Pre-financing of the National Recovery Fund for Poland is a fiction

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The Polish Development Fund could stop pre-financing investments from the NRRP later this month because of a lack of funds. The Polish Development Fund denies this information, but the Fund’s data shows the budget does not tally: it is short of at least PLN 2.5 bn

The Polish Development Fund claims it will spend a total of PLN 12 bn on ‘pre-financing the National Recovery and Resilience Plan’ by the end of the year. The Fund’s press office provided this information to on 11 September 2023.


Prime Minister Mateusz Morawiecki and Paweł Borys, president of the Polish Development Fund, have repeatedly said that the NRRP is being financed ‘according to plan’ despite the lack of EU funds.


Meanwhile, it arises from the information obtained by that the Polish Development Fund could stop pre-financing investments from the NRRP later this month because of a lack of funds.


‘Do not discuss the lack of funds’


A person working for one of the ministries responsible for the implementation of the NRRP (who wishes to remain anonymous) told that the Polish Development Fund announced it would stop financing investments from the NRRP in September because the current budget is exhausted.


This happened at a meeting held on 8 September 2023 between the representatives of the ministries implementing the NRRP and the coordinating ministry. That is the Ministry of Development Funds and Regional Policy (MDF&RP).


After the declaration of the Polish Development Fund, the ministry allegedly recommended ‘blocking payment instructions and slowing down the rate of signature of contracts’.


Furthermore, at a meeting on 13 September, the MDF&RP appealed to the ministries:

  • ‘not to discuss the lack of funds’
  • and ‘to maintain that the funds are being paid until after the elections’.


What is the Polish Development Fund and why is it paying out ‘pre-financing of the NRRP’


The Polish Development Fund is the only institution responsible for pre-financing the Polish NRRP in the part regarding the grants. According to the first version of the Polish National Reconstruction and Recovery Plan, Poland was to receive PLN 106.9 bn from it over 5 years.


That was the first, because the second is already being negotiated.


Less than a month ago, the Polish government, like other Member States, submitted a request to the EC to revise the NRRP, about which we wrote here. The revision is related to the launch of the REPowerEU programme. It envisages additional funding to increase the EU’s energy security because of the war in Ukraine.


The modified Polish NRRP amounts to almost €60 bn (compared to €34 bn from the first plan). This is over PLN 276 bn.


According to the new plan, the grant part is €25.26 bn, which is more than PLN 116 bn. The loan part is €34.5 bn, which is almost PLN 160 bn.


Disbursements from the Polish Development Fund – a way of handling the lack of funds from the EC


The Polish Development Fund is a non-budgetary entity, which is controlled by the State Treasury, but is not part of public finance. The minister of finance is not constitutionally responsible for it. So far, among other things, the Polish Development Fund was responsible for disbursing financial shields to businesses during the Covid-19 pandemic.


Since the funds from the Polish Development Fund are not flowing to Poland because of the failure to implement the milestones (or more precisely, the milestone that requires the Polish government to restore the independence of the courts), the Polish government has found a way of circumventing this problem: it has outsourced the payment of ‘pre-financing of the NRRP’ to the Polish Development Fund, which is an institution that does this ‘on credit’.


This is because the Polish Development Fund does not have any income at its disposal. The only funds that it receives are the refunds of grants that the Polish Development Fund paid to businesses during the pandemic.


It was then that the Polish Development Fund issued approximately PLN 70 bn of non-budget debt, from which the shields were paid, in order to implement the government’s programme of support for businesses. Part of this support was refundable, and it is these funds that are flowing into the Polish Development Fund’s coffers today. They funds are used to pre-finance investments from the NRRP, although – according to the original plans – they were to be used to pay for the redemption of at least some of the bonds issued by the fund.


Denial of the MDF&RP and the Polish Development Fund


The Ministry of Funds and Regional Policy, as well as the Polish Development Fund, deny that the Polish Development Fund will run out of money for pre-financing the NRRP by the end of the year.


The Polish Development Fund maintains that it has secured funding for the payment of pre-financing at the declared amount (PLN 12 billion).


The Polish Development Fund’s press office responded to that ‘it is not true that there is a slowdown in the processing of tenders, the signature of contracts and fulfilment of disbursement instructions under the NRRP’. It added that ‘the Polish Development Fund is pre-financing all investments reported on an ongoing basis and within the time limits, in accordance with the disbursement instructions submitted to the Polish Development Fund.’


Additionally, the Polish Development Fund’s press service states that ‘the funds for pre-financing the NRRP are currently coming from repayments of some of the support received by the beneficiaries of the Polish Development Fund Financial Shield programmes.’


In response to the question of whether it is true that it was said during a ministerial meeting in the first half of September that the Polish Development Fund does not have any more funding for pre-financing the NRRP up to the end of the year, the Fund stated that ‘there is no information that decisions were made at such meetings to limit the disbursements from the NRRP’.


This is a rather evasive response to a clearly phrased question.


The MDF&RP also denies this


The Ministry of Funds and Regional Policy – as the coordinator of the implementation of the NRRP – also denied that it was stated at the September meeting with the ministries responsible for the implementation of the NRRP that there is a shortage of funds in the Polish Development Fund for the disbursement of pre-financing.


However, the MDF&RP did not respond directly to the question of what funds the Polish Development Fund has up to the end of the year.


In response to the questions from, it wrote that ‘an update on the status of the launch of the NRRP was presented at the meeting held on 13 September 2023 between the MDF&RP and the ministries responsible for the implementation of the NRRP.’ Furthermore, ‘nothing was said at the meeting about a lack of funds in the Polish Development Fund for the disbursement of pre-financing.’


Meanwhile, as transpires from the financial data provided by the Polish Development Fund, with this level of pre-financing of the NRRP up to the end of the year, the Polish Development Fund’s budget will be short of cash for everything that the fund itself declares it intends to finance.


Morawiecki: ‘NRRP projects are being implemented’


Prime Minister Mateusz Morawiecki also makes the assurance that pre-financing of the NRRP is going according to plan.


It was just on 1 July 2023, during a Law and Justice (PiS) rally in Kościerzyna, in the Kashubia region, that Prime Minister Mateusz Morawiecki said that ‘NRRP projects are being implemented’ and that ‘some of this money [from the EU funds] is already flowing into Poland’.


A few days later, he repeated the same statement during a question-and-answer session in the social media.


‘We are implementing these projects in very many ministries; there is a recruitment of projects, of programmes. We aren’t waiting for this money, because it should come to Poland sooner or later, within the coming few months,’ reassures the prime minister.


Paweł Borys, president of the Polish Development Fund, also says that ‘the NRRP project financing programme is being implemented according to plan’ quite frequently in the media. He said exactly these words in an interview with the Polish Press Agency (PAP) on 7 September 2023.


Several days earlier, on 30 August 2023, the president of the Polish Development Fund also stated in PAP that ‘the Polish NRRP is accelerating despite the lack of funds from the EC’.


In an interview given to WNP on 14 September, Paweł Borys made the assurance that ‘we have already disbursed PLN 5 billion on investment projects within the framework of the NRRP in September. We expect that, by the end of the year, it will be at least PLN 10 billion’.


But ‘pre-financing of the NRRP’ with funding from the Polish Development Fund is problematic. And this is so for several reasons.


PLN 4 bn? A drop in the ocean

In the correspondence with, the Polish Development Fund states that the fund has disbursed less than PLN 4 billion on pre-financing of the NRRP so far. While, according to data from the MDF&RP, it was exactly PLN 3.917 bn.


Additionally, as the Polish Development Fund told us on 11 September, it plans to disburse PLN 12 bn on pre-financing of the NRRP this year.


The PLN 4 billion disbursed so far is a drop in the ocean compared to what was supposed to flow into Poland for the NRRP.


The National Recovery and Resilience Plan (NRRP) consists of 54 investment projects and 48 reforms. Poland was to receive PLN 158.5 bn, of which PLN 106.9 bn was to be in grants and PLN 51.6 bn in preferential loans. Under the revised NRRP – as we have already written – these amounts are even higher.


Given that the implementation of the National Recovery and Resilience Plan, and therefore both investments and reforms need to be settled by the end of August 2026 (including the spending of all funds – both from the grant and the loan parts), the rate of spending in Poland’s case should average at least PLN 30 bn a year.


And this is from 2022, when the Polish NRRP was approved.


Meanwhile, the last quarter of 2023 is approaching and, as the Ministry of Funds and Regional Policy admits, the counter is showing less than PLN 4 billion of pre-financed investments.


Simultaneously, the European Commission has already received 34 payment requests from 21 Member States.


A total of €153.4 bn has already been disbursed to the Member States, which is an average of €7.3 bn to each of them. Poland has received zero and this will probably not change for a long time. Especially since the United Right has announced that it will ‘continue its judicial reforms’ if it wins the elections. And this can mean only one thing: the further dismantling of the independence of the judiciary and no EU funds for Poland.

Changing declarations


The next issue is that the Polish Development Fund changes its declarations every now and again as to the planned level of funding for the NRRP. As recently as in February 2023, citing information from the Polish Development Fund’s press office, Rzeczpospolita reported that the Polish Development Fund is due to allocate PLN 15–20 bn to the pre-financing of the NRRP this year.


The president of the Polish Development Fund said the same in March 2023 in an interview with


In May, during the first meeting of the NRRP implementation monitoring committee, the Ministry of Funds and Regional Policy declared that the Polish Development Fund has PLN 19 billion for pre-financing the NRRP. Monitoring Committee Member Kamil Sobolewski, chief economist of the Employers of Poland organization, who attended the meeting, posted this information on Twitter.


In September 2023, in response to a question from, the Polish Development Fund declares that it will allocate approximately PLN 12 bn to the pre-financing of the NRRP this year.


Meanwhile, as arises from the financial data which the Polish Development Fund and the Ministry of Funds and Regional Policy provided to, the disbursement of such an amount on the pre-financing of the NRRP could be problematic because of the fund’s other financial obligations.


The Polish Development Fund will have a shortfall of at least PLN 2.5 bn


Let’s do the calculations.


The Polish Development Fund declares it will disburse approximately PLN 12 bn on the pre-financing of the NRRP this year. These funds are to come from the refund of subsidies to businesses paid during the pandemic.


We therefore asked the Polish Development Fund exactly how much of the subsidy funds have already been received and how much is still expected to be refunded by the end of the year.


The Polish Development Fund informed us that ‘the Polish Development Fund started to receive the first repayments of the non-cancelled parts of the subsidies in July 2021. A total of PLN 24.346 bn has been received from all Financial Shields. According to the repayment schedules, a total of PLN 2.643 bn more will have been received from all Shields by the end of this year.’


Therefore, it appears that the Polish Development Fund will have a total of almost PLN 27 billion (precisely PLN 26.989 bn) from the repayments of the Shields by the end of the year.


It would seem that the allocation of PLN 12 bn from this to pre-finance the NRRP will not be a problem. However, there is one ‘but’.


The Polish Development Fund also needs to have funds for redeeming bonds and interest


The Polish Development Fund’s main financial obligation is not the disbursement of the pre-financing for the NRRP, but the redemption of the bonds issued by Polish Development Fund during the pandemic period and the payment of interest to the investors who bought them.


The Polish Development Fund made a total of 11 rounds of bond issues in 2021 and 2022 for approximately PLN 70 bn. These are all guaranteed by the State Treasury, so, if the Polish Development Fund becomes insolvent, the State Treasury becomes liable for the repayment of these liabilities.


A full list of the bonds issued by the fund, together with information on their maturity and issue value, can be found here.


The first of these are due to be redeemed – for over PLN 16 bn (precisely PLN 16.325 bn) – in March 2024.


In the correspondence with, the Polish Development Fund claims it ‘has secured funds’ for the redemption of these bonds.


Furthermore, this year alone, the Polish Development Fund has already partially paid, and will pay a total of PLN 1.16 bn in interest on the bonds it has issued.


If account is taken of the fact that, according to its own declarations, the Polish Development Fund has PLN 27 bn at its disposal, there will be a shortfall of around PLN 2.5 bn for everything that the Polish Development Fund declares it intends to finance.


Therefore, we asked the Polish Development Fund and the Ministry of Finance whether the Polish Development Fund is planning another round of bond issues. We have not received an answer to that question.


PiS will leave a time bomb for the next government asked two economists to comment on such a method of pre-financing the NRRP.


Dr Sławomir Dudek, president and chief economist of the Institute of Public Finance and member of the authorities of the Society of Polish Economists, points out that the financing of EU programmes by institutions such as the Polish Development Fund is highly non-transparent.


‘The Polish Development Fund is not a budget unit, it is not a ministry, it is not subject to the Public Finance Act. In fact, we only know how much the Polish Development Fund has spent on anything from their declarations. We do not have access to public reports telling us what it looks like,’ the economist notes.


Besides, the disbursement of investment funds from the NRRP by the Polish Development Fund is not pre-financing in the meaning of the disbursement of EU funds.


‘Pre-financing of investments for the NRRP’ would normally be financed by advances paid by the European Commission. However, Poland has not received such advances because it did not meet the deadline for approval of the NRRP. In order for a Member State to receive them, the National Recovery and Resilience Plan needed to be approved by December 2021. The Polish plan was approved as late as in June 2022, because of extended negotiations with the EC.


Pre-financing of the NRRP bypassing the European funds budget 

Under normal circumstances, EU programmes should also be pre-financed through the European funds budget. This ‘pre-financing of the NRRP’ does not go through the European funds budget at all.


Furthermore, if the Polish Development Fund disburses funds from the refund of subsidies from businesses to pre-finance the NRRP and Poland ultimately does not receive the funds from the EC, then the Polish Development Fund’s financial obligations related to the need to redeem the bonds will be transferred to the State Treasury.


The first bonds mature next year. The Polish Development Fund claims it has the funds for this.

  • However, more than PLN 30 bn of pandemic debt is to be repaid from the Polish Development Fund (precisely PLN 33.675 bn) in 2025,
  • and a further PLN 10 billion in 2027.


The next government will need to set aside these funds in its budget.


The Polish Development Fund’s debt is also only part of the whole of the off-budget debt generated by the PiS government. It currently amounts to PLN 300-400 bn.

Therefore, as Dr Dudek notes, the financing of state tasks by institutions such as the Polish Development Fund is controversial, because

  • it generates non-budget debt, which is not subject to constitutional limits;
  • and it is an unnecessary burden on taxpayers: such debt is much more expensive than financing directly with State Treasury debt. The liquidity risk is higher, the Polish Development Fund is a smaller entity, etc.


‘This financial vehicle created by the government to circumvent budget limits is costing the taxpayer an additional PLN 12 bn,’ Slawomir Dudek tells


The disbursement of funds without monitoring?


Kamil Sobolewski, chief economist of the Employers of the Republic of Poland, also has reservations about the way the pre-financing of the NRRP is being implemented. Sobolewski is a member of the NRRP Implementation Monitoring Committee, which is a body consisting of both representatives of ministries responsible for the implementation of the NRRP and representatives of the public: employers’ organizations, industry associations of entrepreneurs, etc. – anyone who is interested in the implementation of the NRRP in Poland (the full list of members of the Monitoring Committee can be found here).


The appointment of a Monitoring Committee was a requirement of each country under the National Recovery and Resilience Plan. The Committee is supposed to monitor, among other things, whether the reforms, measures and investments contained in the NRRP are being implemented in accordance with the programme’s objectives. And therefore, for example, without conflicts of interest or discrimination, and in accordance with the principles of equality.


In an interview with, Kamil Sobolewski points out that


the first funds for NRRP investments were disbursed even before the Monitoring Committee was constituted.


And indeed: the first meeting of the Monitoring Committee was held in May 2023. And, as transpires from the Polish Development Fund’s information, the first funds for pre-financing the NRRP were already disbursed in November 2022.


On the day of the Monitoring Committee’s meeting, Sobolewski posted the information he received on Twitter (here and here).


The economist of the Employers of Poland also points out that only one meeting of the Monitoring Committee has been held so far. And this despite many questions and ambiguities raised at the first meeting.


And the most fundamental issue: with such a level of financing that the Polish Development Fund is able to provide, the NRRP is a missed opportunity.


‘Investments from the NRRP are necessary to build the capacity of the economy. Many entrepreneurs operating in Poland will not be able to take advantage of funds from the NRRP because there will be insufficient time for that. Every day of delay [in Poland’s receipt of NRRP funding] is a lost opportunity and unequal conditions of competition for companies operating in Poland with respect to entities from other countries operating within the common market,’ emphasizes the expert.


Translated by Roman Wojtasz 

Author journalist



September 30, 2023


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