| In Principle

The opportunities for using public-private partnerships in the Polish defence sector are attracting greater and greater attention. This is particularly evident in the context of the current challenges in implementing the Pact for the Security of Poland—Central Pomerania and the recommendations from the European Investment Bank for execution of key infrastructure projects. The Pact for the Security of Poland report was announced on 5 September 2025 in the Pomeranian city of Ustka. This strategic document calls for implementation of key infrastructure projects, including upgrading of seaports, expansion of transhipment terminals, and adapting road and rail networks for military transport.

The defence sector in Poland and Europe as a whole is growing at a pace not seen for decades. Increased state budget expenditures, new financial instruments (EDF, SAFE, ReArm Europe, Poland’s Security and Defence Fund), and the openness of state-run entities to cooperation with private industry are creating genuine business opportunities for Polish and foreign firms. More and more businesses, including those in the civilian economy, are considering taking part in projects for the Polish Armed Forces or submitting bids in tenders for strategic supplies, services and infrastructure.

The Data Act became applicable on 12 September 2025. What do businesses need to pay attention to under this new EU-wide regulation?

Whistleblowing became a buzzword in Poland in 2024 following the delayed implementation of the EU’s Whistleblower Directive (Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law) (WBD). By September 2024, most private companies in Poland were required to comply with national legislation mandating internal policies for reporting and follow-up actions. At the time, many organisations scrambled to meet these statutory requirements—some were fine-tuning existing speak-up channels to align with the new law, while others were building a framework from scratch. The business press was flooded with discussions on compliance, and webinars and seminars on the topic were everywhere. However, much of the focus was on setting up reporting channels and policies, often overlooking the broader significance and long-term impact of these changes.

Today, 9 September 2025, an amendment to the Public Procurement Law entered into force which fundamentally changes the rules for access to the Polish public procurement market by contractors from certain third countries. The changes result from EU competition policy and judgments from the Court of Justice recognising this concept in cases C-652/22 Kolin Inşaat Turizm Sanayi ve Ticaret AŞ and C-266/22 CRRC Qingdao Sifang.

On 25 August 2025 a bill to amend the Environmental Protection Law was posted on the Government Legislation Centre website. The proposal awards ecological organisations, among others, the right to challenge air protection programmes, revisions to such programmes, and sort-term action plans in this area.

On 21 August 2025, the President of Poland signed the Act of 5 August 2025 Amending the Civil Procedure Code, the Civil Code and Certain Other Acts. The key changes involve electronic service of documents, digitalisation of appellate instruments, and the increased importance of mediation.

The recent amendment to the Civil Procedure Code repealed a problematic regulation that allowed the courts to reject pleadings. The regulation was abused in practice, delaying court proceedings. 

Following a pilot programme started in 2024 and involving more than 70 lawyers across all practice groups, we have adopted Legora, the leading collaborative AI platform for lawyers. Legora is designed to maximise collaboration between legal services and machine learning, supporting day-to-day legal work such as case analysis, document and table review, drafting support, and more. 

The Ministry of Health and the Chief Sanitary Inspector, Dr Paweł Grzesiowski, have drafted a bill to amend the Food Safety and Nutrition Act and the State Sanitary Inspectorate Act (item no. UD247). The bill would introduce a number of changes, including significantly raising fines for violating food regulations.

Support from Poland’s National Recovery Plan under the A1.2.1 investment scheme was aimed as assisting micro, small and medium-sized businesses in the hotel, restaurant and catering industry in rebuilding after the difficult period of the pandemic. But when a map of the aid awarded under the scheme was published to showcase the scale of the programme’s success, it raised questions about whether the funding went to the places where it was most needed. This led to the launch of a sweeping review of the scheme—not random checks, but inspections of all beneficiaries. It’s no wonder that many businesses are considering now how to work through this process and protect their own interests.

On 4 August 2025 the Province Administrative Court in Waraw denied complaints filed by ecological organisations from Poland and Germany against the decision of the General Director for Environmental Protection concerning the environmental conditions for implementing the project for construction of the container terminal in the external port in Świnoujście. The judgment is not yet legally final.