue. The new whistleblower 
protection law entered into force and limited steps have been taken towards establishing an 
electronic  asset  declaration  and  verification  system.  Significant  corruption  risks  have  been 
identified in public procurement, with potential impacts on investments and business activities. 

A planned media law reform is to address concerns regarding the impartiality and independence 
of the media regulator as well as the independence and pluralism of public service media more 
broadly. Meanwhile, some further efforts have been made to strengthen the process of granting 
operating  licences  and  to  ensure  the  independent  governance  and  editorial  independence  of 
public  service  media,  though  challenges  remain  in  safeguarding  media  pluralism  and, 
particularly in situations involving foreign investment in media ownership. Politically biased 
media content has decreased, and state advertising expenditure is more evenly distributed. The 
Government is working on a new state-funded model aimed at replacing the licence fee system. 
The  legal  framework  for  access  to  public  information  remains  stable,  though  stakeholders 
report  certain  challenges  with  its  implementation.  The  number  of  strategic  lawsuits  against 
public  participation  (SLAPPs)  has  decreased  and  the  Government  continues  to  address 
challenges  affecting  the  safety  of  journalists  and  the  protection  of  journalistic  sources  and 
confidential communications. 

Poland strengthened the  rules governing  consultations to  improve the quality  of legislation. 
Further steps have been taken to improve the framework in which civil society operates. Efforts 
are under way to address instances of abuse of power by public officials. The Ombudsperson 
continues to fulfil a key role in the system of checks and balances.   

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RECOMMENDATIONS 

Overall, concerning the recommendations in the 2024 Rule of Law Report, Poland has made: 

•  Significant  progress  on  separating  the  office  of  the  Minister  of  Justice  from  that  of  the 
Prosecutor General and to ensure the functional independence of the prosecution service 
from the Government. 

•  Limited  progress  on  standardising  the  online  system  for  asset  declarations  of  public 
officials and Members of Parliament and no progress on introducing lobbying rules. 
•  Some  progress  on  ensuring  independent  and  effective  investigations  and  prosecutions, 
address the broad scope of immunities for top executives and remove previously introduced 
impunity  clauses  in  legislation  in  order  to  enable  a  robust  track  record  of  high-level 
corruption cases. 

•  Some further progress on ensuring that fair, transparent and non-discriminatory procedures, 

are adhered to for the granting of operating licences to media outlets. 

•  Some further progress on ensuring an effective legislative framework for the independent 
governance  and  editorial  independence  of  public  service  media,  taking  into  account 
European standards on public service media. 

•  Some further progress on improving the framework in which civil society operates. 

On this basis, and considering other developments that took place in the period of reference, 
and in addition to recalling the obligation to comply with the rule of law related rulings of the 
Court of Justice of the EU and the rule of law related infringement procedures referred to in 
the country chapter as well as recalling the relevant commitments made under the Recovery 
and Resilience Plan, it is recommended to Poland to: 

•  Continue  to  advance  on  the  implementation  of  the  Action  Plan  on  the  Rule  of  Law, 
including as regards the National Council for the Judiciary and the Constitutional Tribunal. 
•  Take forward the reform to separate the function of the Minister of Justice from that of the 
Prosecutor-General and to ensure functional independence of the prosecution service from 
the Government. 
Introduce  rules  on  lobbying  and  a  standardised  online  system  for  asset  declarations  of 
public officials and members of Parliament while ensuring effective verification. 

• 

•  Continue  efforts  to  ensure  independent  and  effective  corruption  investigations  and 
prosecutions,  address  the  broad  scope  of  immunities  for  top  executives  and  remove 
impunity clauses to enable a robust track record of high-level corruption cases. 

•  Take forward reforms to ensure that fair, transparent and non-discriminatory procedures 

are adhered to for the granting of operating licences to media outlets. 

•  Take  forward  reforms  to  ensure  an  effective  legislative  framework  for  the  independent 
governance  and  editorial  independence  of  public  service  media,  taking  into  account 
European standards on public service media. 

•  Continue ongoing efforts to improve the framework in which civil society operates, taking 

into account European standards on civil society organisations.  

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I. 

JUSTICE SYSTEM1  

Independence  

The level of perceived judicial independence in Poland continues to be very low among 
both the general public and companies. Overall, 26% of the general population and 24% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in 20252. The perceived judicial independence among the general public has slightly decreased 
in comparison with 2024 (28%) and 2021 (29%). The perceived judicial independence among 
companies  has  slightly  increased  in  comparison  with  2024  (22%)  and  has  increased  in 
comparison with 2021 (18%).  

Significant efforts have been made to implement the Action Plan on the Rule of Law and 
Poland  is  delivering  on  its  commitments  to  consult  the  Venice  Commission  on  new 
legislation.  Poland  consulted,  in  line  with  the  Action  Plan3,  the  Venice  Commission  on 
legislative proposals concerning the prosecution system, the National Council for the Judiciary, 
and the Constitutional Tribunal4. Poland pledged to take account of the recommendations made 
by the Venice Commission and to reconsult it as necessary5. A draft law was proposed to ensure 
the implementation of European Court of Human Rights’ (‘ECtHR’) rulings, providing, among 
others,  for  better  coordination  between  public  authorities6.  Amendments  were  adopted  to 
implement  a  ruling  of  the  Court  of  Justice  of  the  EU  (the  Court  of  Justice)  on  judicial 
secondments in criminal courts in Poland7. The amendments include changes to the institution 
of delegation in the ordinary and military courts. The Government is also working on two draft 
laws which would remove provisions from a 2019 law on the judiciary, found by the Court of 
Justice to  be in  violation of EU law, and on a law restoring  judicial self-government  in  the 
functioning of courts and changing the structure of ordinary disciplinary courts8. The President 
of  the  Republic  referred  three  acts  to  the  Constitutional  Tribunal:  the  Act  of  12  July  2024 
amending the Law on the National Council for the Judiciary and the two Acts of 13 September 
2024 on the Constitutional Tribunal.  

Further steps have been taken to address the situation of judges appointed at the request 
of the National Council for the Judiciary in its post-2017 composition. In February 2025, 
the  Codification  Committee  for  the  Courts  and  Prosecution  Systems  (the  Codification 

1  An overview of the institutional framework for all four pillars can be found here.  
2   Figures 51 and 53, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The 
level  of  perceived  judicial  independence  is  categorised  as  follows:  very  low  (below  30%  of  respondents 
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%). 

3   2024 Rule of Law Report, Poland, pp. 3-4. 
4   See Venice Commission (2024), (2024a) and (2024b). 
5   This concerns notably the draft law on the Public Prosecutor’s Office and the draft law on the restoration of 

the right to an independent and impartial court established by law as presented in February 2025.  

6   Polish Government (2025), written input, p. 25; cf. draft law UD177 inscribed in the legislative work schedule 

of the Council of Minister. See Pillar IV, p. 21. 

7   The Law of 6 March 2025 amending the law on the Ordinary Courts Organisation and the law on the Military 
Courts Organisation. See CJEU judgment of 16 November 2021 in joined cases C-748/19 to C-754/19. The 
law would provide criteria allowing the secondment of a judge and its revocation by the Minister of Justice. 
The National Council for the Judiciary asked to veto the law or refer it to the Constitutional Tribunal. See 
NCJ (2025a) and (2025b). The President of the Republic signed the law on 16 April 2025. 

8   Polish Government (2025), written input, pp. 6-7; the draft law  of 21 January 2025 amending the law on 
ordinary courts organisation (rendered public on 21 March 2025) and the draft law of 13 May 2025 on the 
restoration of the right to an independent and impartial court established by law by regulating the effects of 
resolutions of the National Council of the Judiciary adopted in 2018-2025.  

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Committee)  prepared,  for  the  Government’s  consideration,  two  proposals  on  the  status  of 
judges appointed at the request of the National Council for the Judiciary (NCJ) in its post-2017 
composition. On that basis, and to follow up on its commitments in the Action Plan, in April 
2025, the Ministry of Justice proposed for the Government’s consideration a draft law9. The 
draft law provides for the removal of 1 600 judges10 while keeping most of them in office on 
the basis of a classification. Those judges considered as appointed in an irregular procedure, 
shall be classified as belonging either to the group of around 1 200 judges who, prior to their 
current appointment, obtained a judicial post via regular procedures, or to the group of around 
360 ordinary judges and 80 Supreme Court judges who obtained judicial status only upon the 
request of the NCJ in its current composition. The judges concerned would be able to legally 
challenge their classification. In principle11, it would not be possible to contest rulings issued 
by these judges. The Venice Commission had recalled12 that any arrangement chosen by Poland 
to address the situation of judges appointed in a deficient procedure would need to comply with 
the following parameters: (a) address the status of all judges appointed in a deficient procedure; 
(b)  the  assessment  of  the  effects  of  the  deficient  appointment  procedure  should  not  be 
conducted by a government-controlled body (and if it is not conducted by a judicial body, some 
form of judicial review should be available); (c) the assessment should be conducted on the 
basis  of  pre-established  criteria  and  procedures  (including  elements  of  fair  trial);  (d)  the 
assessment and the consequences following from that assessment should be in line with the 
principle  of  proportionality,  requiring  some  form  of  individual  assessment.  The  Venice 
Commission  considers  that  some  form  of  assessment  by  reference  to  groups  (‘cohorts’)  of 
appointments  including,  where  necessary,  individual  circumstances  of  appointment  or 
promotion, would be needed; and (e) the mechanism should allow a fairly rapid settlement of 
the issue. Given the complexity of the matter and its potential impact on the functioning of the 
justice  system,  the  Polish  authorities  reconsulted  the  Venice  Commission  on  the  draft  law 
proposed by the Ministry of Justice and committed to take its opinion into account13.  

Ordinary court judges are protected from unjustified disciplinary proceedings and are 
more  involved  in  decision-making  regarding  the  courts  where  they  adjudicate.  As 
announced in the Action Plan on the Rule of Law, the Minister of Justice continues to appoint 
ad hoc disciplinary officers to terminate undue disciplinary proceedings against judges14 and 
launch new disciplinary proceedings. The Main Disciplinary Officer for Ordinary Court Judges 
and his Deputy were dismissed from office15. The Minister of Justice dismissed presidents of 

9   According to the draft, judges who had already been appointed in a regular procedure in the past prior to 
assuming their current post would have the resolution giving rise to their appointment ex lege invalidated by 
law and would be ex lege delegated for two years to continue in their current post (except Supreme Court and 
Supreme Administrative Court judges), pending a new competition before a reformed NCJ.  

10  13% of the overall number of judges in Poland. Judges appointed for the first time by the NCJ in its post-
2017 composition (in the same deficient procedure) following the training provided by the National School 
of Judiciary would remain in office. 

11   The only exception envisaged concerns rulings issued in proceedings in which a party contested the regularity 

of the composition of the court, and it would be possible exclusively at the request of such a party.  

12   Venice Commission (2024c), requested by Poland on 10 July 2024. The opinion was based on four abstract 

questions posed by the Minister of Justice who had not provided any draft legislative text.  

13   Ministry of Justice (2025i).  
14   So far, the Minister of Justice issued 24 ordinances appointing such officer which took over 95 proceedings 
concerning 63 judges. Ad hoc officers joined 66 proceedings initiated by the main Disciplinary Officer and 
his two Deputies. 35 disciplinary proceedings were discontinued, 5 indictments were withdrawn, and 26 new 
disciplinary cases were initiated. See: Polish Government (2025), written input, p. 8. 

15   The dismissals were motivated by deficiencies in carrying out duties of disciplinary officers and supervising 
court as their presidents and as regards the Deputy Officer, in view of the support provided to candidates 
running for the office of NCJ judge-member in 2022; Ministry of Justice (2025c) and (2025d).  

4 

 
 
 
ordinary courts appointed without the involvement of judicial self-government bodies16. The 
Constitutional  Tribunal  found  such  dismissals  to  be  unconstitutional  because  provisions  on 
which  they  are  based  do  not  require  a  binding  opinion  of  the  National  Council  for  the 
Judiciary17.  

Plans for amending the structure of the Supreme Court are being prepared with a view 
to strengthen its independence. A draft law was proposed by the Ministry of Justice in April 
202518  that  would  dismantle  the  Chamber  of  Extraordinary  Control  and  Public  Affairs  and 
provide for a number of important changes. The draft law would also remove the competence 
of the President of the Republic to designate an ‘acting First President of the Supreme Court’ 
and to decide on the overall number of Supreme Court judges without a prior request of the 
College of the Supreme Court, thereby limiting the potential influence over the judiciary. The 
President of Poland appointed a new President of the Chamber of Extraordinary Control and 
Public Affairs and a new President of the Civil Chamber, who are both judges found to have 
been appointed in violation of Article 19(1) TEU and Article 6(1) ECHR requirements19. The 
office of President of the Labour Chamber remains vacant. The First President of the Supreme 
Court is subject to several disciplinary proceedings and a criminal investigation20. The 2025 
budget of the Supreme Court was reduced, which led to a reduction of clerical staff21.  

Legislation addressing the lack of independence of the National Council for the Judiciary 
and the serious concerns related to the Constitutional Tribunal have not yet entered into 
force. Three acts amending the law on the NCJ22 and establishing the Constitutional Tribunal23 
were adopted by Parliament to follow up on their commitments in the Action Plan and restore 
the independence of these two bodies. The Venice Commission, while welcoming the overall 
aim  of  the  legislative  proposals,  recommended  more  moderate  means  than  declaring  all 
judgments that involve irregularly appointed judges invalid, such as the possibility to reopen 
proceedings24. Similar opinions were issued by other stakeholders calling to reflect more on 

16   See e.g. the Ministry of Justice (2025a) and (2025b). 
17   Ruling of 16 October 2024 in K 2/24; also criticised by the Supreme Court (2025), written input, p. 4 and 

“Sędziowie RP” (2025), written input, pp. 19-23.  

18   Ministry of Justice (2025i).  
19   On 26 February 2025, the President of the Republic appointed as President of the Chamber of Extraordinary 
Control and Public Affairs a judge who sat in the bench contested by the ECtHR in its judgment 8 November 
2021, Dolińska - Ficek and Ozimek v. Poland, 49868/19; Supreme Court (2025a). On 27 September 2024, 
the  President  of  the  Republic  appointed  as  President  of  the  Civil  Chamber  a  judge  who  sat  in  the  bench 
contested by the ECtHR in its judgment of 3 February 2022, Advance Pharma Sp. Z O.O v. Poland, 1469/2l; 
Supreme  Court  (2024a).  The  CJEU  found  that  benches  composed  of  judges  appointed  in  circumstances 
analysed by the ECtHR in the aforementioned rulings to not comply with the requirements of Articles 19(1) 
TEU and 267 TFEU; CJEU, judgment of 7 November 2024 in case C-326/23 and of 21 December 2023 in 
case C-718/21. 

20   Supreme  Court  (2025),  written  input,  p.  4;  the  criminal  investigation  was  opened  in  view  of  the  First 
President’s  refusal  to  convene,  at  request  of  its  members,  the  Tribunal  of  State  (cf.  National  Prosecution 
(2024)). The First President of the Supreme Court delivered several statements contesting actions announced 
by the Government to implement its Action Plan. See e.g. Supreme Court (2025), (2024c), (2024d). 

21   Supreme Court (2025), written input, p. 3; also Supreme Court (2024e).  
22   On the content of the law and its aspects which prima facie do not comply with the opinion of the Venice 
Commission thereon, and other opinions of stakeholders, see the 2024 Rule of Law Report, Poland, pp. 7-8. 

23   See 2024 Rule of Law Report, Poland, pp. 9-10. 
24   Venice Commission (2024c). The Opinion recommended the authorities to reconsider the ex lege invalidation 
of  judgments  and  orders  involving  irregularly  appointed  judges,  providing  for  a  more  tailored  approach 
through envisaging the possibility to have proceedings reopened.  

5 

 
 
 
the  approach  being  taken25.  The  Supreme  Court  and  the  National  Council  for  the  Judiciary 
considered the two drafts to violate the Polish constitution26. The President of the Republic 
referred the amendments to the law on the NCJ and those related to the Constitutional Tribunal 
to the Constitutional Tribunal for its review, where they remain pending. Considering the views 
of stakeholders, the Government is working on a revised proposal on which it committed to 
reconsult the Venice Commission. 

Pending new legislation, serious concerns related to the Constitutional Tribunal remain. 
Since March 2024, the Government refuses to publish in the Official Journal any judgments 
issued by the Constitutional Tribunal, on the grounds that the Constitutional Tribunal is not a 
legitimate  constitutional  body27.  The  Sejm  ceased  appointing  judges  to  vacant  posts  in  the 
Constitutional Tribunal28 considering it to no longer perform constitutional functions29, while 
in  February  2025,  the  President  of  the  Republic  appointed  a  new  Vice-President  of  the 
Constitutional Tribunal30. In March 2025, the Advocate General in his opinion proposed to the 
Court of Justice to uphold the Commission’s infringement action and declare that Poland has 
failed to fulfil its obligations under EU law in view of the Constitutional Tribunal and its case-
law31.  The  new  President  of  the  Constitutional  Tribunal  stated  that  this  would  be  a  grave 
violation of the Constitutional Tribunal’s competences and expressed concerns about Poland’s 
support of the Commission’s infringement action, on the grounds that EU law cannot limit the 
Constitutional  Tribunal’s  competences32.  He  also  asked  the  prosecutor’s  office  to  open  an 
investigation33 and requested the Deputy Disciplinary Officer for Judges in office since 2018 
to  initiate  disciplinary  proceedings  against  judges  who  refuse  to  apply  the  Constitutional 
Tribunal’s rulings34. With the exception of the President of the Republic, representatives of the 
executive  and  legislative  powers  are  no  longer  initiating  cases,  participating  in  hearings  or 
providing  written  contributions  before  the  Constitutional  Tribunal35.  The  Constitutional 
Tribunal also ruled on the constitutionality of EU Treaty provisions36. 

25   OSCE-ODIHR (2024b), National Chamber of Legal Councillors (2024), Ombudsperson (2024) and National 
Bar Council (2024) – all of which supported the aim of the laws but considered important to reflect on the 
approach towards the ex lege invalidation of all rulings issued in an irregular composition. 7 NGOs (2025), 
written input, pp. 42-43. 

26   Opinion of the National Council for the Judiciary of 2 July 2024 SPS-WP.020.87.4.2024 and of the Supreme 

Court of 19 April 2024 BSA III.021.8.2024. 

27   See Government resolution n° 162 of 18 December 2022.  
28   As of the date of publication of the report, there are overall 11 judges of the Constitutional Tribunal.  
29   Pursuant to the Resolution of 6 March 2024 of the Sejm, cf. the 2024 Rule of Law Report, Poland, p. 9. 
30   On  7  December  2024,  the  President  of  the  Republic  appointed  a  new  Tribunal  President.  The  Tribunal 
declined to inform whether the Tribunal judges appointed to already occupied posts had participated in the 
selection procedure of candidates (cf. Helsinki Foundation for Human Rights (2025)).  

31   Opinion of 11 March 2025 in case C-448/23; on the infringement procedure see 2023 Rule of Law Report, 

Poland, p. 9. 

32   Constitutional Tribunal (2025a). 
33   Allegedly  committed  by  i.a.  the  Prime  Minister,  Marshals  of  the  Parliament  and  certain  judges  and 
prosecutors, while requesting that the investigation be conducted by a prosecutor of his own choosing; cf. 
Constitutional Tribunal (2025b) and (2025c) 

34   Constitutional Tribunal (2025d).  
35   This follows the resolution of the Sejm of 6 March 2024 and of the Council of Ministers of 18 December 

2024 (see above). 

36   Ruling of 10 June 2025 in case K 10/24, where the Constitutional Tribunal asserted the unconstitutionality of 
Article 191(1) read in connection with Article 192 let. c of the Treaty on the Functioning of the European 
Union, “interpreted in such a way that the unanimity requirement of the Council is limited to measures whose 
primary  intended  result—arising  from  their  purpose  or  content—is  to  significantly  affect  the  Republic  of 
Poland’s choice between different energy sources and the general structure of its energy supply”. 

6 

 
 
 
The National Council for the Judiciary continues to operate despite serious concerns as 
to its independence. Since July 2024, the NCJ adopted over 140 resolutions requesting judicial 
appointments to the President of the Republic. The Minister of Justice continues not to publish 
vacant posts in ordinary courts, citing a need to avoid a deterioration of legal certainty in the 
justice system37. According to the Supreme Court, this has a negative impact on the efficiency 
of the ordinary judiciary38. An Ad Hoc Disciplinary Officer opened disciplinary proceedings 
against 18 judges-members of the NCJ on grounds of their participation in a body that does not 
meet constitutional requirements39. The NCJ has criticised decisions of the Government40 and 
has appointed a special Committee to examine and monitor what it considers to be a political 
harassment of judges and assistant judges41. The annual budget of the NCJ was decreased42. 

Significant progress has been made on the recommendation to separate the office of the 
Minister  of  Justice  from  that  of  the  Prosecutor  General  and  to  ensure  the  functional 
independence of the prosecution service from the Government43. The Government tabled 
in July 202444 a draft law separating the function of the Prosecutor General and the Minister of 
Justice. The Venice Commission welcomed it, while noting shortcomings as regards notably 
the procedure for appointing and dismissing the Prosecutor General45 and recalling that the law 
is  only  a  first  step  in  an  overall  reform  of  the  prosecution  system.  In  December  2024,  the 
Standing Committee of the Council of Ministers adopted the draft law, taking into account the 
recommendations  made  by  the  Venice  Commission46.  The  National  Prosecution  reviewed 
criminal investigations carried out in the period 2016-2023, revealing significant irregularities 
in most of the cases it investigated47. The criminal investigation against Supreme Court judges 
for the content of their judicial decisions, opened in 2020, was discontinued48. The Prosecutor 
General instructed prosecutors to request the recusal of judges of the Supreme Court appointed 
at  the  request  of  the  NCJ  in  its  post-2017  composition49.  One  of  the  Deputy  Prosecutors-
General appointed by the previous Prosecutor General  was suspended, following a criminal 

37   See the 2024 Rule of Law Report, Poland, p. 7. 
38   Supreme Court (2025), written input, p. 3.  
39   Ministry of Justice (2025c). These proceedings were criticised by the First President of the Supreme Court 

and by the Council itself; Supreme Court (2025) and National Council for the Judiciary (2025a). 

40   I.a. as regards legislation aimed at implementing CJEU case-law.  
41   National Council for the Judiciary (2025c) and (2025d). 
42   The decrease of the government is of ca. 15.2% in comparison to the 2024 annual budget (reduction from ca. 
PLN  24.94  million  to  PLN  21.16  million).  On  10  May  2025,  the  Constitutional  Tribunal  considered  the 
decrease unconstitutional (case K 2/25). 

43   The 2024 Rule of Law Report recommended to Poland to ‘[c]ontinue efforts to separate the function of the 
Minister  of  Justice  from  that  of  the  Prosecutor-General  and  to  ensure  functional  independence  of  the 
prosecution service from the Government’. 

44   Draft law UD95; the draft law tabled on 14 July 2024; Polish Government, written input, p. 8. 
45   Venice Commission (2024). The Opinion welcomes the proposed aim of the reform. It identifies a number of 
issues,  in  particular  regarding  the  procedures  for  the  appointment  and  accountability  of  the  Prosecutor 
General, as well as the composition and powers of the National Prosecution Council.  

46   Permanent Committee of the Council of Ministers (2024). The draft law removes MPs and Senators from the 

list of entities allowed to propose candidates to the office of Prosecutor General.  

47  National Prosecution (2025). The partial audit covered 200 out of a total of 600 cases. 51 cases were initiated 
against  independent  judges,  prosecutors,  and  opposition  supporters.  37  cases  were  found  to  have  been 
conducted without significant issues. The remaining 112 cases presented serious reservations that should lead 
to criminal and disciplinary liability. The report concluded that “the Prosecutor's Office from 2016 to 2023 
failed  to  adequately  perform  its  responsibilities.”  The  President  of  the  Constitutional  Tribunal  (who  was 
National Prosecutor at the time), called the report defamatory (Constitutional Tribunal (2025e)). 

48   National Prosecution (2024a). On the investigation see the 2021 Rule of Law Report, Poland, p. 8 fn. 52. 
49   National Prosecution (2024b). 

7 

 
 
 
investigation  he  had  reportedly  opened  in  violation  of  the  applicable  legislation50.  The 
secondment  of  prosecutors,  perceived  as  a  form  of  disciplinary  sanction,  ceased.  Overall, 
significant progress has been made to separate the office of the Minister of Justice from that of 
the Prosecutor General and to ensure the functional independence of the prosecution service 
from the Government. 

Quality  

The  Government  engaged  in  efforts  to  boost  digitalisation  of  ordinary  courts.  The 
Ministry of Justice is developing a tool to digitalise access to justice in ordinary courts and is 
setting-up a Digital Consumer and Competition Protection Court51. The Ministry also adopted 
a “Digital Court” strategic programme setting out steps to be taken by 2029 to optimise the 
effectiveness of the justice system and make it fit for the digital age. The real impact will have 
to be assessed over time52.  

Efficiency 

The overall performance of ordinary and administrative courts remains relatively stable. 
As  regards  ordinary  courts,  the  estimated  time  needed  to  resolve  civil,  commercial, 
administrative, and other cases continued to decrease (from 100 days in  2022 to 97 days in 
2023), and the opposite trend as regards litigious civil and commercial cases in first instance 
courts started to reverse (a decrease from 362 in 2022 to 360 in 2023). The rate of solving civil, 
commercial, administrative, and other cases also started to improve. As regards administrative 
courts, the rate of resolving administrative cases in first instance significantly improved (from 
98% in 2022 to 108% in 2023) and the number of pending administrative cases in first instance 
decreased53.  

II. 

ANTI-CORRUPTION FRAMEWORK  

The  perception  among  citizens,  experts  and  business  executives  is  that  the  level  of 
corruption in the public sector remains relatively high. In the 2024 Corruption Perceptions 
Index  by  Transparency  International,  Poland  scores  53/100  and  ranks  20th  in  the  European 
Union and 53rd globally54. This perception has been relatively stable over the past five years55. 
The  2025  Special  Eurobarometer  on  Corruption  shows  that  55%  of  respondents  consider 
corruption widespread in their country (EU average 69) and 47% of respondents feel personally 
affected  by  corruption  in  their  daily  lives  (EU  average  30).  As  regards  businesses,  41%  of 
companies  consider  that  corruption  is  widespread  (EU  average  63)  and  19%  consider  that 
corruption  is  a  problem  when  doing  business  (EU  average  35).  Furthermore,  46%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 

50   The case concerned the initiation, without following the prescribed procedure, of a criminal investigation at 
the  request  of  the  President  of  the  Constitutional  Tribunal  who  considers  that  a  number  of  high-ranking 
officials committed a coup d’etat (see above). National Prosecution (2025a). 

51   Ministry of Justice (2025d). The tool is expected to become fully operational in designated courts by mid-

2026; 7 NGOs (2025), written input, p. 17. See also CCBE (2025), written input, p. 159. 

52   Prawo.pl (2025a). 
53   Figures 4, 5, 9, 11 and 14, 2025 EU Justice Scoreboard. 
54   The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60), 

relatively high (between 59-50), high (below 50). 

55   In 2020, the score was 56, while, in 2024, the score is 53. The score significantly increases/decreases when 
it changes more than five points; improves/deteriorates (between 4-5 points) and is relatively stable (from 1-
3 points) in the last five years. 

8 

 
 
 
practices (EU average 36), while 21% of companies believe that people and businesses caught 
for bribing a senior official are appropriately punished (EU average 33)56.  

The  Polish  Government  is  working  to  strengthen  the  legislative  framework  against 
corruption.  The  Government  is  working  to  increase  the  independence  of  anti-corruption 
institutions  to  address  risks  of  politicisation57.  The  draft  reform  separating  the  positions  of 
Prosecutor General and Minister of Justice was approved by the Cabinet Standing Committee 
on 5 December 202458. In December 2024, the Council of Ministers adopted a draft law59 on 
an  ‘anti-corruption  shield’  to  protect  the  state’s  economic  interests60.  It  would  provide  for 
binding coordination procedures for the police, the Internal Security Agency and the Military 
Service61, and it also aims to dissolve the Central Anti-Corruption Bureau, which in the past 
had given rise to concerns about its independence from the executive62. Amended rules for the 
coordination  of  prosecution  services63  entered  into  force  and  a  draft  legislative  act  was 
introduced  for  Poland’s  accession  to  enhanced  cooperation  with  the  European  Public 
Prosecutor  Office  (EPPO)64.  Following  the  confirmation  by  the  European  Commission  of 
Poland’s participation in the EPPO65 , the Council of the EU appointed the European Prosecutor 
from  Poland66  and  the  EPPO’s  College  appointed  8  delegated  European  prosecutors67.  The 
EPPO is fully operational since January 2025 to investigate and prosecute crimes affecting the 
Union’s  financial  interests  committed  after  1  June  2021,  which  is  expected  to  facilitate 
Poland’s response to fraud and corruption68. Investigative authorities, such as the police and 
the National Revenue Administration69, were provided with new guidelines70.  

A new Central Office for Combatting Corruption is to be established within the police 
with a country-wide competence to detect, analyse, prevent and investigate corruption. 
The draft bill on the Anti-Corruption Shield71 aims at transferring the Central Anti-Corruption 
Bureau’s  resources  and  competences,  including  on  corruption  to  the  police,  the  Internal 
Security Agency (ABW) and the National Revenue Administration (KAS). Of the Bureau’s 
approximately 1300 full-time officers and 200 civilian employees, a total of 950 officers and 

written input, p. 1. See also pillar I. 

56   Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025). 
57   Polish Government (2023). 2024 Rule of Law Report, Poland, p. 18, and earlier reports. 
58   Draft Act amending the Public Prosecutor’s Office Act (UD95), 15 July 2024. Polish Government (2025), 
59   Chancellery  of  the  Prime  Minister  (2024).   Act  on  the  coordination  of  anti-corruption  activities  and  the 
60   I.e. behaviour causing a significant damage to public finance, state-owned enterprises or local governments 
exceeding approx. EUR 50 000 (Art. 115(7) Criminal Code). Polish Government (2025), written input, p. 13.  
61   Guidelines of the Prime Minister (20 March 2024) already implement the Shield; the bill would make them 

liquidation of the Central Anti-Corruption Bureau, UD46. Batory Foundation (2024). 

binding. 

62   2024 Rule of Law Report, Poland, p. 16. Bertelsmann Stiftung (2024), p. 11: the Bureau is closely linked to 
the former government lacking independence. Country visit Poland, Batory Foundation/ Helsinki Foundation, 
suggesting an ex-ante impact assessment and inclusion into a larger, strategic anti-corruption policy approach 
for the far-reaching reform. 

63   Regulation of the Minister for Justice (7 January 2025) on Rules of Procedure for the internal office of general 

organisation units of the Public Prosecutor’s Office. 

64   To implement Council Regulation (EU) 2017/1939 of 12 October 2017. 
65   See 2024 Rule of Law Report, Poland, p. 13. 
66   Decision of 12 December 2024; Council of the EU (2024). 
67   Decision of 16 December 2024; EPPO (2024). 
68   European Commission Decision 2024/807 of 29 February 2024. This step is welcomed by the Association of 

Judges and Prosecutors Iustitia, Themis and Lex Super Omnia (2025). 

69   Poland’s tax authority. 
70   Polish Government (2025), written input, p. 12. 
71   Act  on  the  coordination  of  anti-corruption  activities  and  the  liquidation  of  the  Central  Anti-Corruption 

Bureau, UD46. 

9 

 
 
 
all civilian employees are envisaged to be transferred to the police. The new Central Bureau 
for  Combating  Corruption  will  recruit  in  addition  approximately  300  officers  and  civilian 
employees from other police units. The KAS will gain 150 full-time positions and the ABW 
200 positions. The budget of the Central Anti-Corruption Bureau is planned to be distributed 
proportionally  to  the  three  entities  (73%  to  police,  15%  to  ABW,  11%  to  KAS)72.  The 
institutional changes envisaged in the legislative proposal adopted by the Council of Ministers 
is now to be sent to the Sejm as the next procedural step before Presidential signature. 

Large-scale  cases  of  corruption  involving  public  officials  and  politicians  are  being 
investigated, whereas further efforts are being made to ensure independent and effective 
investigations  and prosecutions with  a view to enabling a robust track record of high-
level corruption cases73. The National Prosecutor’s Office published a review report of cases 
of public interest concluded by the prosecution service between 2016 and 202374, including 
recommendations to address identified irregularities75. Large-scale corruption cases involving 
public officials and politicians are being investigated76. The autonomy and cooperation among 
relevant  anti-corruption  entities,  as  well  as  the  access  to  relevant  registries,  are  considered 
sufficient for the effectiveness of investigations and prosecutions. The Supreme Audit Office 
reports that its operations and audit controls have improved77. The Parliament commission set 
up to investigate the activities of high-level public officials, including members of Parliament, 
issued several corruption-related notifications to the National Prosecutor’s Office and regional 
prosecution  offices,  which  led  to  the  detention  of  several  high-level  officials78.  The 
effectiveness  of  combatting  foreign  bribery  in  practice,  although  still  low,  has  slightly 
improved79. The Ministry of Justice is working on an amendment of the Act on the liability of 
collective  entities  for  criminal  offences  to  remove  the  rule  according  to  which  private 
companies can be held criminally liable for foreign bribery only  after a final instance court 
sentence convicting the natural person(s) involved in the case, or after the termination of the 
proceedings for other reasons80. Against this background, there has been some further progress 
on this part of the recommendation. 

There has been no progress yet on the recommendation to address the broad immunities 
of top executives and to remove impunity clauses in legislation81. Immunities cause concern 
as they act as an obstacle to criminal accountability for corruption committed by top executives 

72   Country visit Poland, Ministry of Justice.  
73   The  2024  Rule  of  Law  Report  recommended  to  Poland  to  “[c]ontinue  efforts  to  ensure  independent  and 
effective investigations and prosecutions, […] in order to enable a robust track record of high-level corruption 
cases.” 

74   2024 Rule of Law Report, p. 15: The aim is to address risks of a selective application of the law and disparity 

in the treatment of corruption cases for political purposes.  

75   National Prosecutor’s Office (2025), review of 200 cases, selected by regional prosecutors and reported by 
the public, finding significant irregularities in 163 cases. Recommendations include to commence or reopen 
proceedings, to implement disciplinary or criminal liability against prosecutors. More case review will be 
presented in a second report.  

76   Central Anti-Corruption Bureau (2025c) and National Prosecution Office (2025c). On the visa scandal, Polish 
Government (2025), written input, p. 14. On the university diplomas bribery scheme, Central Anti-Corruption 
Bureau (2025b). 

77   Country visit Poland, Supreme Audit Office. 
78   For the bribe-for-visa case, facilitating the illegal entry into Poland and the Schengen area of over 12 000 

immigrants, see Polish Government (2025), written input, p. 14; Notes from Poland (2025). 

79   Polish Government (2025), written input, p. 13, reporting two new investigations. OECD (2024), para. 65.  
80   2024 Rule of Law Report, Poland, p. 17.  
81   The 2024 Rule of Law Report recommended to Poland to “[a]ddress the broad scope of immunities for top 
executives and remove previously introduced impunity clauses in legislation in order to enable a robust track 
record of high-level corruption cases”. 

10 

 
 
 
outside their official capacity82. Previously introduced impunity clauses83 are still in force84, 
yet  their  use  is  monitored  by  the  Central  Anti-Corruption  Bureau.  In  2024,  they  have  been 
applied  in  9  proceedings  (compared  to  10  in  2023)85.  Such  exemptions  from  criminal 
responsibility increase the risk of corruption and abuse of political or administrative power, 
given the lack of deterrence and the perception of impunity. Overall, there has been no progress 
yet on the recommendation, neither on immunities nor on impunity clauses. 

There  is  no  anti-corruption  strategy  in  place.    Poland’s  last  anti-corruption  strategy  and 
action plan covered the period from 2018-2020. While, as illustrated above, steps to combat 
corruption  have  been  taken  or  are  planned  by  the  Government,  a  new  strategic,  holistic 
Government approach to corruption is not yet in place86. As previously reported, the Supreme 
Audit  Office recommended in  its December 2022 report to  prepare and  adopt  such an anti-
corruption programme87.  

There has been no progress to strengthen integrity rules since no rules on lobbying have 
been introduced88. No steps have been taken to oblige persons in top executive functions to 
fully disclose their contacts with interest representatives in a meaningful and timely manner89. 
There is no information yet on whether the Ministry of Interior’s preparatory work of previous 
years will provide a basis for future work90. Challenges also persist as to the effectiveness of 
existing lobby registers, with continuing low registration rates, de-registrations and insufficient 
oversight and enforcement in practice91. In the Sejm, only 6 out of the 14 registered lobbyists 
have reported lobbying the Parliament in 202492. Therefore, there has been no progress on the 
recommendation.  

82   2024 Rule of Law Report, Poland, p. 19. GRECO (2023), paras. 54-63; (2019) paras. 82-91, reiterating its 
recommendation for an in-depth reform of top executives’ immunities to facilitate corruption prosecution, 
including by introducing objective criteria for transparent immunity lifting procedures. 

83   Exemptions from criminal responsibility (‘impunity clauses’) exist in  Art.  305(6) Criminal Code; Law  of 
December 2022 on the abandonment of prosecution relating to the organisation of the presidential elections; 
April  2022  amendments  to  Art.  483(1)  of  the  Commercial  Company  Code  Act,  abolishing  liability  of 
management and supervisory boards for actions to the detriment of the company. Art. 76 of the Law on special 
support instruments in connection with the spread of SARS-COV-2 virus, adopted in April 2020.  

84   A bill amending Art. 229(6) Criminal Code on suspects cooperating with the police in return for more lenient 

sanctions is planned for 2025, but not considered an impunity clause under this recommendation. 

85   Country visit, Poland, National Prosecutor’s Office. 
86   Country visit, Poland, Batory Foundation/Helsinki Foundation. OECD (2024), p. 4: lack of a strategy and 
disinterest, questioning Poland’s commitment. GRECO (2025), para. 59, finding a ‘globally unsatisfactory’ 
compliance  level  with  recommendations  for  MPs,  prosecutors  and  judges  (8  out  of  22),  and  insufficient 
compliance for government top executives. 
87   Supreme Audit Office (2022b) and (2022a). 
88   The  2024  Rule  of  Law  Report  recommended  to  Poland  to  “[s]trengthen  the  existing  integrity  rules  by 

introducing lobbying rules […].”  

89   Internal guidelines exist only for some ministries since 2006.  
90   Law of 7 July 2005 on Lobbying defines lobbying, establishes a public register and determines sanctions. 
The  2018-2020  Anti-Corruption  Programme  had  envisaged  a  revision  of  the  lobbying  law,  Council  of 
Ministers Resolution No. 207, 19 December 2017 (M.P. z 2018 r. item 12). 

91   There is a lobby register for the Government, with only 600 entries, one for the lower chamber of Parliament 
(Sejm – with an even lower number of entries) and one for the higher chamber of Parliament (Senate).  The 
Chancellery of the Prime Minister did not report any meetings with lobbyists in 2024; in  the Ministry of 
Interior and Administration in 2024 one lobbying notification was processed, yet no meeting with lobbyists 
took  place  according  to  the  Ministry.  See  also  GRECO  (2025),  paras.  34-36,  noting  that  the  scope  and 
enforcement of the rules appearing to apply to top executive functions remain unclear in practice. 

92   Country visit Poland, Senate Ethics Committee. 

11 

 
 
 
There  has  been  limited  progress  as  regards  a  standardised  online  system  for  asset 
declarations93.  The  legislative  proposal  introduced  in  November  2023  to  broaden  asset 
declaration rules is yet to be adopted94. As most declarations are still filled out by hand and in 
a variety of formats95, stakeholders have called for a comprehensive reform of the conflict of 
interest and asset declaration system96. The Central Anti-Corruption Bureau, with the support 
of the Internal Security Agency and the Military Counterintelligence Service, is still submit to 
the Minister of Interior a draft legal act to regulate the unification, digitisation and control of 
asset declarations97. Meanwhile, to address the low level of digitalisation of politicians’ asset 
declarations98, the Bureau, in cooperation with the Ministry of Digital Affairs and the Central 
Information  Technology  Center,  is  working  on  a  user-friendly  IT  system  for  the  electronic 
submission of asset declarations. The Bureau checks the completeness of Senators’ – mostly 
non-digitalised – asset declarations, while verification tasks remain with the tax authority99. 
Checks conducted by the Bureau also focused on asset declarations submitted by municipal 
officials  and  employees100.  Overall,  limited  progress  has  been  made  to  have  a  standardised 
online system for asset declarations of public officials and Members of Parliament. 

The new law on whistleblower protection is in force101. Stakeholders welcomed the law as 
a  first  significant  step,  calling  however  for  a  broader  material  scope102.  A  dedicated 
whistleblower department was established at the Office of the Commissioner for Human Rights 
to  receive  whistleblower  reports,  including  on  corruption  linked  to  potential  breaches  of 
fundamental  freedoms,  and  additional  staff  was  hired.  Its  budgetary  resources  were  also 
increased  but  are  deemed  insufficient  to  effectively  examine  the  high  number  of  reports 
received (approximately 7 000 in 2024)103. The Office refers whistleblower disclosures to the 
competent authorities. According to prosecutors, such disclosures are an important source of 
information to detect crimes, including corruption, and an effective whistleblower protection 
system is instrumental in the fight against corruption104. 

Weaknesses  remain  in  practice  in  political  party  financing,  but  the  authorities  are 
starting  to  address  the  issue.  Challenges  persist  in  the  practical  application  of  the  2022 
legislation  on  financing  of  political  parties105.  Publication  levels  of  party  finances  are  not 
standardised and still vary significantly. Some good practices exist, where filter functionalities 
are embedded on parties’ websites, facilitating the search for specific party finance data106. The 
National Election Commission has found irregularities in several party financial reports and 

93   The 2024 Rule of Law Report recommended to “[s]trengthen the existing integrity rules by introducing […] 

a standardised online system for asset declarations of public officials and Members of Parliament.” 

94   The  Bill  amending  the  Act  on  Restrictions  on  the  Conduct  of  Business  by  Persons  Performing  Public 

Functions would extend the scope to cover high-level officials and spouses’ property. 

95   At least 16 different forms are in use; provisions are scattered among several legislative acts. 2024 Rule of 

Law Report Poland, p. 22. 

96   Country visit, Poland, Batory Foundation/ Helsinki Foundation for Human Rights. 
97   Central Anti-Corruption Bureau (2025) to develop a central, integrated, electronic system. 
98   GRECO (2019), recommendations x and xi, paras. 72 and 78. 
99   Country visit Poland, Senate Ethics Committee. 
100   Central Anti-Corruption Bureau (2024). 
101   Act of 14 June 2024 (UC101), implementing Directive (EU)2019/1937, enforced largely since September.  
102   Polish Institute on Human Rights and Business (2024), p. 33, recommending covering breaches of all laws 

and internal regulations (Codes of Conducts, by-laws). 

103   Contributing also to legislative proposals and extraordinary tasks (e.g. Ukraine refugee immigration). 
104   Country visit Poland, National Prosecutor’s Office.  
105   2024  Rule  of  Law  Report,  Poland,  p.  23.  Arts.  25,  27  of  the  Act  require  parties  to  publish  up-to-date 
information in the donations and the contracts register. Stakeholders stress the need to test data reliability. 
106   See 2024 Rule of Law Report, Poland, p. 17. Parties’ data is published in pdf format or as embedded tables. 

12 

 
 
 
rejected one report entirely  for breaches  of the Electoral  Code on grounds of acceptance of 
unlawful financial benefits107.  Poland is now also engaging with the OSCE/ODIHR, which 
raised concern on undue influence over the use of state resources and public media and issued 
recommendations108.  The  parliamentary  bill  of  29  February  2024,  which  aims  to  address 
previously identified systemic transparency challenges relating to clientelist networks around 
state-owned  enterprises  (SOE)109,  has  passed  the  Sejm’s  first  reading  and  the  leading  Sub-
Committee on 20 November 2024110. The Supreme Audit Office expressed the need for audit 
controls of SOEs111, which had been found to circumvent campaign finance rules by exceeding 
spending limits and undermining the separation of the state and parties and raising questions 
as to conflicts of interest112.  

Public procurement remains an area highly vulnerable to corruption. Businesses’ attitudes 
towards corruption in the EU show that 12% of companies in Poland (EU average 25%) think 
that  corruption  has  prevented  them  from  winning  a  public  tender  or  a  public  procurement 
contract  in  practice  in  the  last  three  years113.  The  Single  Market  and  Competitiveness 
Scoreboard on access to public procurement in Poland reports a high 54% of single bids for 
2023 (EU average 29%). However, 58% of companies perceive the level of independence of 
the  public  procurement  review  body  (National  Board  of  Appeal)  as  very  or  fairly  good114. 
Following  several  delays,  legislative  amendments  to  the  Act  on  Public  Finances  have  been 
proposed in March 2025, which stakeholders welcome, indicating however risks of reduced 
transparency due to high thresholds that would not cover many local government tenders115. 
Public  procurement  data,  including  on  large-scale  investments,  is  publicly  available,  but 
corruption risk monitoring is still difficult due to scattered data116. The Central Anti-Corruption 
Bureau’s investigations of suspected irregularities relating to EU structural funds, corruption 
and abuse of public officials’ powers in the National Centre for Research and Development117 
led to pre-trial investigations and several arrests118. Investigations into alleged bid-rigging and 
embezzlements pertaining to the Justice Fund, which provides post-penitentiary assistance and 
support to crime victims, have led to several arrests, pre-trial detention and an arrest warrant 
for a high-level official, with an estimated damage of more than EUR 50 million (PLN 224 
million)119. Stakeholders still consider public procurement as the main corruption risk sector, 
with potential impacts on investments and business activities.  

107   Arts. 144(1)(3)(e), 132(5) Electoral Code. National Electoral Commission Resolution, 18 November 2024. 
See also Sejm (2024), Final report of the Committee of Inquiry to investigate the postal voting for the election 
of the President in 2020 and vote to submit notifications to the prosecution service for alleged crimes that led 
to charges against a former high-level official on for exceeding his powers. 

108   OSCE/ODIHR (2024c); see also (2024a), p. 1: the lack of requirements for reporting prior to election day, and 
unregulated  third-party  campaigning,  combined  with  insufficient  campaign  finance  regulation  for  the 
referendum, negatively affected transparency and accountability of political party and campaign finance. 

109   See 2024 Rule of Law Report, Poland, p. 24. 
110   By increased transparency requirements and a ban of SOE executives’ payments to politicians. Sejm Deputies' 

bill on corporate governance in companies with State Treasury shareholding, Paper no. 261. 

111   Country visit Poland, Supreme Audit Office. 
112   OSCE/ODIHR (2024a), pp. 1-3. The National Election Commission is the oversight body. 
113   Flash Eurobarometer 557 (2025). This is 13 percentage points below the EU average. 
114   Figure 59, 2025 EU Justice Scoreboard. 
115   With approx. 60% below the threshold, country visit, Poland,  Batory Foundation. Draft Act Amending the 

Criminal Code and the Public Finance Act (UD 197).  

116   Country visit Poland, Batory Foundation/ Helsinki Foundation. 
117   The Centre is an executive agency of the Ministry of the Science and Higher Education.  
118   Central Anti-Corruption Bureau (2023). The Supreme Audit Office’s control found large scale irregularities 

confirming corruption risks, see Supreme Audit Office (2023); Science Business (2023).  

119   Estimates provided by Ministry of Justice. National Prosecutor Office (2024). European Parliament, (2024). 

13 

 
 
 
III.  MEDIA PLURALISM AND MEDIA FREEDOM  

The  Government  plans  to  address  persisting  concerns  regarding  the  impartiality  and 
independence of the media regulator with a new media law reform. The media regulator – 
the  National  Broadcasting  Council  (KRRiT)  –  continues  to  face  criticism  for  its  perceived 
partisan  stance,  raising  concerns  among  stakeholders  as  to  the  regulator’s  impartiality  and 
independence120.  The  Government  plans  to  introduce  stricter  eligibility  and  experience 
requirements  for  the  regulator’s  members  to  address  concerns  related  to  the  appointment 
procedures as part of the media law reform implementing the European Media Freedom Act 
(EMFA)121.  However,  some  stakeholders  consider  the  proposed  changes  insufficient, 
advocating  for  a  more  comprehensive  reform  of  the  appointment  process,  including  more 
robust safeguards122. Moreover, some stakeholders have raised concerns as to the regulator’s 
discretion in imposing fines on broadcasters for content deemed unlawful and as regards the 
Chair’s  prerogatives  under  the  current  rules123,  questioning  the  adequacy  of  the  current 
safeguards124.  The  Polish  authorities  plan  to  introduce  collegiality  into  the  decision-making 
process regarding fines, by requiring decisions of the media regulator’s Chair to be preceded 
by a resolution of the KRRiT125. The media regulator pointed out that its budget only partially 
covers its needs related to its human resources and constitutional functions, raising concerns 
about  the  sufficiency  of  available  funding126.  The  Government  intends  to  evaluate  the 
regulator’s financial needs as part of the media law reform127. 

There has been some further progress to ensure adherence to fair, transparent and non-
discriminatory procedures when granting operating licences to media outlets128. Whilst 
no new negative decisions regarding the granting or renewing of licences have been reported 
since the 2024 Rule of Law report129, stakeholders continue to raise concern about gaps in the 

120   International Press Institute and Media & Journalism Research Center (2025), p. 4. 
121   Ministry  of  Culture  and  National  Heritage  (2024),  p.  15,  as  confirmed  during  the  country  visit  Poland, 
Ministry of Culture. The concept of new law highlights the importance of  Council’s members specialised 
knowledge in media, economics, and law, while stressing the need for independence from political affiliations 
and influence. The concept of draft law inclines changing one-third of the KRRiT members every two years. 

122   7 NGOs and Reporters Without Borders (2025), written inputs, pp. 31-32 and 15 respectively. 
123   The 1992 Broadcasting Act, Article 53. According to this provision, fines are imposed by the Chair of the 
National Broadcasting Council – not by the entire Council collegially. For instance, one of the alerts on the 
Mapping Media Freedom monitoring report registers the case of the media regulator sanctioning for airing a 
documentary about alleged wrongdoing linked to Catholic priest and media owner Tadeusz Rydzyk. This fine 
against TVP follows a similar case in November 2024, when KRRiT fined TVN, Poland’s largest private 
broadcaster, for another critical report on Rydzyk. 

124   7 NGOs (2025), written input, pp. 30, 32. Article 18 of the 1992 Broadcasting Act stipulates, inter alia, that 
“programmes may not promote actions contrary to the law, to the Polish raison d'état and attitudes and views 
contrary to morality and social good (...)’ and should respect the religious beliefs of the audience, ‘and in 
particular the Christian system of values”. Media Pluralism Monitor (2025), p. 16. 

125   Ministry  of  Culture  and  National  Heritage  (2024),  p.  10,  as  confirmed  during  the  country  visit  Poland, 
Ministry of Culture and National Heritage. Under the current provisions, imposing sanctions is a prerogative 
of the Chair, which may be appealed to a court.  
126   Country visit Poland, National Broadcasting Council. 
127   Country visit Poland, Ministry of Culture and National Heritage. 
128   The 2024 Rule of Law Report recommended Poland to: “[p]ursue efforts to ensure that fair, transparent and 
non-discriminatory procedures, are adhered to for the granting of operating licences to media outlets ensure 
that fair, transparent and non-discriminatory procedures are adhered to for the granting of operating licences 
to media outlets”. 

129   Country  visit  Poland,  Ministry  of  Culture  and  National  Heritage;  Wirtualna  Polska  (2024).  However,  in 
September 2024, a Warsaw court in Poland has determined that the National Broadcasting Council (KRRiT) 
mishandled the renewal of TVN24's licence, deeming it a "serious violation of the law". The court also found 

14 

 
 
 
 
safeguards  of  the  licencing  process  and  the  slow  pace  of  decisions130.  The  Mapping  Media 
Freedom monitoring report has noted a new alert regarding delays in licences renewals131. As 
part of the announced reform to implement the EMFA and following a public consultation over 
the  concept  of  law,  the  Government  plans  to  introduce  a  revamped  licensing  system  which 
would streamline the process and ensure timely decision-making, with a provision keeping the 
issuance of licences within a clearly defined timeframe132. Therefore, some further progress 
has  been  made  on  the  recommendation  to  ensure  fair,  transparent  and  non-discriminatory 
procedures for granting operating licences to media outlets.  

Pending  new  rules  to  strengthen  the  independence  of  the  management  of  public 
broadcasters’ management bodies, there has been a decrease in politically biased media 
content in public service media. The current management of the major public service media 
(i.e.  Polish  Television,  Polish  Radio  and  Polish  Press  Agency)  is  composed  of  temporary 
liquidators133, appointed to oversee public broadcasting entities during the state of liquidation. 
However, pending the media law reform announced by the Government, standards are assessed 
by some stakeholders as not sufficient to protect their independence134, which amplifies the 
vulnerability of public service media. In addition, while there has been a notable decrease in 
polarising and biased content in public service media,  some stakeholders have reported that 
certain  bias  in  reporting  political  content  occasionally  persists  while  impartiality  in  news 
programmes  has  not  been  achieved135,  as  highlighted  also  by  the  Media  Pluralism  Monitor 
2025136.  

There has been some further progress to ensure an effective legislative framework for the 
independent  governance  and  editorial  independence  of  public  service  media137. 
Stakeholders  have  questioned  the  independence  of  the  National  Media  Council  (RMN),  in 
charge  of  appointing  public  broadcasters’  management  board  members,  due  to  the  lack  of 
proper  safeguards  in  the  nomination  and  dismissal  of  its  members,  making  it  vulnerable  to 
undue influence138. As part of the reform to implement the EMFA, the Government is preparing 
a draft law that would dissolve the National Media Council to ensure more coherence in the 

that the handling of TVN7's licence was improper. As a consequence, KRRiT's  Chair, Swirski, was fined 
PLN  60 000 for failing to extend TVN Style's concession; referring to the decision on renewed lincences 
issued in June 2024, whereas the re-concession process lasted 11 months. 

130   Media Pluralism Monitor (2025), p. 27. 
131   Mapping Media Freedom (2024) Platform issued on 17 October 2024 alert noting that the media regulator 

postponed decisions on TVN and Agora broadcasting licences. 
132   Country visit Poland, Ministry of Culture and National Heritage. 
133   The appointment of liquidators followed the decision of the Minister of Culture and National Heritage as the 
body  exercising  the  ownership  rights  of  the  State  Treasury  over  the  public  service  media  to  dismiss  the 
management  bodies  of  public  service  media  on  the  basis  of  the  Commercial  Companies  Code  and  the 
liquidation state.  

134  The  decision to liquidate  PSM was  taken in December 2023 in accordance with the Code  of Commercial 
Companies  and  the  Act  on  the  Principles  of  Managing  State  Property.  The  liquidators  may  be  subject  to 
dismissal at any time and without a clearly defined cause, given their accountability to  the Polish state, as 
represented by the Minister of Culture and National Heritage; Civil Liberties Union for Europe (2025), p. 
811. 

135   Country visit Poland, Helsinki Foundation for Human Rights and Stefan Batory Foundation. 
136   7 NGOs (2025), written input, p. 34, as confirmed during the country visit Poland by Fundacja Batorego. In 
addition, as reported by Demagog (2024), a large portion of airtime is still allocated to representatives of the 
ruling coalition. Media Pluralism Monitor (2025), p. 28. 

137   The 2024 Rule of Law Report recommended to: “[p]ursue efforts to ensure an effective legislative framework 
for  the  independent  governance  and  editorial  independence  of  public  service  media,  taking  into  account 
European standards on public service media”. 

138   International Press Institute and Media & Journalism Research Center (2025), pp. 13-14. 

15 

 
 
 
media regulation landscape and re-entrust the media regulator with the function of appointing 
public broadcasters’ management board members139. Moreover, the draft law would include 
guarantees for the independence of public service media and rules for appointing the governing 
bodies  of  public  broadcasting  companies  to  ensure  their  editorial  and  managerial 
independence140. The Government also plans to reform and strengthen the competences of the 
programme  councils  of  public  service  media,  and  to  ensure  the  separation  of  editorial  and 
management  departments141.  Overall,  some  further  progress  has  been  made  on  the 
recommendation. 

Public broadcasters are facing operational instability due to the temporary suspension of 
licence  fee  funds,  but  a  new  state-funded  model  is  expected.  The  media  regulator 
temporarily suspended the allocation of public funds collected through the licence fee system 
in  2024, impacting the operational  stability  of Poland’s major public broadcasters142. These 
licence fee funds were held in a court deposit account for part of the year, as a result of the 
ongoing  liquidation  of  Poland’s  major  public  service  media143.  Public  broadcasters  have 
initiated  proceedings  against  the  media  regulator’s  decision  to  suspend  the  allocation  of 
funds144, leading  to  payments  in  some cases145.  Nevertheless, the licence fee system  is not 
considered fully efficient, and state funding is used to offset losses incurred from licence fee 
collection146. As a result, more households stopped paying their licence fees147. As part of the 
forthcoming media law reform to implement the EMFA, the Government plans to replace the 
licence fee system with an annual budget equivalent to a minimum 0.09% of Poland’s GDP for 
public service media148. 

Certain challenges persist in safeguarding media pluralism and editorial independence, 
particularly  in  situations  involving  foreign  investment  in  media  ownership.  The  Media 
Pluralism  Monitor  (MPM)  2025  notes  the  medium-high  risk  of  market  plurality  with  the 
indicators of high risk of plurality of media providers as well as editorial independence from 
commercial  and  owners  influence149.  In  particular,  it  reports  challenges  in  balancing  state 
intervention and protection of national  security in cases of some media ownership changes, 
such  as  takeovers  or  mergers  involving  foreign  capital.  In  December  2024,  Poland  added 
private broadcasters TVN and Polsat to its list of strategic companies, requiring Government 
approval for their sale or change of ownership150. The Government has argued that this measure 
was essential to safeguard media critical to the state’s information security and to ensure the 

139   The provisions on the National Media Council were declared as inconsistent with the Constitution since they 
deprived the National Broadcasting Council of the powers necessary for that body to carry out its function of 
“upholding freedom of expression, the right to information and the public interest in broadcasting” (Judgment 
of the Constitutional Tribunal of 13 December 2016, case no. K 13/16). 

140   Polish Government, written input, p. 19 as confirmed during the country visit by the Ministry of Culture. 
141   Ministry of Culture and National Heritage (2024), p. 27. 
142   Except for the licence fee funds released by the National Broadcasting Council to the local PSM  following 

the September 2024 floods in Southern and Western Poland (October 2024 instalment). 

143   Namely of Polish Television, Polish Radio and Polish Press Agency.  
144   Country visit Poland, Ministry of Culture and National Heritage.  
145   Media Pluralism Monitor (2025), pp. 15-16. 
146   Country visit Poland, Ministry of Culture and National Heritage. Public service media are funded through a 
mix  of  licence  fees,  advertising,  and  direct  government  funding.  International  Press  Institute  &  Media  & 
Journalism Research Center (2025), p. 15. 

147   International Press Institute & Media & Journalism Research Center (2025), p. 15. 
148   Ministry of Culture and National Heritage (2024), p. 45, as confirmed during the country visit Poland by the 

Ministry of Culture and National Heritage.  

149   Media Pluralism Monitor (2025), p. 19. 
150   Council of Ministers (2024b). 

16 

 
 
 
sector’s independence and stability amid potential external threats151. The Government further 
stated that this measure was a temporary solution, pending the implementation of the EMFA. 
Yet,  some  stakeholders  have  expressed  concerns  over  the  potential  constraints  on  media 
pluralism152  and  on  the  balance  between  state  intervention  and  protection  of  national 
security153.  

State  advertising  expenditure  has  become  more  evenly  spread  across  multiple  media 
platforms. Currently, there are no established procedures for the allocation of public funds for 
state  advertising154,  and  the  MPM  2025  reports  little  transparency.  Nevertheless,  there  are 
reports of some progress since the 2024 Rule of Law Report with a more even distribution of 
state advertising expenditure across media outlets155. The Government intends, as part of the 
upcoming  media  law  reform,  to  address  the  various  aspects  of  state  advertising,  including 
transparency, and to address the process of controlling the process of allocating public funds 
for state advertising156.  

The  situation  regarding  transparency  of  media  ownership  improved,  while  the 
Government is working on a media ownership database. As part of the market plurality, the 
MPM 2025 notes that transparency of media ownership reached a medium-low risk level, a 
decrease compared to the 2024 Rule of Law Report. However, some stakeholders have noted 
the issue of fragmentation of ownership data157. In addition, some issues have been reported 
related to the lack of transparency in local media ownership, with stakeholders highlighting 
uneven level playing field between privately owned local media and those publicly owned by 
local government authorities158. The Government is working on a media ownership database 
as part of the media law reform to implement the EMFA. 

The legal framework for access to public information remains stable, though stakeholders 
report  certain  challenges  with  its  implementation.  This  is  particularly  due  to  delays  in 
appellate proceedings following refusals or absence of responses to information requests159. 
Additionally,  authorities  may  rely  on  several  exceptions  which,  according  to  stakeholders, 
results in inconsistent and restrictive interpretations160. As highlighted by the MPM, journalists 
continue to encounter challenges in obtaining public information such as being denied access 
by press officers at state institutions and experiencing prolonged accreditation procedures161. 

The  number  of  SLAPPs  has  decreased,  while  the  Government  continues  to  work  on 
legislation to address additional challenges affecting the safety of journalists. The number 
of  Strategic  Lawsuits  Against  Public  Participation  (SLAPP)  initiated  by  national  public 
authorities decreased compared to the 2024 Rule of Law Report162 and state-owned companies 
have dropped some lawsuits. However, some new cases have emerged, launched primarily by 

151   Prawo.pl (2024). 
152   European Civic Forum (2025), p. 16. 
153   Media Pluralism Monitor (2025), p. 20. 
154   Country visit Poland, Ministry of Culture and National Heritage. 
155   Media Pluralism Monitor (2025), p. 28; Country visit Poland, Chamber of Press Publishers. 
156   Country visit Poland, Ministry of Culture and National Heritage. 
157   Media Pluralism Monitor (2025), pp. 18-19.  
158   Demagog (2024a), Portal Samorządowy (2025). 
159   Country visit Poland, Watchdog Polska. 
160   7 NGOs (2025), written input, pp. 31, 37. 
161   Media Pluralism Monitor (2025), p. 6.  
162   7 NGOs (2025), written input, p. 37, as confirmed during the Country visit with the Helsinki Foundation for 

Human Rights. 

17 

 
 
 
private entities, individuals and local governments163. In the reporting period, the Council of 
Europe  Platform  to  Promote  the  Protection  of  Journalism  and  the  Safety  of  Journalists  has 
recorded four new alerts concerning Poland. Two of the created alerts concern harassment and 
intimidation  of  journalists,  respectively,  an  incident  of  a  journalist  denied  access  to  crisis 
management  meetings,  and  threats  against  an  investigative  journalist.  The  other  two  alerts 
concern  defamation  and  insult  laws  and  practice,  and  journalists  fearing  a  loss  of  editorial 
independence  as  a  TV  channel  reconstructs164.  Moreover,  the  Mapping  Media  Freedom 
monitoring report has noted twenty-one new alerts: nine relating to incidents of interference, 
eight relating to verbal attacks and four classified as lawsuits and fines165. At the same time, 
self-regulatory measures and trade unions are lacking within the journalistic community166. In 
January 2025, the Government published a draft law to implement the anti-SLAPP Directive167. 

The  use  of  defamation  and  insult  laws  against  journalists  has  been  reported  to  pose 
additional risks. The Safety of Journalists Platform reports a systemic issue with journalists 
lacking adequate protection under the current defamation and insult laws168. According to some 
stakeholders,  the  current  law  on  defamation  creates  additional  risks  of  SLAPPs  being  used 
against  journalists169.  As  part  of  the  law  implementing  the  anti-SLAPP  Directive,  the 
Government intends to limit the severity of the penalty for the offence of defamation170. While 
stakeholders view the Government’s engagement as positive, they consider that this measure 
would not entirely eliminate the risk of defamation being used as a potential basis for SLAPPs 
against journalists171.  

The Government is working on new rules to protect journalistic sources and confidential 
communications. Some stakeholders deem the existing rules for the protection of journalistic 
sources and confidential communications insufficient172. The Government intends to address 
these issues in the upcoming media law reform and sees the need to launch inter-ministerial 
dialogue to find appropriate solutions to address these issues173. Building on this momentum, 
in  December  2024  the  Polish  authorities  amended  three  regulations  related  to  operational 
control carried out by special services174. Under the new rules, requests for operational control 
addressed to the prosecutor’s office and courts must be better substantiated and the courts must 
justify  not  only  refusals,  but  also  authorisations  of  operational  control.  However,  some 
stakeholders have called for more comprehensive rules on surveillance175. 

163   7 NGOs (2025), written input, p. 37; ENHRI (2025), written input, p. 16. 
164   Council of Europe Platform to promote the protection of journalism and safety of journalists (2025).   
165   European Centre for Press and Media Freedom (2025). 
166   Country visit Poland, Journalists’ Society (Towarzystwo Dziennikarskie); Media Pluralism Monitor (2025), 

p. 7. 

167   Ministry of Justice (2025g).  
168   Safety of Journalists Platform (2024). Defamation (as per Article 212 of the Criminal Code) and insult (under 
Article 216) are considered criminal offenses, carrying penalties such as fines or community service. When 
defamation or insult occurs through the media, imprisonment remains a possible punishment. 

169   Safety of Journalists Platform (2024). 
170   Prawo.pl (2025c). 
171   Gazeta Prawna (2025). 
172   7 NGOs (2025), written input, p. 36. For instance, in practical terms: Judicial review is limited to cases where 
journalists sources are presented as evidence in criminal proceedings, rendering this protection limited. The 
European Court of Human Rights (ECHR) found in the case Pietrzak v. Poland, Bychawska-Siniarska and 
Others v. Poland (June 2024) that the Polish national legislation fails to offer adequate safeguards against 
excessive surveillance and unwarranted interference with individuals' privacy. 

173   Country visit Poland, Ministry of Culture. 
174   Council of Ministers (2024c). 
175   Media Pluralism Monitor (2025), p. 37. 

18 

 
 
 
IV. 

OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Poland  strengthened  the  rules  governing  consultations  to  improve  the  quality  of 
legislation. In line with its commitments under the Recovery and Resilience Plan176, Poland 
amended177  the  rules  of  procedure  of  the  Sejm,  the  Senate  and  the  Council  of  Ministers  to 
introduce  a  mandatory  impact  assessment  and  public  consultation  for  draft  laws.  While  the 
long-term effects of these reforms will need to be assessed178, stakeholders179 consider that the 
new rules provide them with sufficient time to present their views on draft legislation180.  

On 1 January 2025, Poland had 52 leading judgments of the European Court of Human 
Rights pending implementation, an increase of 6 compared to the previous year181. At that 
time, Poland’s rate of leading judgments from the past 10 years that had been implemented was 
at  49%  (unchanged  from  2024;  51%  remained  pending),  and  the  average  time  that  the 
judgments  had  been  pending  implementation  was  5  years  and  5  months  (unchanged  from 
2024)182. The oldest leading judgment, pending implementation for almost 20 years, concerns 
excessive  length  of  proceedings  before  administrative  bodies  and  courts  and  absence  of  an 
effective remedy183. As regards the respect of payment deadlines, on 31 December 2024 there 
were 26 cases in total awaiting confirmation of payments (compared to 18 in 2023)184. On 16 
June 2025, the number of leading judgments pending implementation had increased to 54185. 
Upon request of the Polish authorities, the European Court of Human Rights postponed, from 
23 November 2024 to 23 November 2025, the examination of cases raising similar problems 
as in those identified in the pilot judgment in the Wałęsa v. Poland case, pending resolution of 
the systemic problems and adoption of general measures to remedy them186. It also suspended 
until that same date the processing of applications submitted in the context of the reorganisation 
of the judicial system in Poland in the years 2016-2023187. As mentioned above, in line with 
its commitments under the Action Plan on the Rule of Law, Poland is preparing a draft law on 
the implementation of rulings of the European Court of Human Rights188, which has not yet 
been tabled to Parliament. 

Efforts are made to address instances of abuse of power by public officials. Two out of the 
three investigative committees established by the Sejm finalised their works and reported on 
the scope of criminal liability of public officials that should be followed up by the prosecution 

176   2024 Rule of Law Report, Poland, p. 29. 
177   The new rules of procedures of the Sejm entered into force on 1 November 2024, and those of the Council of 

Ministers on 20 August 2024; Polish Government (2025), written input, p. 23. 

178   According to stakeholders, for the time being the impact of the change is limited with consultations on some 
60-75%  of  draft  laws  proposed  in  May-December  2024,  and  better  justification  for  reducing  consultation 
below 21 days would be desirable; 7 NGOs (2025), written input, pp. 40-41. 

179   In the period November-December 2024, all draft laws proposed by  Sejm members were subject to public 
consultation  (23);  in  one  case  a  30-days  consultation  period  was  shortened  to 14  days.  Before,  no public 
consultations were held. 7 NGOs (2025), written input, p. 4; Polish Government (2025), written input, p. 23. 
180   Country visit to Poland, Ombudsperson. According to the Ombudsperson’s office, while the Ombudsperson 
is  provided  with  adequate  time  to  present  views  on  draft  legislation  tabled,  its  recommendations  are  not 
reflected in the legislation adopted. 

181   For an explanation of the supervision process, see the Council of Europe (2025).   
182   All figures calculated by the European Implementation Network (EIN) and based on the number of cases that 

are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 7. 

183   Judgment of the ECtHR, 51837/99, Beller v. Poland, pending implementation since 2005.  
184   Council of Europe (2025), p. 157.   
185   Data according to the online database of the Council of Europe (HUDOC). 
186   ECtHR judgment of 23 November 2023, Wałęsa v. Poland, 50849/21. 
187   ECtHR (2024). 
188   Draft law UD177 of 23 December 2024; Polish Government (2025), written input, p. 25. See Pilar I, p. 3. 

19 

 
 
 
service189. Before they concluded their work, the Constitutional Tribunal considered two of the 
investigative  committees  to  be  unconstitutional  on  grounds  of  their  broad  mandate  and  the 
limited timeframe for their analysis190. The President of the Republic vetoed the law abolishing 
the State Committee for the examination of Russian influence on the internal security of Poland 
between  2007  and  2022,  which  had  already  ceased  its  operations  in  practice191.  Law 
enforcement  agencies  followed  up  on  the  findings  of  the  Supreme  Audit  Office192.  Legal 
professions are functioning well and enjoy a high degree of independence193, notably as regards 
the protection of professional secrecy, the disclosure of which, when requested by prosecutors, 
is in principle refused by courts194.  

The Ombudsperson continues to fulfil a key role in the system of checks and balances. 
The Ombudsperson enjoys an ‘A’ status by the UN Global Alliance of National Human Rights 
Institutions (GANHRI)195. His annual budget was increased. Nevertheless, the Ombudsperson 
still considers it suboptimal in view of all the tasks linked to his mandate196. The Ombudsperson 
remains committed to promoting a vibrant and pluralistic civic space, where civil society and 
rights’ defenders can do their work freely197.  

Less than half of the companies surveyed in Poland express high levels of confidence in 
the effectiveness of investment protection.  39% of companies are very or fairly confident 
that investments are protected by law and courts. The main reasons among companies for their 
lack  of  confidence  are  the  frequent  changes  in  legislation  or  the  quality  of  the  law-making 
process (36%). 73% perceive the level of independence of the national competition authority 
(Office of Competition and Consumer Protection) as very or fairly good198. The Government 
intends to reduce the administrative burden for business and society, focusing on deregulation 
of commercial and administrative law, creating a task force and, concomitantly, to adopt a draft 
law  to  that  effect199.  The  Supreme  Audit  Office  considers  it  important  to  improve  public 
support for business in Poland to optimise the business environment in line with the guidelines 
contained in  government strategies200.  A number of judicial mechanisms are in  place at  the 
level of the Supreme Administrative Court to ensure the implementation of administrative court 
judgments, which include the possibility to quash administrative decisions for continued non-

189   This  concerns  the  investigative  committee  to  examine  possible  breaches  of  law  by  the  organisers  of  the 
“postal” Presidential elections in 2020 and the investigative committee to examine alleged irregularities in 
the  issuance  of  Polish  visas  to  foreigners. The  investigative  committee  for  the  use  of  “Pegasus”  software 
continues its activities. 

190   Rulings of 6 November 2024 (case U 2/24) and of 10 September 2024 (case U 4/24). The rulings have not 

been published (see Pillar I).  

191   President of the Republic (2024d) who decided to veto the law abolishing the State Committee on 16 August 
2024. For the lack of operability of the State Committee see 2024 Rule of Law Report Poland pp. 31-32. 

192   Country visit to Poland (2025), Supreme Audit Office. 
193   Country visit to Poland (2025), National Bar Council and National  Chamber of Legal Councillors. CCBE 

(2025), written input, p. 156. 

194   According to data presented by the National Bar Council in the context of the country visit to Poland. 
195   Global Alliance of National Human Rights Institutions (2023).  
196   ENNHRI (2025), written input, p. 3. 
197   Ombudsperson (2024), (2025a). 
198   Figures  54,  55  and  60,  2025 EU  Justice  Scoreboard.  35%  of  the  surveyed  investors  perceive  the  quality, 

efficiency or independence of justice as a reason for the lack of confidence in investment protection. 

199   Council of Ministers (2025a), (2025b), Prawo.pl (2025b).  
200   Supreme Audit Office (2024). 

20 

 
 
 
compliance  with  the  court’s  instructions.  However,  these  mechanisms  do  not  include 
disciplinary actions against the responsible officials or direct enforcement measures201. 

Some further progress has been made to improve the framework in which civil society 
operates202.  In March 2025,  the assessment  of the civic space in  Poland was updated from 
‘obstructed’  to  ‘narrowed’203.  The  Public  Benefit  Committee  of  the  Council  of  Ministers 
organised special working groups with civil society organisations on matters pertaining to their 
functioning and intends to reflect their input in future legislation204. Based on the work of the 
groups,  a  draft  amendment  to  the  Act  on  Public  Benefit  Activities  and  Volunteering  was 
prepared and submitted to the Council of Ministers for consideration. Stakeholders underlined 
that the engagement with civil society and the improvements to their financing system are still 
at an early stage, but that the direction is overall good205. A new government program has been 
launched for small and medium-sized non-governmental organisations in small towns, with a 
budget  of  PLN  70  million  for  2025.  Steps  have  also  been  taken  to  increase  the  protection 
against hate crime and hate speech. The Government set up a special Committee to examine 
alleged attacks against civil society organisations and rights defenders in the past and to come 
up with recommendations to strengthen the enabling environment for civil society206. At the 
same  time,  civil  society  organisations  reported  that  measures  adopted  by  the  Government, 
while  not  addressed  specifically  to  NGOs,  adversely  affected  their  functioning207.  Overall, 
some further progress has been made to improve the framework in which civil society operates. 

201   EU  Justice  Scoreboard  2025,  Figure  49.  The  information  provided  reflects  exclusively  the  existing 

mechanisms in the highest administrative court instance. 

202   The 2024 Rule of Law Report recommended to Poland to ‘[c]ontinue the on-going process to improve the 
framework  in  which  civil  society  operates,  taking  into  account  European  standards  on  civil  society 
organisations’. 

203   Rating  given  by  CIVICUS.  Ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed,  obstructed, 

repressed and closed. Until 2024, the civic space was considered obstructed. 

204   Working Group for Simplifying Law as regards the NGOs, Working Group for Activism and Volunteering, 
and Working Group for Civic Participation and Dialogue. Polish Government (2025), written input, p. 27, 
the Council of Ministers (2025), NGO.pl (2025). 

205   7 NGOs (2025), written input, pp. 45-48. 
206   Ministry of Justice (2025f).  
207   The Polish authorities introduced a ban at the Polish-Belarussian border prohibiting entities unauthorised by 
the State bodies from operating at that border. The Polish authorities justify their actions and restrictions at 
the border on grounds of national security. Statements made by MPs or members of the Government against 
NGOs active in the field of environment and migration, gave rise to increasing negative rhetoric against civil 
society organisations working on those issues. 7 NGOs (2025), written input, pp. 46-47. Helsinki Foundation 
of  Human  Rights  (2025a),  Watchdog  Polska  (2025),  written  input,  p.  18.  Country  visit  Poland  (2025), 
Helsinki Foundation of Human Rights and Batory Foundation. 

21 

 
 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2025 Rule of Law report 
can 
https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

Batory  Foundation, (2024),  Position  on the government's  bill  on the coordination  of  anti-corruption 
activities and liquidation of the Central Anti-Corruption Bureau (Oświadczenie Fundacji im. Stefana 
Batorego w sprawie rządowego projektu ustaw o koordynacji działań antykorupcyjnych oraz likwidacji 
Centralnego  Biura  Antykorupcyjnego),  https://www.batory.org.pl/oswiadczenie/stanowisko-fundacji-
im-stefana-batorego-ws-rzadowego-projektu-ustawy-o-koordynacji-dzialan-antykorupcyjnych-oraz-
likwidacji-centralnego-biura-antykorupcyjnego/.  

Bertelsmann  Stiftung  (2024),  Transformation  Index  (BTI)  –  Country  report:  Poland,  https://bti-
project.org/fileadmin/api/content/en/downloads/reports/country_report_2024_POL.pdf.  

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(2025a),  Asset  declarations  –  work  on  a  new  bill, 

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Central 
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Anti-Corruption 

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More 

people 

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Central Anti-Corruption Bureau (2025c), News section, https://www.cba.gov.pl/pl/aktualnosci.  Central 
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Chancellery of the Prime Minister(2024), Draft law on coordination of anti-corruption activities and on 
liquidation 
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2024 
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the  Central  Anti-Corruption  Bureau 

6  December 

of 

of 

Civil 
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Liberties  Union 

(2025), 

Europe 

for 

Rule 

of 

Law 

Report, 

Poland, 

Constitutional  Tribunal,  judgment  of  [date],  Case  K  10/24,  https://trybunal.gov.pl/postepowanie-i-
orzeczenia/wokanda/art/ksztaltowanie-przez-unie-europejska-i-jej-organy-kompetencji-do-wyboru-
przez-panstwo-czlonkowskiego-zrodla-energii-i-ogolnej-struktury-zaopatrzenia-rzeczypospolitej-
polskiej-w-energie-2. 

infringement 

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the 
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stanowiska-polskiego-rzadu-w-postepowaniu-przed-tsue. 

case  C-448/23, 

Constitutional Tribunal (2025b), Notification of a reasonable suspicion of a criminal offence having 
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been 
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22 

 
 
Constitutional Tribunal (2025c), Letter of the President of the Constitutional Tribunal to the Prosecutor-
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Deputy 

Constitutional Tribunal (2025d), Signalisation letter of the President of the Constitutional Tribunal to 
the 
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Disciplinary 

Ordinary 

Officer 

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trybunalu-konstytucyjnego-z-16-stycznia-2025-r.  

(Oświadczenie 

Trybunału 

Prezesa 

2025 

Council  of  Europe:  Committee  of  Ministers  (2025),  Supervision  of  the  execution  of  judgments  and 
decisions of the European Court of Human Rights, 18th Annual Report of the Committee of Ministers, 
https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d. 

Council of Europe: Venice Commission (2024), opinion of 24 June 2024 no. CDL-AD(2024)018. 

Council of Europe: Venice Commission (2024a), opinion of 14 October 2024 nos. CDL-AD(2024)029 
and CDL-AD(2024)034. 

Council of Europe: Venice Commission (2024b), opinion of 11 December no. 2024 CDL-AD(2024)035.  

Council of Europe: Venice Commission and the Directorate General Human Rights and Rule of Law 
(2024c), opinion on European standards regulating the status of judges CDL-AD(2024)02. 

Council of Europe Platform to promote the protection of journalism and safety of journalists (2025), 
Poland, https://fom.coe.int/en/accueil . 

Council  of  Ministers  (2024a),  Resolution  No.  162  of  18  December  2024  on  the  counteracting  the 
negative effects of the constitutional crisis as regards the judiciary (Uchwała Rady Ministrów z dn. 18 
grudnia 2024 r. w sprawie przeciwdziałania negatywnym skutkom kryzysu konstytucyjnego w obszarze 
sądownictwa), https://isap.sejm.gov.pl/isap.nsf/download.xsp/WMP20240001068/O/M20241068.pdf. 

Council  of  Ministers  (2024b)  Regulation  of  18  December  2024  on  the  list  of  entities  subject  to 
protection and their competent control authorities, Journal of Laws 2024 item 1892. 

Council of Ministers (2024c), Amendments to the regulation of the President of the Council of Ministers 
as regards the operational control carried out by special forces (Nowelizacja rozporządzeń Prezesa Rady 
Ministrów 
specjalne)  
https://www.gov.pl/web/sluzby-specjalne/nowelizacja-rozporzadzen-prezesa-rady-ministrow-dot-
kontroli-operacyjnej-realizowanej-przez-sluzby-specjalne. 

realizowanej 

Operacyjnej 

Kontroli 

służby 

przez 

dot. 

Council 
https://www.gov.pl/web/pozytek/grupy-robocze.  

of  Ministers 

(2025),  Working  Groups 

at 

Public  Benefit  Committee 

Council of Ministers (2025a), Draft law amending certain laws in order to deregulate commercial and 
administrative law and to improve the principles of commercial law-making (Projekt ustawy o zmianie 
niektórych  ustaw  w  celu  deregulacji  prawa  gospodarczego  i  administracyjnego  oraz  doskonalenia 
zasad  opracowywania  prawa  gospodarczego),https://www.gov.pl/web/premier/projekt-ustawy-o-
zmianie-niektorych-ustaw-w-celu-deregulacji-prawa-gospodarczego-i-administracyjnego-oraz-
doskonalenia-zasad-opracowywania-prawa-gospodarczego. 

23 

 
 
Council of Mnisters (2025b), Economy without unnecessary barriers  – speeding up the deregulation 
process 
deregulacja 
przyspiesza),https://www.gov.pl/web/premier/gospodarka-bez-zbednych-barier--deregulacja-
przyspiesza.  

(Gospodarka 

zbędnych 

barier 

bez 

– 

Council  of  the  EU  (2024),    European  Public  Prosecutor’s  Office:  the  Council  appoints  European 
prosecutors  from  Poland  and  Sweden  (Prokuratura  Europejska:  Rada  powołuje  prokuratorów 
europejskich 
https://www.consilium.europa.eu/pl/press/press-
releases/2024/12/12/eu-public-prosecutor-s-office-eppo-council-appoints-european-prosecutors-for-
poland-and-sweden/pdf/. 

Szwecji) 

Polski 

z 

i 

Demagog (2024), Who is the media inviting? KO dominance in TVP (Kogo zapraszają media? W TVP 
dominacja  KO),  https://demagog.org.pl/analizy_i_raporty/czysta-woda-bez-kobiet-i-z-dominacja-
koalicji-obywatelskiej-kogo-zapraszaja-programy-publicystyczne.  

Demagog (2024a), Local journalists support ban on local government media.  It's ruining the market 
rynku”), 
(Lokalni 
https://demagog.org.pl/analizy_i_raporty/lokalni-dziennikarze-za-zakazem-mediow-samorzadowych-
to-psucie-rynku/. 

za zakazem  mediów 

samorządowych. 

dziennikarze 

psucie 

„To 

DoRzeczy.pl (2025), The 2025 budget. The President makes a move (Budżet na 2025 rok. Jest ruch 
prezydenta), 
https://dorzeczy.pl/ekonomia/678891/budzet-na-2025-rok-prezydent-duda-zwrocil-sie-
do-trybunalu.html. 

European  Centre  for  Press  and  Media  Freedom  (2025),  Media  Freedom  Rapid  Response  –  Poland, 
https://www.mfrr.eu/.  

European Civic Forum (2025), written input for the 2025 Rule of Law Report. 

European Court of Human Rights (2024), “Rule-of-law” cases against Poland are adjourned for an 
additional  year  (ECHR  269(2024)),  https://www.echr.coe.int/w/-rule-of-law-cases-against-poland-
adjourned. 

European Court of Human Rights, judgment of 1 February 2005, Beller v. Poland, 51837/99. 

European Implementation Network (EIN) (2025), written input for the 2025 Rule of Law Report. 

European  Parliament  (2024),  Parliamentary  question  E-003079/2024,  Actions  of  Viktor  Orbán’s 
government in granting asylum to Marcin Romanowski, former Polish Deputy Minister of Justice, who 
faces prosecution on corruption charges, https://www.europarl.europa.eu/doceo/document/E-10-2024-
003079_EN.html. 

European  Public  Prosecutor’s  Office  (EPPO)  (2024),  College  Decision  of  16  December  2024, 
https://www.gov.pl/attachment/d1da4170-50b3-4f81-8f25-c944ed01d722. 

Gazeta Prawna (2025), A renewed call for the repeal of criminal liability for defamation (Ponowny apel 
o 
zniesławienie), 
https://www.gazetaprawna.pl/wiadomosci/kraj/artykuly/9722075,ponowny-apel-o-zniesienie-
odpowiedzialnosci-karnej-za-znieslawienie.html. 

odpowiedzialności 

zniesienie 

karnej 

za 

GRECO (2023), Fifth Evaluation Round, Second Compliance Report - Poland, https://rm.coe.int/fifth-
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GRECO  (2019),  Fifth  Evaluation  Round,  Evaluation  Report  –  Poland,  https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/168092005c. 

24 

 
 
GRECO (2025), Fourth Evaluation Round, Third Interim Compliance Report, including Follow-up to 
the ad hoc (rule 34) report – Poland, https://rm.coe.int/grecorc4-2024-9-final-eng-3rd-interim-inc-rule-
34-poland-public/1680b35908. 

Helsinki Foundation of Human Rights (2025), Correspondence with the Bureau of the Constitutional 
Tribunal , https://hfhr.pl/upload/2025/03/mw_odpowiedz_tk.pdf. 

Helsinki Foundation of Human Rights (2025a), Opinion of the HFHR on the regulation of the Council 
of  Ministers  as  regards  the  limitation  of  the  right  to  international  protection  (Opinia  HFPC  o 
rozporządzeniu  Rady  Ministrów  w  sprawie  ograniczenia  prawa  do  ochrony  międzynarodowej), 
https://hfhr.pl/aktualnosci/rozporzadzenie-zawieszajace-prawo-do-ochrony-miedzynarodowej. 

International  Press  Institute  and  Media  &  Journalism  Research  Center  (2025),  Media  Capture 
Monitoring  Report:  Poland.  Measuring  Compliance  with  the  European  Media  Freedom  Act, 
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Mapping Media Freedom (2024), Head of KRRiT postpones decisions on TVN and Agora broadcasting 
licences, https://www.mappingmediafreedom.org/. 

Ministry  of  Culture  and  National  Heritage  (2024),  European  Media  Freedom  Act  -  Concept  of 
Implementation into the Polish Legal Order. Report from public consultations (Prezentujemy raport z 
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raport-z-konsultacji-spolecznych-zalozen-do-ustawy-medialnej. 

of 

Ministry 
press 
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rejonowego-w-jastrzebiu-zdroju. 

(2025a), 

release 

Justice 

April 

of 

8 

2025: 

of 

Ministry 
press 
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we-wloclawku. 

(2025b), 

release 

Justice 

April 

of 

7 

2025: 

of 

Ministry 
press 
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dyscyplinarnego-sedziow. 

(2025c), 

release 

Justice 

April 

of 

4 

2025: 

Ministry of Justice (2025d), press release of 7 April 2025: https://www.gov.pl/web/sprawiedliwosc/co-
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(2025e), 

release 

Justice 

March 

19 

of 

of 

2025: 

of 

Ministry 
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(2025f), 

release 

Justice 

press 

April 

of 

7 

2025: 

Ministry  of  Justice  (2025g),  Register  of  draft  legal  acts,  Projekty  aktów  prawnych  -  Ministerstwo 
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of 

Ministry 
press 
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z-funkcji-rzecznika-dyscyplinarnego. 

(2025h), 

release 

Justice 

April 

25 

of 

2025: 

25 

 
 
of 

press 
Ministry 
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(2025i), 

release 

Justice 

April 

24 

of 

2025: 

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competitions  in  2019–2023  (Środki  przyznane  w  Funduszu  Sprawiedliwości  poza  naborami  i 
konkursami  w  latach  2019–2023),    https://www.gov.pl/web/sprawiedliwosc/FS-raport-przyznanych-
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National  Bar  Council  (2024),  Opinion  on  the  MPs’  draft  law  –  implementing  the  Law  on  the 
Constitutional 
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009.pdf  

the  draft 

National Chamber of Legal Councillors (2024), Opinions on the MPs’ draft law on the Constitutional 
Tribunal  and  on 
the  Constitutional  Tribunal, 
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004.pdf   

the  Law  on 

implementing 

law 

National  Council 
2025: 
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kwietnia-2025-r.html. 

Statement 

Judiciary 

(2025a), 

April 

the 

for 

of 

8 

for 

National  Council 
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dnia-11-pazdziernika-2024-r-w-przedmiocie-projektu-ustawy-o-zmianie-ustawy-prawo-o-ustroju-
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11  October 

Judiciary 

the 

of 

2024: 

National  Council  for  the  Judiciary  (2025c),  Summary  of  the  session  of  4-7  March  2025: 
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Prosecution 

November 
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National 
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czynnosci-podejmowanych-przez-prokuratorow-wystepujacych-przed-sadem-najwyzszym. 

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13 

of 

2024: 

National Prosecution (2025), Press release of 14 January 2025: https://www.gov.pl/web/prokuratura-
krajowa/raport-czesciowy-zespolu-prokuratorow-do-zbadania-spraw-pozostajacych-w-
zainteresowaniu-opinii-publicznej. 

26 

 
 
(2025a), 
National 
https://www.gov.pl/web/prokuratura-krajowa/wszczecie-sledztwa-zpg. 

Prosecution 

release 

Press 

of 

11 

February 

2025: 

National Prosecution (2025b),  Press release of 7 March 2025: https://www.gov.pl/web/prokuratura-
krajowa/wytyczne-prokuratora-generalnego-w-zakresie-prowadzenia-postepowan-o-przestepstwa-
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National  Prosecution  Office 
krajowa/aktualnosci. 

(2025c),  News 

section,  https://www.gov.pl/web/prokuratura-

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konkursami w latach 2019-2023 – interactywna mapa), https://www.gov.pl/web/sprawiedliwosc/FS-
raport-przyznanych-srodkow. 

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(Raport częściowy zespołu prokuratorów do zbadania spraw pozostających w zainteresowaniu opinii 
publicznej), 
https://www.gov.pl/web/prokuratura-krajowa/raport-czesciowy-zespolu-prokuratorow-
do-zbadania-spraw-pozostajacych-w-zainteresowaniu-opinii-publicznej.  

NGO.pl  –  Portal  Organizacji  Pozarządowych  (2025),  Working  Group  for  Civic  Participation  and 
Dialogue.  Summary  of  its  first  months’  work  (Grupa  robocza  do  spraw  partycypacji  I  dialogu 
obywatelskiego. Podsumowanie pierwszych miesięcy prac), https://publicystyka.ngo.pl/grupa-robocza-
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Notes from Poland (2025), Poland detains officials accused of corruptly helping 12,500 immigrants 
obtain  visas,  https://notesfrompoland.com/2025/04/09/poland-detains-officials-accused-of-corruptly-
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(2024),  Anti-Bribery  Convention,  Phase  4  –  Two  Year  Follow-Up  Report 

OECD 
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report-on-poland_83945426-
en.html#:~:text=This%20Phase%204%20Two%2DYear,International%20Business%20Transactions
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), 

Official 
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the  Supreme  Court  of  3  September  2024, 

Journal 

Ombudsperson (2024), Remarks of the Ombudsperson as regards the the Local Government Charters 
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other Charters (Uwagi RPO dot. Samorządowych Kart Praw Rodzin. Zapowiedzi zmian w uchwałach i 
uchylenie 
https://bip.brpo.gov.pl/pl/content/rpo-samorzadowa-karta-praw-rodzin-
kolejnych), 
watpliwosci-odpowiedzi. 

Ombudsperson (2025), Another judgment of the ECtHR on the lack of legal recognition of same-sex 
partnerships  in  Poland  (Kolejny  wyrok  ETPC  ws.  braku  prawnego  uznania  w  Polsce  związków 
jednopłciowych), 
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zwiazkow-jednoplciowych. 

Ombudsperson  (2025a),  Ombudsperson  on  the  draft  law  amending  the  Law  on  the  granting  of 
protection to foreigners in the territory of the Polish Republic. Opinion transmitted to the President of 
the Republic (RPO o projekcie nowelizacji ustawy o udzielaniu cudzoziemcom ochrony na terytorium 
RP.  Opinia  przekazana  Prezydentowi  RP),  https://bip.brpo.gov.pl/pl/content/rpo-cudzoziemcy-
ochrona-miedzynarodowa-projekt-opinia-prezydent. 

27 

 
 
Ombudsperson (2024), Laws on the Constitutinal Tribunal. The opinion of ODIHR confirms a part of 
reservations  of  the  Ombudsperson  (Ustawy  dotyczące  Trybunału  Konstytucyjnego.  Opinia  ODIHR 
potwierdza  część  zastrzeżeń  RPO),  https://bip.brpo.gov.pl/pl/content/rpo-ustawy-dotyczace-tk-
uzupelniajace-uwagi-sejm  

OSCE/ODIHR 
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15  October 

2023:  Final  Report, 

OSCE/ODIHR 
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(2024b), 

opinion-Nr.: 

JUD-POL/502/2024, 

OSCE/ODIHR (2024c), ODIHR discusses election observation findings and recommendations on 2023 
parliamentary elections in Poland, https://www.osce.org/odihr/elections/poland/576387. 

OSCE/ODIHR 
https://www.osce.org/files/f/documents/b/8/565423_1.pdf. 

Parliamentary 

(2023d), 

Elections: 

Final 

Report, 

Permanent  Committee  of  the  Council  of  Ministers  (2024),  press  release  of  6  December  2024, 
https://www.gov.pl/web/sprawiedliwosc/komitet-staly-rady-ministrow-przyjal-projekt-rozdzielajacy-
funkcje-prokuratora-generalnego-i-szefa-ms. 

Polish  Government 
15padziernika-program 

(2023),  Coalition  Agreement,  https://www.gov.pl/web/premier/koalicja-

Polish Institute on Human Rights and Business (2024), Basic analysis of the current situation in Poland 
regarding  access 
(…),  https://pihrb.org/wp-
content/uploads/2024/12/PHIRB_RS_1_2024_Analiza-barier_web_final-1-1.pdf. 

in  cases  of  corporate  abuse 

remedies 

to 

Portal Samorządowy (2025), Ministry of Culture and National Heritage: new regulations would allow 
local governments to publish bulletins without advertisements (MKiDN: nowe przepisy dopuszczałyby 
wydawanie 
reklam), 
https://samorzad.pap.pl/kategoria/aktualnosci/mkidn-nowe-przepisy-dopuszczalyby-wydawanie-
przez-samorzady-biuletynow-bez. 

biuletynów 

samorządy 

przez 

bez 

Prawo.pl (2024), TVN and Polsat as strategic companies? Tusk's plan is not so simple legally (TVN i 
Polsat jako spółki strategiczne? Plan Tuska nie taki prosty prawnie), https://www.prawo.pl/biznes/tvn-
i-polsat-jako-spolki-strategiczne-prawnicy-maja-watpliwosci,530512.html. 

Prawo.pl (2025), A section of „neo-judges” was created at the Regional Court in Warsaw (Powstała 
„sekcja  neo-sędziów”  w  Sądzie  Okręgowym  w  Warszawie),  https://www.prawo.pl/prawnicy-
sady/sekcja-neo-sedziow-w-sadzie-okregowym-w-warszawie,531397.html. 

Prawo.pl  (2025a),  Digitalisation 
https://www.prawo.pl/prawnicy-sady/cyfryzacja-sadow-jakie-plany-ms,532071.html. 

in  courts  going  beyond  Swiss-Franc 

loans  cases  (…), 

Prawo.pl (2025b), Draft law on the deregulation finally adopted by the  government (Projekt ustawy 
deregulacyjnej  wreszcie  przyjęty  przez  rząd),  https://www.prawo.pl/biznes/co-zawiera-rzadowa-
ustawa-deregulacyjna,531919.html. 

Prawo.pl (2025c), Suppressing criticism by prosecuting defamation is more difficult, but penalties are 
to  remain  (Tłumienie  krytyki  przez  ściganie  zniesławienia  trudniejsze,  ale  kary  mają  zostać), 
https://www.prawo.pl/prawnicy-sady/znieslawienie-a-zmiany-w-procedurze-cywilnej,531261.html. 

28 

 
 
of 

President 
https://www.prezydent.pl/prawo/wnioski-do-tk/nowela-ustawy-o-krs-skierowana-do-trybunalu-
konstytucyjnego,89868.  

Republic 

(2024a), 

release 

August 

press 

the 

of 

2 

of 

President 
https://www.prezydent.pl/prawo/wnioski-do-tk/dwa-wnioski-do-tk-w-trybie-kontroli-
prewencyjnej,92504.  

Republic 

(2024b), 

release 

press 

the 

of 

7  October 

2024: 

2024: 

of 

President 
https://www.prezydent.pl/aktualnosci/nominacje/prezydent-powolal-bogdana-swieczkowskiego-na-
prezesa-tk,95276.  

the  Republic 

9  December 

(2024c), 

release 

press 

of 

2024: 

of 

President 
https://www.prezydent.pl/prawo/zawetowane/weto-do-ustawy-o-uchyleniu-ustawy-o-panstwowej-
komisji-ds-badania-rosyjskich-wplywow,90267.  

Republic 

(2024d), 

release 

August 

press 

the 

16 

of 

2024: 

of 

President 
https://www.prezydent.pl/prawo/zawetowane/prezydenckie-weto-do-tzw-ustawy-
incydentalnej,98576.  

Republic 

(2025), 

release 

press 

the 

of 

10  March 

February 
President 
https://www.prezydent.pl/aktualnosci/nominacje/prezydent-powolal-wiceprezesa-tk,97718.  

the  Republic 

(2025a), 

release 

press 

21 

of 

of 

2024: 

2025: 

President 
https://www.prezydent.pl/aktualnosci/wydarzenia/prezydent-budzet,96257.  

the  Republic 

(2025b), 

release 

press 

of 

of 

17 

January 

2025: 

Rzeczpospolita (2023), Two candidates to the post of the Vice-President of the Constitutional Tribunal 
selected 
na  wiceprezesa  Trybunału  Konstytucyjnego), 
https://www.rp.pl/sady-i-trybunaly/art38765721-wybrano-dwoch-kandydatow-na-wiceprezesa-
trybunalu-konstytucyjnego. 

kandydatów 

(Wybrano 

dwóch 

Rzeczpospolita (2025), Constitutional Tribunal replies to the opinion of the CJEU Advocate General. 
“Grave violation of exclusive competences” (Trybunał Konstytucyjny odpowiada na opinię rzecznika 
TSUE. 
https://www.rp.pl/sady-i-
trybunaly/art41908791-trybunal-konstytucyjny-odpowiada-na-opinie-rzecznika-tsue-razace-
wkroczenie-w-wylaczne-kompetencje. 

kompetencje”), 

wkroczenie 

wyłączne 

„Rażące 

w 

Science Business (2023), Audit uncovers ‘corruption mechanisms’ at Polish research funding agency, 
https://sciencebusiness.net/news/international-news/audit-uncovers-corruption-mechanisms-polish-
research-funding-agency. 

Sejm (2023), Committee of Inquiry to investigate the legality, correctness and purposefulness of 
actions taken to prepare and conduct the election of the President of the Republic of Poland in 2020 
in the form of postal voting (SKGK), 
https://www.sejm.gov.pl/Sejm10.nsf/agent.xsp?symbol=KOMISJASL&NrKadencji=10&KodKom=S
KGK. 

Supreme  Audit  Office  (2024),  Effects  of  the  functioning  of  the  system  of  business  environment 
instytucji  otoczenia  biznesu  of  27  August  2024 
institutions  (Efekty  działalności  systemu 
(KGP.430.2.2024)): 
https://www.nik.gov.pl/najnowsze-informacje-o-wynikach-kontroli/instytucje-
otoczenia-biznesu.html.  

Supreme Audit Office (2023), NCBR  – Billions spent with no effect for innovations, 16 November 
2023 https://www.nik.gov.pl/en/news/ncbr-billions-spent-with-no-effect-for-innovations.html. 

29 

 
 
Supreme Audit Office (2022a), Post-audit presentation of the audit Implementation of the Government 
Anti-Corruption  Programme  for  2018-2020  (Wystąpienie  Pokontrolne  –  Realizacja  Rządowego 
Programu  Przeciwdziałania  Korupcji  n  alata  2018-2020),  https://www.nik.gov.pl/kontrole/wyniki-
kontroli-nik/pobierz,kap~p_21_007_202109201211591632132719~id5~01,typ,kj.pdf. 

Supreme  Audit  Office  (2022b),  Implementation  of  the  Government  Programme  Counteracting 
Corruption for the Years 2018-2020 (…), https://www.nik.gov.pl/plik/id,27014,vp,29814.pdf. 

Court 

2024: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1028-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2024. 

September 

(2024a), 

release 

press 

27 

of 

Court 

2024: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1017-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2024. 

September 

(2024b), 

release 

press 

of 

3 

Court 

2024: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1024-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2024. 

September 

(2024c), 

release 

press 

12 

of 

Court 

2024: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1047-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2024. 

December 

(2024d), 

release 

press 

23 

of 

court 

2024: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1040-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2024. 

November 

(2024e), 

release 

press 

22 

of 

Court 

2025: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1070-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2025. 

(2025), 

release 

press 

April 

of 

5 

Court 

2025: 
Supreme 
https://www.sn.pl/aktualnosci/SitePages/Wydarzenia.aspx?ItemSID=1059-0dc69815-3ade-42fa-bbb8-
549c3c6969c5&ListName=Wydarzenia&rok=2025. 

February 

(2025a), 

release 

press 

27 

of 

Wirtualna Polska (2024), High fine for Świrski. KRRiT chief punished by court (Wysoka grzywna dla 
Świrskiego.  Szef  KRRiT  ukarany  przez  sąd),  https://wiadomosci.wp.pl/swirski-ukarany-przez-sad-
razaca-bezczynnosc-7074551057144320a.  

30 

 
 
 
 
 
Annex II: Country visit to Poland 

The Commission services held virtual meetings in March 2025 with: 

•  Association of Judges ‘Sędziowie RP’  
•  Association of Judges ‘Themis’ (Stowarzyszenie Sędziów Polskich Themis)  
•  Association  of  Judges  and  Prosecutors  ‘Iustitia’  (Stowarzyszenie  Sędziów  Polskich 

Iustitia)  

•  Association of Polish Journalists (Stowarzyszenie Dziennikarzy Polskich) 
•  Association  of  Prosecutors  ‘Lex  Super  Omnia’  (Stowarzyszenie  Prorkuratorów  Lex 

Super Omnia)  

•  Batory Foundation (Fundacja Batorego)  
•  Central Anti-Corruption Bureau (Centralne Biuro Antykorupcyjne)  
•  Helsinki Foundation for Human Rights (Helsinska Fundacja Praw Człowieka)  
•  Ministry  of  Culture  and  National  Heritage  (Ministerstwo  Kultury  i  Dziedzictwa 

Narodowego)  

•  Ministry of Justice (Ministerstwo Sprawiedliwości)  
•  National Bar Council (Naczelna Rada Adwokacka) 
•  National Chamber of Legal Councillors (Krajowa Izba Radców Prawnych)  
•  National Council for the Judiciary (Krajowa Rada Sądownictwa)  
•  National Media Council (Rada Mediów Narodowych) 
•  National  Television  and  Radio  Broadcasting  Council  (Krajowa  Rada  Radiofonii  i 

Telewizji) 

•  Office of the Minister of European Affairs (Urząd Ministra ds. Europejskich) 
•  Ombudsperson’s Office (Biuro Rzecznika Praw Obywatelskich) 
•  Polish Media Association (Stowarzyszenie Polskich Mediów) 
•  Prosecutor General’s Office (Prokuratura Generalna) 
•  Society of Journalists (Towarzystwo Dziennikarskie) 
•  Supreme Administrative Court (Naczelny Sąd Administracyjny) 
•  Supreme Audit Office (Najwyższa Izba Kontroli) 
•  Supreme Court (Sąd Najwyższy)  
•  Watchdog Polska  

* The Commission also met the following organisations in a number of horizontal meetings:  

•  Amnesty International 
•  Araminta 
•  Civil Liberties Union for Europe  
•  Civil Society Europe  
•  European Civic Forum  
•  European Partnership for Democracy 
•  European Youth Forum, 
• 
• 

International Commission of Jurists  
International Federation for Human Rights (FIDH) 

31 

 
 
 
•  JEF Europe 
•  Philea – Philanthropy Europe Association. 
•  Transparency International  

32