{"id":6103,"date":"2026-09-06T13:34:51","date_gmt":"2026-09-06T11:34:51","guid":{"rendered":"https:\/\/ak-law.pl\/blog\/kas-audit-what-does-it-mean-for-a-funding-recipient\/"},"modified":"2026-09-23T15:08:37","modified_gmt":"2026-09-23T13:08:37","slug":"kas-audit-what-does-it-mean-for-a-funding-recipient","status":"publish","type":"post","link":"https:\/\/ak-law.pl\/en\/blog\/kas-audit-what-does-it-mean-for-a-funding-recipient\/","title":{"rendered":"KAS audit \u2013 what does it mean for a funding recipient?"},"content":{"rendered":"\n

Further proceedings may take place between the audit findings and the final resolution of the case.<\/strong><\/p>\n\n

For a business subject to a KAS audit, this distinction has significant practical consequences. A finding of irregularities during an audit does not automatically mean that funding must be repaid<\/a> or that criminal liability has been established. If the KAS audit concerns a business implementing a publicly funded project, the audit may examine, among other things, expenditure incurred, compliance with applicable law, and compliance with the funding conditions. The precise scope of the audit depends on the type of funding, the subject matter of the audit, and the funding conditions applicable to the particular project. <\/p>\n\n

For a funding recipient, the key issues are the stage of the case and the legal nature of the document received. An audit finding, a demand for repayment of funding<\/a>, an administrative decision<\/a>, a notification to the prosecutor\u2019s office, or the bringing of criminal charges are different legal events, each of which requires a separate assessment. <\/p>\n\n

What can KAS examine during a project audit?<\/strong><\/h2>\n\n

In relation to projects financed from European Union funds, the audit may cover, among other things, the management of those funds and of funds allocated for national co-financing. The Act on the National Revenue Administration<\/a> also provides for audits of the management of funds under the national recovery and resilience plan. For a funding recipient, this means that the audit may examine how funds were used in a particular project, whether expenditure was lawful and properly incurred, the documents confirming that expenditure, and compliance with the applicable funding conditions. <\/p>\n\n

The scope of the audit is not limited to analysing documents submitted to the authority. The Act allows audit activities to be carried out at the funding recipient\u2019s premises, at the place where it conducts its business, and at the project implementation site. In connection with the audit, KAS may also request documents from the audited entity and its contractors and carry out on-site inspections. <\/p>\n\n

From the funding recipient\u2019s perspective, it is therefore important at the outset of the audit to verify its scope, including the period under review, the expenditure being examined, the documents requested, and the funding conditions relied upon by KAS.<\/p>\n\n

What do the findings of a KAS audit mean?<\/h2>\n\n

The findings of a KAS audit are documented in an audit report or an opinion, depending on the type of audit. The document summarising the audit must, however, be distinguished from any subsequent decisions or other measures that may arise in the funding recipient\u2019s case. An audit report is not an administrative decision and does not in itself impose an obligation to repay funding. Its findings may nevertheless be used in subsequent actions or decisions concerning the project. <\/p>\n\n

Communication from the National Revenue Administration dated 31 August 2026<\/a> The communication gives three figures that are easy to remember: 177 audited entities, more than PLN 120 billion in identified irregularities, and 255 notifications to the prosecutor\u2019s office concerning more than PLN 106 billion.<\/p>\n\n

Once repeated in the media, however, these figures may begin to suggest more than the original communication actually states. KAS refers to the \u201ctotal amount of irregularities<\/em>\u201d identified in the course of audits and to notifications concerning a suspected offence. In one media headline, the same information was presented as more than PLN 120 billion in \u201cidentified fraud<\/em>\u201d. This is not merely a stylistic difference. It changes the scope of what may be understood from those findings. <\/p>\n\n

PLN 120 billion is therefore not a balance sheet of fraud established by final judgments, and 255 notifications do not mean 255 offences have been proven.<\/strong><\/p>\n\n