PFR control of the ways in which subsidies are spent – what the entrepreneur’s bill of conscience should take into account

9 July 2025 • Autor: Kancelaria Brysiewicz Bokina i Wspólnicy

The first inspections of companies using the Polish Development Fund’s Financial Shield are about to begin. Which entrepreneur will be inspected will be decided by algorithms specially designed for this purpose. Those entrepreneurs who have received aid despite failing to meet the conditions for granting it should expect special consequences. These consequences manifest themselves not only in the obligation to repay the aid, but also in criminal liability, which may be incurred by the managers of the beneficiaries for so-called subsidy fraud. It is therefore worth making an honest examination of conscience right now. In the pages of Prawo.pl, attorney Krzysztof Brysiewicz draws attention to the various aspects of preparing a company for an audit.


Checks on the spending of funds provided by the PFR under the Financial Shield can cover various areas of a company’s operations, and in addition to instruments such as tax and Social Security records, they can also consist of on-site inspections or verification of companies’ internal records, including bank account histories.

The subsidy agreement generally stipulates that the subsidy should be used to cover the costs of the business.

It can be expected that the actual status of enterprises will be subject to meticulous scrutiny given that its examination in providing support was not conducted on the basis of automated algorithms and verified on the basis of data from KAS and ZUS - unlike, for example, the decline in the level of revenue or the number of employees.

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