An arbitral award has been issued. The debtor holds assets in Poland. The creditor now faces a system that is technically open to foreign awards – but procedurally demanding. Miss one document or misread one deadline, and enforcement stalls for months.

Enforcing an arbitral award in Poland requires a two-stage court procedure: first, recognition or declaration of enforceability by a Polish court, and second, execution through a court bailiff (komornik sądowy). The entire process is governed by the Kodeks postępowania cywilnego (Code of Civil Procedure, KPC) and, for foreign awards, by the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. A creditor who skips the recognition stage cannot instruct a bailiff – enforcement is simply unavailable until the court order is obtained.

This alert covers the two-stage procedure, the document requirements, the grounds on which a Polish court may refuse enforcement, and the immediate action items creditors must address. It is relevant to any party holding a domestic or foreign arbitral award and seeking to recover assets located in Poland.

What does the two-stage enforcement procedure require?

Polish law draws a clear line between uznanie (recognition) and stwierdzenie wykonalności (declaration of enforceability). Recognition applies to awards that do not require compulsory execution – for example, awards establishing a legal relationship. A declaration of enforceability is needed whenever the creditor intends to instruct a bailiff. In practice, most commercial creditors need the second route. The competent court is the district court (sąd okręgowy) at the place where enforcement is to be carried out, or, if that is unclear, the District Court for the Capital City of Warsaw (Sąd Okręgowy w Warszawie).

The court examines the application without a full hearing in the first instance. It does not re-examine the merits of the award. Processing typically takes between 30 and 90 days, depending on the court's workload and the completeness of the application. Once the court issues an enforcement clause (klauzula wykonalności), the creditor presents it to a bailiff, who then initiates asset seizure, bank account garnishment, or real-property enforcement.

  • File the application with the correct district court – jurisdiction errors cause immediate delay.
  • Attach a certified copy of the arbitral award and the arbitration agreement.
  • Provide certified translations into Polish for all foreign-language documents.
  • Pay the court fee – currently PLN 300 for a declaration of enforceability under KPC.
  • Anticipate a debtor challenge within 14 days of service of the court's order.

We secured enforcement of an ICC award exceeding EUR 3m for a technology client with assets in the Mazowieckie region (spring 2025). The critical factor was submitting a complete document set on day one – the court issued its order within 45 days.

When can a Polish court refuse to enforce an arbitral award?

Refusal is the exception, not the rule – but it is a real risk. Under the New York Convention and the KPC, a Polish court may refuse recognition or enforcement on a closed list of grounds. The debtor bears the burden of proving most of them. The court raises only two grounds on its own motion: non-arbitrability of the subject matter, and violation of public policy (klauzula porządku publicznego). Both are interpreted narrowly by Polish courts, but "public policy" has expanded in practice to include sanctions compliance concerns.

The debtor-side grounds include: incapacity of a party, invalidity of the arbitration agreement, lack of proper notice, award exceeding the scope of the submission, and irregular composition of the tribunal. Each ground requires specific documentary evidence. A debtor who raises multiple weak objections simultaneously may still delay enforcement by 60 to 90 days while the court processes responses. That delay has real economic cost – assets can be dissipated in that window if interim measures are not in place. (Interim measures from the National Court Register (KRS) search to asset freeze can be obtained in parallel with the recognition application.)

Sanctions compliance has become a distinct pressure point since 2022. If the award creditor or debtor appears on EU, US, or UN sanctions lists, the Polish Financial Supervision Authority (KNF) and the General Inspector of Financial Information (GIIF) may block payments even after a court order is obtained. A litigation Warsaw practitioner must screen both parties before filing. For context on cross-border enforcement complexity, see our guide on enforcing a Ukraine judgment in Poland step-by-step.

We obtained interim asset-protection measures for a German investor's subsidiary in Lower Silesia (autumn 2024), preserving over PLN 8m in receivables while the recognition application was pending. Acting within 7 days of the award was decisive.

What immediate action items apply after an award is issued?

Speed matters. Polish civil procedure does not impose a short limitation period specifically for enforcement applications – the general 6-year limitation period applies to most commercial claims. However, delay gives debtors time to restructure or dissipate assets. The practical window for effective enforcement is the first 30 to 60 days after the award becomes final.

The checklist below applies to any creditor holding a foreign or domestic arbitral award and targeting Polish assets. A dispute lawyer familiar with Polish enforcement practice should be engaged before the application is filed, not after a first refusal.

  • Obtain a certified copy of the final award within 7 days of issuance.
  • Commission certified Polish translations of the award and arbitration agreement immediately.
  • Run a KRS and land register search to map debtor assets before filing.
  • File for interim measures if asset dissipation risk is identified – the court can act within 7 days on an urgent application.

For creditors whose awards arise from public procurement disputes, note that a KIO appeal (appeal to the National Appeals Chamber, Krajowa Izba Odwoławcza) follows a separate administrative track and is not subject to the KPC enforcement procedure described here. Similarly, parties involved in EU-funded projects should review EU funds compliance – KPO and RRF requirements in Poland before initiating enforcement, as grant conditions may restrict asset disposal. For creditors enforcing UK-issued awards post-Brexit, the separate bilateral framework is addressed in our article on enforcing a United Kingdom judgment in Poland step-by-step.

Enforcement of arbitral awards in Poland is procedurally achievable. The risks are concentrated at two points: an incomplete application at the outset, and unprotected assets during the recognition period. Both are manageable with early legal engagement.

Your specific enforcement situation involves irreversible consequences if assets move before the court order is obtained. Delay at the application stage forfeits the practical value of the award.

To receive an expert assessment of your enforcement position and a document checklist tailored to your award, contact info@kordeckipartners.com.

Frequently asked questions

Q: How long does it take to enforce a foreign arbitral award in Poland?

A: The recognition stage typically takes 30 to 90 days at the district court level, assuming a complete application. Once the enforcement clause is issued, a bailiff can begin asset seizure within days. If the debtor challenges the order, add 60 to 90 days for the appeal. Total time from application to first asset recovery is commonly 3 to 6 months.

Q: Does Poland apply the New York Convention to all foreign awards?

A: Poland is a party to the New York Convention without the reciprocity reservation, meaning it applies the Convention to awards from all contracting states regardless of whether the state of origin applies it to Polish awards. This is a common misconception – Poland's position is more creditor-friendly than many assume. Awards from non-Convention states are enforced under bilateral treaties or general KPC provisions.

Q: What documents must be submitted with the enforcement application?

A: The application must include a certified copy of the arbitral award, a certified copy of the arbitration agreement, and certified Polish translations of both documents if they are in a foreign language. The court fee of PLN 300 must be paid at filing. Missing or uncertified translations are the single most common cause of first-instance rejection.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to commercial litigation and arbitral award enforcement. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your enforcement situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.