Annex B. Progress against OECD legal instruments under the responsibility of the DAC

The average grant element of Polish ODA commitments was 99.1% in 2020 and 99.0% in 2021. This exceeds the norm of 86%, and therefore meets the requirements of Paragraph 2 of the Recommendation on the Terms and Conditions of Aid. Poland’s preliminary ODA as a share of GNI also surpassed the DAC average country effort of 0.38% for the first time in 2022 (preliminary figures). This meets the requirements of Paragraph 3 of the Recommendation.

In 2021, Poland also met for the first time the commitment on the special terms for least developed countries (LDCs) (Paragraph 8), exceeding the 90% norm. The grant element of bilateral ODA commitments to LDCs reached 98.71% in 2021, compared to 86.89% in 2020. If this trend persists for 2022 and beyond, Poland will be on track to meet the alternative norm of maintaining a three-year average of grant element of bilateral ODA to LDCs beyond 86%.

Poland is not yet aligning with the DAC Recommendation on Untying Official Development Assistance. The share of de jure untied ODA provided to countries covered by the Recommendation stood at just 7.5% in 2021, compared to 24% in 2020 (OECD, 2022[1]).

Poland awarded more than 80% of contracts (in terms of value) to domestic entities, largely domestic CSOs.

Regarding adherence to the transparency provision of the Recommendation, Poland consistently reports to the DAC Secretariat on its ex post contract awards. Poland usually does not have any contracts above the Special Drawing Rights 700 000 ex ante notification threshold.

Poland is transitioning to a modernised crisis response system that would more systematically adopt the Humanitarian, Development and Peace (HDP) Nexus approach. Poland has two very distinct responses to crises and crisis risks. In Poland’s neighbourhood, the HDP nexus approach is well articulated because Poland’s development co-operation has a clear political objective of supporting democracy and preventing crisis. In this geography, peace is the objective to which development co-operation is mobilised, historically through the Solidarity Fund. This is a rare case of a DAC member adopting an HDP nexus approach by design.

In other geographical areas, peace, development and humanitarian assistance are more disjointed. The aggregation of separate projects across humanitarian, development or peace sectors does not reflect an intentionally designed HDP nexus approach, in which each individual engagement is relevant. In Lebanon, for example, there is no strategic link between Poland’s participation in the United Nations Interim Force in Lebanon (UNIFIL) with 192 troops (UN, 2023[2]) and its different infrastructure or humanitarian operations in other parts of the country.

The DAC Recommendation is built on the premises of prevention always, development wherever possible and humanitarian assistance only when necessary. Most of Poland’s priority or additional countries are fragile but not in conflict. Several of them face particular governance issues or crises. Poland can build on its expertise in democratisation, governance and crisis prevention to support both government and civil societies, ensuring that society is an integral part of all structural change and reforms.

Beyond its strategic aspect, building an HDP nexus response to crises and crisis risks entails operational and financial flexibility. Supporting local civil society requires significant decision-making power at embassy level. In addition, Poland’s funding processes continue to be constrained. The calls for proposal modality and annual programming prevent Poland from building the long-term partnerships that are required to reach long-term development and support governance objectives.

Thanks to Poland’s experience in mobilising its ODA toward a clear political objective, there is scope for building a more comprehensive system to respond to crises risks and autocratisation.

Regarding the development of policies and professional conduct standards (Pillar 1), Poland’s Solidarity Fund has developed a code of conduct to prevent discrimination and harassment (Solidarity Fund, 2021[3]). The MFA has not yet developed a similar code of conduct.

Poland has classified sexual exploitation and abuse and sexual harassment as crimes under Polish labour laws, applicable to those working in government. Poland could develop specific guidelines on how this applies in a development and humanitarian assistance context, including when working with external partners.

Regarding the development of a victim/survivor-centred response (Pillar 2), Poland states that it has taken initial steps towards adopting a more victim/survivor-centred approach, but how these efforts apply in practice remains unclear. Poland needs to accelerate progress on specific measures, including dedicated services and co-ordinated support to sexual exploitation, abuse and harassment victim/survivors, and addressing the underlying causes of violence. Integrating SEAH in regular staff training and risk assessments to underpin a stronger environment of prevention would support implementation of the Recommendation.

Regarding training and awareness raising (Pillar 4), Poland has translated the DAC Recommendation into Polish. However, this is awaiting approval for publication on the MFA’s website and is therefore not yet public (MFA, 2023[4]). Poland has taken steps to disseminate the DAC Recommendation with civil society partners and local authorities, which is to be further encouraged.

Regarding international co-ordination for preventing SEAH (Pillar 5), Poland will need to continue collaborating with international stakeholders – including through the DAC Reference Group on Ending SEAH – to ensure progress against implementation of the DAC Recommendation. Poland has committed to co-operate closely with other DAC members on the Recommendation (MFA, 2023[4]). Clarifying Poland’s priorities for this engagement and communicating on these can help to deliver on this commitment.

Regarding respecting, protecting and promoting civic space (Pillar 1), Poland aims to promote civic space in Eastern Partnership countries. In its four Eastern Partnership priority partner countries, Polish Aid is committed to “building civil society, including efforts to ensure flexible, inclusive, participatory and representative decision-making at all levels of government” (MFA, 2021[5]). To this end, Poland has translated the DAC Recommendation into Polish and published it on line (Government of Poland, 2022[6]).1 Poland also intends to engage in dialogue with partner country governments through the preparation of partner country strategies (MFA, 2023[4]). There is no evidence of co-ordination or exchange of information with other providers or international, regional or national bodies to monitor the evolution and state of civic space in partner countries. In Moldova, Polish Aid implemented through Polish CSOs is not systematically recorded in the partner government’s ODA management systems, complicating oversight and accountability.

Regarding supporting and engaging with civil society (Pillar 2), Poland considers CSOs to be key implementing partners of Polish Aid. Excluding funding to the Solidarity Fund, which Poland considers as a CSO in its ODA reporting to the OECD, the share of total bilateral ODA funding to and through CSOs averaged 7.9% over the period 2017-21 (OECD, 2023[7]). This contrasts with the OECD-DAC average of 14.7% over the same period. To date, Poland does not provide core support to CSOs. As there are legal and regulatory constraints for Poland to provide financial support to non-Polish CSOs within partner countries Polish CSOs are required to partner with local institutions and organisations as a means to strengthen civil society in partner countries.

In line with the DAC Recommendation (Pillar 2, Provisions 3 and 4.a and Pillar 3, Provisions 3 and 4), Poland is encouraged to provide financial support to more diverse civil society actors, including those in partner countries; increase the availability of direct, flexible and predictable support, including core support and/or programme-based support to CSOs; work with CSOs to implement mutual capacity building to address CSOs’ vulnerabilities; and support more equitable partnerships between provider country and/or international CSOs and partner country CSOs they work with.

Poland’s policy documents commit to policy coherence for sustainable development at the national government level. The MFA is mandated to co-ordinate government activities to consider the possible spill over or transboundary effects of policies and regulations on other countries, including developing countries, while the Ministry of Economic Development and Technology is responsible for the national implementation of the SDGs (Government of Poland, 2021[8]).

Poland has identified five priority policy coherence issues and has listed them in its development co-operation policy documents. As of 2023, they are: illicit financial flows in the areas of fighting tax evasion and money laundering; combatting illegal trade in endangered plant and animal species; implementation of corporate social responsibility standards; sustainable cities and communities; and climate, including the natural environment and the seas.

Activities in these priority areas should be implemented by the relevant line ministry as a lead institution, in co-operation with the MFA and in consultation with other ministries. Priority issues are set out in Poland’s multiannual programme and updated from time to time in annual plans. Co-ordination between line ministries and the MFA on these issues appears to be on an ad hoc basis. The government is expected to present progress on each priority area to the Policy Council on an annual basis (Government of Poland, 2021[8]). As Policy Council discussions and the progress reports are not made public, it is unclear whether this does indeed take place and the extent to which this helps Poland resolve policy trade-offs in practice. Institutional responsibilities for following up on priorities need to be clarified.

Regulatory impact assessments are required for all laws and regulations, enabling the Ministry of Economy and Development to monitor the implementation of the SDGs and look at the impact of regulations beyond individual ministerial silos. They do not yet consider the transboundary impacts of Polish laws and regulations on other countries’ development aspirations despite a commitment during the last peer review to include this.

Poland relies on mandatory anti-corruption e-learning courses as one of its main tools to manage corruption risks in its development and humanitarian assistance operations. These are linked to codes of conduct, guidance on asset declarations, and whistleblower and reporting mechanisms. There is scope to develop these further, in particular with regard to their application to and use by external partners. Further, it appears that the Polish development co-operation system recorded no reports of allegations of corruption or intentional misuse of resources in recent years. This near absence of corruption reports questions the efficiency of the corruption risk management system. Evidence from other donor countries highlights the fact that no reported allegations or incidents of corruption raises concerns on the effectiveness of detection and reporting mechanisms. Looking into the disincentives to report suspicions of corruption, with a view to better tackling them, could improve the risk management system.

The Recommendation calls for an active and systematic assessment and management of corruption risks. The extent and frequency with which Poland assesses corruption risks is unclear – as are risks that extend beyond the fiduciary dimension (e.g. conflicts of interest, nepotism, reputational risks, etc.). Enhanced and systematic coverage of these risks would likely help enhance the effectiveness and integrity of Polish ODA.

Recent annual plans specify that all projects need to be preceded by an analysis of their compliance with cross-cutting priorities, including that a project does not harm the environment (MFA, 2022[9]; 2021[5]). Not all projects are analysed for their potential impact on climate and the environment. Guidelines associated with the 2023 call for proposals include some additional guidance for partners on how Poland expects climate and the environment to be considered in project design. The degree to which these support more effective mainstreaming remains to be seen, and monitoring reports suggest limited understanding by staff and partners of how to integrate climate and environment considerations into project design. Another barrier appears to be the lack of general consent that cross-cutting priorities need reinforced as well as a lack of specific expertise within the MFA. Poland could make greater use of the DAC Secretariat and the statistical peer review mechanisms to improve the screening and use of the Rio Markers.

With respect to investments of commercial clients financed by BGK, a requirement has been implemented to screen and verify the potential impact on the climate and environment, both from the perspective of the financed transaction itself and the existing business activity of the business partner. The verification procedure takes place as part of the broadly understood ESG risk management system.At a national level, Poland has set goals for improving efforts to protect the environment and tackle climate change and has undertaken carbon neutrality commitments under the United Nations Framework Convention on Climate Change (UNFCCC). However, the rule of climate neutrality for projects has not yet been adopted as a binding principle for Polish Aid. Climate, including the environment and the seas, is among Poland’s priority policy coherence for development issues (as of 2023).

Polish Aid recognises climate as a priority aspect of development in line with international agreements, including the Paris Agreement on Climate Change and the Convention on Biological Diversity. According to the 2021-2030 Multiannual Programme, climate is both a cross-cutting and a priority area of Polish development assistance, with the current programme adding forests and biodiversity and renewable energy to Polish Aid’s priority themes. Climate is also one of Poland’s Policy Coherence for Development priority areas. Poland has undertaken carbon neutrality commitments under the UNFCCC but has not yet adopted the rule of climate neutrality for projects as a binding principle for Polish ODA (MFA, 2023[4]).

The current Multiannual Programme (2021-2030) commits Polish development co-operation to not harm the environment; perceive climate change as a risk to achieving the SGDs; strive to reduce greenhouse gas emissions relating to project activities; support the effective functioning of the economy and society in a changing climate; contribute to capacity building for using renewable energy sources as well as adapting to climate change and mitigating its effects; and promote sustainable management of natural resources, protection of biodiversity and ecosystems.

Measures to achieve Poland’s commitments are primarily carried out through the “Polish Development Assistance” annual calls for proposals. In practice, Poland’s ODA programming does not reflect the importance Poland places on climate both as a priority area and a cross-cutting topic. In 2020-21, Poland committed just 4.4% of its total bilateral allocable aid (USD 6.2 million) in support of the environment and the Rio Conventions (compared to the DAC average of 34.3%), down from 27.7% in 2018-19 (OECD, 2023[10]).

The MFA is working on developing tools to better integrate climate into Polish Aid projects. A series of questions for potential implementing partners has been added to project grant forms, encouraging partners to include climate considerations into project planning. Questions include whether a project includes environmental awareness building and/or communication as part of its activities, and whether the project aims to increase the capacity of local communities to adapt to the effects of climate change.


[6] Government of Poland (2022), “Recommendations of the OECD Development Assistance Committee on the inclusion of civil society in development cooperation and humanitarian aid”, press release,

[8] Government of Poland (2021), The Multiannual Programme for Development Cooperation for 2021-2030: Solidarity for Development, Annex to Resolution No. 11/2021 of the Council of Ministers, January 19, 2021, Government of Poland,

[4] MFA (2023), “Poland OECD-DAC Peer Review Self-Assessment”, Government of Poland,

[9] MFA (2022), 2023 Development Cooperation Plan, Government of Poland, Warsaw,

[5] MFA (2021), 2022 Development Cooperation Plan 2022, Government of Poland,

[7] OECD (2023), OECD International Development Statistics, OECD Publishing, Paris,

[10] OECD (2023), “Poland”, in Development Co-operation Profiles, OECD Publishing, Paris,

[1] OECD (2022), 2022 Report on the Implementation of the DAC Recommendation on Untying Official Development Assistance, OECD, Paris,

[3] Solidarity Fund (2021), Code of Conduct: To Prevent Discrimination and Harassment, Including Sexual Harassment, at Solidarity Fund PL, Solidarity Fund,

[2] UN (2023), Troop and Police Contributors (database),

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