EU project audit in Poland: thresholds, requirements and what auditors check

When is an EU project audit required?

EU project audits in Poland arise from two sources: the funding agreement (umowa o dofinansowanie) and the programme rules. The obligation is triggered by the volume of eligible expenditure declared to the managing authority — not by the size of the company receiving the funds.

The audit may be required at a specific milestone (e.g. after submitting the final payment application) or periodically during implementation. Some programmes require an audit for every payment request above the threshold; others require one final audit at project close.

Expenditure thresholds by programme

What the auditor checks

An EU project audit is a structured engagement focused on four main areas:

1. Eligibility of declared costs: Were all costs included in the payment application actually incurred, properly documented and within the eligible cost categories defined in the funding agreement? Common disqualifications: costs incurred outside the eligible period, costs not listed in the approved budget, costs not supported by adequate source documents.
2. Public procurement compliance: Were procurement procedures followed correctly? For public entities: full Public Procurement Law (Prawo Zamówień Publicznych). For private entities: the competitiveness principle (zasada konkurencyjności) — minimum three quotes for most purchases, published tender for larger contracts.
3. Separate project accounting: Does the entity maintain a dedicated cost centre, project code or separate account for the EU project? Can all project costs and revenues be traced unambiguously? This is one of the most frequently cited weaknesses in project audits.
4. Achievement of project indicators: Were the outputs and results committed to in the application (e.g. number of jobs created, R&D results, energy savings) actually achieved and documented?

How to choose a project auditor

Not all auditors are equally suited to EU project audits. When selecting, consider:

• Experience with the specific programme: NCBiR audits have different documentation requirements than FEnIKS or PARP. An auditor familiar with the programme's specific rules is more efficient.
• PANA registration: The auditor must be a registered statutory auditor (biegły rewident) listed in the Polish Agency for Audit Oversight (PANA) register. Some managing authorities additionally require KIBR membership — verify the requirements in your call documentation.
• Report format knowledge: Each programme has a specific auditor's report template. Verify that the auditor knows the required format before engagement.
• Independence: The auditor must be independent of the entity — they cannot have provided accounting, financial management or other services that could create a conflict of interest.

Pre-audit checklist for project beneficiaries

• ☐ All original source documents (invoices, contracts, bank transfers) filed and accessible
• ☐ Separate accounting records (cost centre or project code) set up and complete
• ☐ Procurement files complete: quote requests, responses, selection decisions
• ☐ Bank statements showing actual payments for all declared costs
• ☐ Timesheet records for personnel costs claimed
• ☐ Documentation of project indicator achievement (reports, photos, contracts)
• ☐ Funding agreement and all amendments accessible to the auditor
• ☐ Prior audit findings (if any) addressed and documented

Audit cost as eligible expenditure

In most Polish EU programmes, the cost of a mandatory project audit is itself an eligible expenditure — meaning it can be charged to the project budget and co-financed by EU funds. To take advantage of this:

• Ensure the audit cost is included in your approved project budget (category: project management or external services)
• Follow the procurement rules when selecting the auditor (competitiveness principle or PZP as applicable)
• Confirm eligibility with your managing authority or PARP/NCBiR project officer before commissioning the audit

For companies in Warsaw or Łódź planning EU-funded projects, see: financial audit Warsaw and financial audit Łódź.