Audit no. P/25/076/LPO
Financing most educational and cultural initiatives audited by NIK violated the requirement of proper, economic, efficacious and reliable management of public funds. The Institute President, contrary to the Act on IPN, established new organisational units focusing mainly on education. Over PLN 50 million was earmarked for their activity. In view of the above nearly PLN 5 million of public funds was inefficaciously spent on salaries of the units’ managers.
Nearly PLN 15 million was spent in an inefficacious and wasteful manner on educational and cultural activities and on current operation of the Institute. When commissioning services and deliveries for the total of PLN 13 million, provisions of the Public Procurement Act or internal regulations were infringed. IPN not always verified the adequacy of awarding contracts for services and deliveries in terms of compliance with the principles of estimating the contract value, maintaining impartiality, objectivity and fair competition rules when selecting contractors. The irregularities found in the area of contracts for services and deliveries indicate that the management control at IPN was not adequate, effective or efficient.
The Institute of National Remembrance – Commission for the Prosecution of Crimes against the Polish Nation is a state organisational unit established under the Act on IPN. The Institute has been allocated mainly the following functions: archiving, investigation, vetting, research and education, searching. The tasks have been carried out by the IPN Headquarters in Warsaw and 11 branches (plus 7 sub-branches), representing organisationally and financially isolated units.
The operation of IPN is financed from the state budget and is related to the management of the State Treasury property. This type of management should be carried out with utmost diligence.
In 2020-2024, there was a dynamic increase in the budget for the functioning of the Institute of National Remembrance – from PLN 396 million in 2020 to over PLN 584 million in 2024 (i.e. by 47%). It should be noted that in 2023 alone, the budget expanded by over PLN 100 million compared to the previous year. In 2022-2024, a total of over PLN 1.5 billion was spent on the Institute's statutory tasks – over PLN 882 million (i.e. 57%) was earmarked for salaries and salary derivatives, almost PLN 450 million for other current expenditures and nearly PLN 155 million for capital expenditures.
Illegal changes of the organisational structure of IPN
In 2021-2025, the IPN President changed the charter and established six additional offices at the IPN Headquarters, performing mainly educational tasks. He thus changed the organisational structure in a way contrary to the Act, which said that the list of organisational units may not be modified through the charter instituted by the President but only through an amendment to the Act. The President’s action was illegal, then. At the same time, the total of PLN 4.8 million was spent on salaries of directors and deputy directors of the newly created offices. They were not hired under the act of appointment referred to in the Act on IPN, though, but as part of an employment agreement. Establishing new offices and appointing their directors against the Act on IPN resulted in spending public funds on their salaries in violation of the principle of public spending efficacy.
Overseas branch of IPN – it absorbed nearly PLN 400 thousand, although it has not been established
The IPN Headquarters took efforts to open a permanent IPN office in Washington as a support centre for the Polish historic politics in North America. In 2022-2025 (first quarter), PLN 397 thousand was spent on activities aimed at the office opening. Although that IPN branch was not provided for in the Institute’s organisational structure under the Act on IPN, its opening was scheduled for the second half of 2024 and the expenditures planned for this purpose were to reach PLN 4.5 million. Eventually, as the IPN Director General explained, the project was not completed due to the political and economic situation and a depletion of the planned budget. As a consequence, the financing of those activities violated the principles of managing public funds.
Most money spent on education
Educational activities, most of which were carried out by the newly created offices, absorbed a significant part (nearly 60%) of the Institute’s current expenditures (except for salaries and derivatives) earmarked for IPN’s statutory tasks. In 2021-2024, that was over PLN 83 million.
Establishing new offices at the IPN Headquarters gave rise to new types of educational initiatives (e.g. multimedia exhibitions, production of computer games and VR products, organisations of concerts, performances, etc.).
In 2022-2025 (first quarter), the IPN Headquarters, as part of the operation of the newly established Cultural Events Office, organised 223 educational and cultural events which cost PLN 14.6 million in total.
Continuing promotion of an educational computer game - ineffective and inefficacious
As part of its educational activity IPN developed an educational computer game called the „Cyphers Game” aimed to reach young people with a historic message. The cost of this project exceeded PLN 1.2 million and its promotion cost nearly four times more – over PLN 4.7 million. It involved, among other things, participation of IPN employees in domestic and international gaming trade fairs (e.g. in Germany, Thailand, USA) and numerous events at which the game was advertised in the social media.
Despite costly and long-term promotion, the game’s popularity was falling systematically. In two first months from making the game available, it was downloaded nearly 25 thousand times, whereas in three following years it was less than 3 thousand downloads (drop by 760%). The declining effectiveness of diverse promotion activities did not translate into less public funds spent to promote the game. In 2022, the “Ciphers Game” became part of the minister’s programme “Games in education” which – according to the IPN Council – helped in reaching 100% of students’ population with the game. The expensive promotion of the game was continued, though, which was inefficacious and wasteful.
Buying avatars of historic persons without full required functionality
Following the decision of the IPN Headquarters, nearly PLN 3.5 million was spent on creating a digital counterpart of historic persons, the so-called avatars. That was to be a high-tech, interactive product using AI and the deep learning method.
The purchased product did not comply with some of the specification requirements set out in the agreement with the contractor. It means that this expensive technology did not have full required functionality and would not be optimally used in the Institute’s activity, anyway.
Other cases of unjustified and wasteful spending
At the IPN Branch in Gdańsk, over PLN 1.7 million was spent against the principle of rational management of public funds, to organise the Pomeranian Congress of National Remembrance. Before taking the decision to incur those expenditures, no documented verification was made of the efficacy of organising initiatives as part of that Congress or the rationale for spending funds for that purpose.
At the IPN Headquarters public funds of PLN 1.2 million were spent in a wasteful and inefficacious manner to produce a miniseries about Grażyna Lipińska, a Polish female soldier during the Second World War. The miniseries was not used for educational purposes by the end of the NIK audit, although 2.5 years passed from its reception from the executive producer.
At the IPN Headquarters nearly PLN 1 million was spent inefficaciously on special handling of one of new organisational units, i.e. the New Technology Division.
Artificial splitting of public procurement contracts
The total value of contracts awarded as a result of contract splitting exceeded PLN 2.2 million. For instance, at the IPN Headquarters and at the Wrocław Branch three contracts were illegally split into 24 separate services or deliveries to circumvent provisions of the Public Procurement Law. The value of those contracts was PLN 1.2 million. Splitting contracts to circumvent provisions of the Public Procurement Law when selecting contractors represented a violation of the Act and did not ensure compliance with the principle of economic spending of public funds.
In 2024, at the IPN Headquarters one entity was awarded four contracts (each under a separate project) totalling nearly PLN 150 thousand. Also in 2024, a contract for PLN 123 thousand was awarded to the same contractor at the IPN Branch in Warsaw, commissioning publication of an article written by the IPN President. The funds to finance that contract were transferred from the IPN Headquarters, though, which also indicated the entity that should be awarded that contract.
Irregularities in awarding below-threshold contracts
The principles of awarding contracts worth not more than PLN 130 thousand, in line with the regulation of the IPN President, fostered arbitrariness in selecting contractors. In all five audited entities, as for 109 contracts for over PLN 4.8 million, the minimum of three offers was not obtained or the contractor selection was not justified. At IPN Headquarters and three IPN branches, contracts were awarded in violation of the principle of impartiality, objectivity and fair competition. That was related to apparent market research and sending offer inquiries to entities linked in professional or private terms with the offices’ directors at the IPN Headquarters or indicated by them. Such conduct undeniably infringed the principles of fair competition and equal treatment of contractors.
The total value of contracts awarded in violation of the principle of impartiality, objectivity and fair competition reached nearly PLN 5.8 million.
The violations involved among others apparent market research, e.g. by sending inquiries to the foundations whose members of their representative bodies were linked to one another by their functions which they fulfilled in other entities participating in these proceedings. That violated the principle of fair competition and equal treatment of contractors and questioned legitimacy of such market research.
Uneconomic rent of premises
In 2022–2024, the Institute took measures to acquire properties, ensure office space for statutory purposes and improve technical condition of the buildings. Not always, though, did they help gain optimal space, adequate to the headcount level and performed tasks. In three cases of office space rent the principles of economic management of public funds were not observed. As a consequence, PLN 1.7 million was spent in a wasteful manner. That applied among others to a building under permanent management of the IPN Headquarters for the needs of the IPN Branch in Wrocław. The property was in a poor technical condition and needed reconstruction. However, only after three years, investment activities were taken to bring the facility to a state enabling its use. At that time, the Wrocław Branch rented office and warehouse space which cost PLN 5.4 million by the end of March 2025 due to rent and service fee.
Inefficient property management for the needs of publishing
Another irregularity concerned the expansion of the warehouse hall originally intended for publishing purposes. Since the concept of operation of the IPN Publishing House was changed, the IPN hall was designed only for temporary storage e.g. of elements of exhibitions and board games. The costs of the hall expansion reached PLN 3.4 million. The ineffective use of the hall revealed uneconomic nature of this spending.
Unreliable supervision over the use of software
The IPN Headquarters did not exercise sufficient supervision over the access to telecommunications and IT systems. More than half of IPN former employees had their rights and access to computer systems disabled many months after the employment termination (up to three years), or not at all. That was related to a risk of losing data, unauthorised access to personal data or generating redundant costs to keep the licence/ access for persons who are not employees. Also the installed software was not effectively monitored on an on-going basis and hence, in some cases, software from sources considered as dangerous was installed.
At the same time, the way of managing the software not always allowed for its effective use. It was implemented with a significant delay or the purchased per seat licences were not used in a full scope. As a result, unnecessary costs of over PLN 392 thousand were incurred. At the IPN Headquarters for nearly two years 57% of office software licences worth over PLN 106 thousand were not installed. That wastefulness was explained with the need to provide the so-called licence buffer because of staff turnover and planned replacement of the office software.
Adequate subsidising by IPN Headquarters
Only one of significant issues covered by the audit was evaluated positively, i.e. granting and settling subsidies. The targeted subsidies covered by the audit, granted by the IPN Headquarters, totalling PLN 14 million were earmarked for:
- financing the costs of implementing the investment for the Museum of Cursed Soldiers and Political Prisoners of the People's Republic of Poland (PLN 13.6 million);
- covering the costs of caring for the grave of a veteran of the struggles for Polish independence for six entities (PLN 0.4 million).
The funds were used as intended and transferred within the deadlines enabling timely implementation of these tasks. Each time, the Institute of National Remembrance verified the correctness of the submitted settlements, which allowed for reliable assessment of the achieved effects and the manner of using the funds for the given task.
Recommendations
In view of the audit results NIK has made the following recommendations:
To the President of the Council of Ministers to:
- take a legislative initiative to change the Act on IPN in terms of the method of establishing the Institute’s internal organisational structure (Article 18 (1) of the Act on IPN), by empowering relevant bodies of the Institute (President or Council of IPN) to establish or remove organisational units and specify the procedure of implementing these changes and their acceptable scope.
To the President of the Institute of National Remembrance to:
- make sure the charter and organisational structure of the IPN Headquarters comply with the law;
- ensure compliance with internal regulations in terms of equal access to public procurement contracts and competitiveness in awarding them;
- take measures to ensure access to public procurement contracts to a broad spectrum of contactors, through optimal use of IT tools designed for communication with contractors and conduct public procurement procedure in a transparent and systematised way;
- strengthen supervision over financial economy of IPN and the manner of signing agreements;
- introduce consistent and transparent principles of using premises owned by the IPN Headquarters.
