The Council of Europe's anti-corruption body - the Group of States Against Corruption (GRECO) - has published a new report assessing Poland's progress in implementing its 2019 recommendations on preventing corruption and promoting integrity in central government (top executive functions) and law enforcement agencies. GRECO concludes that Poland has implemented satisfactorily three of the 21 recommendations; eight recommendations have been partly implemented, and ten recommendations remain non-implemented. (See also the unofficial translation into Polish, as provided by the authorities of Poland).
Since the last assessment, carried out two years ago, some progress has been made concerning persons with top executive functions (PTEFs). Guidelines on rules of conduct for PTEFs and a gift policy have been developed, as have rules on public consultation and impact assessment. Oversight of access-to-information has improved, and work is underway to develop cross-ministerial guidelines on PTEFs' engagements with lobbyists and third parties. Draft legislation requiring disclosure of spouses' separate property is under parliamentary scrutiny.
However, progress is required in other areas. A general integrity plan for PTEFs remains at an early stage. Post-employment restrictions, ancillary activity regulations, training programs for PTEFs, confidential counselling, asset declarations and review remain unaddressed. GRECO encourages the Government to ensure that plans and reforms translate into meaningful and concrete progress.
With respect to law enforcement agencies (the Police and Border Guard), the Border Guard has drafted an anti-corruption policy and has adopted professional ethics rules and a gift policy. The entry into force of the Law on the Protection of Whistleblowers is welcomed, while its implementation by the Police and the Border Guard has not yet been evaluated. However, confidential counselling is not available to Police and Border Guard officers. Despite the introduction of objective criteria for their appointment and promotion, transparency and competitive selection processes are lacking, as are proper vetting procedures and clear dismissal procedures. Regulating the exercise of secondary activities is still under internal review.
GRECO concludes that Poland is not in sufficient compliance with the recommendations and has requested a progress report on the implementation of the outstanding recommendations by 31 March 2026.
