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Already at the beginning of May, European Commission President Ursula von der Leyen confirmed that Poland had submitted its National Recovery Plan to Brussels. However, according to unofficial information from our sources within the EU institutions, the Polish government has also asked the Commission to postpone the plan’s final assessment by four weeks, so that it would have enough time to still work out the changes during preliminary consultations. This means that the process of assessing the National Recovery Plan will not start before June, as the Commission has two months to complete it. In practice, we can expect the final assessment and approval of the Polish plan to be announced sometime in July.

The draft Recovery Plan was developed over many weeks in consultations between Warsaw and Brussels, and Valdis Dombrovskis, vice-president of the European Commission, briefly reported on the status of the talks already at the Commission's meeting on March 24.

Thus, there was no particular pressure from Brussels to formally submit the draft plan at the beginning of May. As one of our sources tells us, it is possible that the hurry was a result of Poland’s intra-governmental political games around the parliamentary vote on the ratification of the EU “own resources” agreement. It is urgently needed to start the Recovery and Resilience Fund and, much less urgently, the Union’s 2021-27 budget.

Not enough information about the Special Monitoring Committee

- The European Commission will review the controls and audit system in the Polish Recovery Plan- says one of our informants in Brussels.

The aim is to strengthen the principle of non-discrimination and ensure that the requested EU funds are distributed fairly and used for their intended purpose. In other words, the aim is to prevent the distribution of EU money according to political sympathies- a scenario that the Polish opposition is particularly afraid of.

Admittedly, the draft plan submitted to the Commission indeed contains provisions on a Special Monitoring Committee- a body consisting of "representatives of institutions involved in the implementation of the National Recovery Plan", i.e. trade unions, employers, and representatives of local governments. Moreover, the plan also mentions that "the funds will be distributed in accordance with all the rules ensuring non-discrimination of all potential recipients, and the selection of beneficiaries will be based on objective criteria". But the exact details on how this Special Monitoring Committee is supposed to operate are yet to be determined, which naturally generates distrust.

Brussels is therefore expecting more binding specifics written into the Polish plan on how the pay-outs will be monitored and how the implementation of goals outlined in the EU Recovery Fund is to be verified. This, then, will be "translated" by the Commission into law in a draft "implementing decision" issued by the EU Council. As a result, the approved rules guiding the works of the Monitoring Committee will not be subject to arbitrary changes later on, at least not without breaking the legally binding arrangements within the EU. Crucially, Poland’s compliance with these rules will determine whether it receives further installments of the EU funds it has requested.

A list of questions regarding the Polish Recovery Plan

As a part of the "preliminary consultations" with the Polish government, European Commission experts are now finalizing the first tranche of questions and comments regarding the Polish Recovery Plan. The list - as one of our sources in Brussels explains - shows that "different parts of the draft plan, distributed among different directorates in the Commission, are being assessed very thoroughly".

One of the EU experts claims that the Polish plan “is not badly written". A Commission official says that the plan sticks to the general objectives of the Recovery Fund in terms of climate policy or digitization. On the other hand, it is possible that the Commission will urge Poland to put more emphasis on loans within the National Recovery Plan projects framework, although this point has already caused controversy among Polish local government officials.

- The evaluation of national recovery plans will take into account much more than simply ticking off the objectives. There is no single answer to the question of whether the plan "contributes to solving a significant part of the challenges" of the country-specific recommendations. Different experts across the Commission will weigh up the merits of each of the measures put forward by member states, including the control and audit system- the EU Economic Affairs Commissioner Paolo Gentiloni said during an EU Parliament debate on the Recovery Fund.

MEPs will also give their opinions on the national recovery plans, but without legal effect and only in consultation with the European Commission and the EU Council. However, MEPs are already demanding (although unsuccessfully) that the Commission provide them with documents with its preliminary assessments of individual countries' recovery plans.

The Polish plan consists of EUR 23.9 billion in grants and EUR 12.1 billion in loans, i.e. slightly more than a third of the low-cost loans foreseen by the EU Recovery Fund. But by 2023, Warsaw may also ask for the remaining funds. After receiving a green light from the European Commission, the National Recovery Plan must then be approved by EU finance (or economy) ministers in the EU Council by a majority of at least 15 member states representing at least 65% of the EU population.

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