# Głos Migranta (wnioskodawca) | pismo wnioskodawcy | 19.09.2026
# Pismo do Sekretariatu CONT PE: sprawozdania roczne z art. 35 - AMIF w Polsce, procedury 236-647 dni i brak wskaźnika czasu (EN)
# źródło tekstu: OCR opublikowanej (zanonimizowanej) wersji
# dokument: https://glos-migranta.eu/dokumenty/gm-374-ep-cont-2026-09-19.pdf

Re: AMIF in Poland: residence procedures of 236-647 days and no
result indicator that measures them
Dear Secretariat,

further to my message of 11 September 2026, I am writing once more because documents released since
then make the point narrower, and because one of them fixes a date by which it can still be acted upon.

1. The programme reporting. On 15 and 16 September the Polish Managing Authority disclosed the four
annual performance reports for programme CCI 2021PL65AMPR001 submitted under Article 35 of Regulation
(EU) 2021/1147, covering January 2021 to June 2025; the latest was approved by the monitoring committee
on 16 February 2026. I read all four in full. None contains a single figure, indicator or sentence on how long
residence procedures take. The 2024/2025 report states that support was directed "primarily to the Office for
Foreigners, the Border Guard and the voivodeship offices, in order to strengthen their capacity".

2. The supervising ministry. On 16 September the same Ministry replied in writing that it "does not possess
periodic reports, compilations or statistical information taking into account the timeliness of residence
legalisation proceedings"; that it requested no explanations from any voivode on the duration of such
proceedings in 2024-2026; that it carried out no inspection or audit of the voivodeship offices in this field since
2024; and that no organisational unit within it is designated to monitor that timeliness.

3. The projects themselves. The indicator sheets of all sixteen projects of the 2024 call for voivodeship offices,
released by the intermediate body on 2 September, show that in every one of the sixteen the sole mandatory
indicator is named "Nie dotyczy" ("not applicable") with a target of 0.0000. Thirteen projects declare no result
indicator at all. The largest, "Cudzoziemiec na Mazowszu" of the Masovian Voivode (PLN 39,540,000, of which
PLN 29,655,000 from AMIF), declares exactly one, named "brak możliwości usunięcia" - "cannot be deleted" -
with a baseline of 0.0000, a target of 0.0000 and "employment contracts" as its method of measurement. The
same project's summary opens with the sentence that "the main problem of third-country nationals in the
residence legalisation procedure in Masovia is the long waiting time for a residence card" and promises IT
functionalities "shortening the duration of the legalisation procedure". No result in it is expressed in time.

4. The number exists and is already used - to distribute money. The rules of the 2026 call for voivodeship
offices (PLN 112,999,000) state that the allocation was divided by a fixed sum per region and five keys, the
fifth being "the average duration of proceedings in the voivodeship office". The Managing Authority therefore
holds this figure for each office and uses it to decide how much each receives, while requiring no indicator on
it from any of them.

5. Money committed this year. The Office for Foreigners' application 0143/25, lodged on 20 February 2026
under the direct call FAMI.02.01-IZ.00-002/25, with a financing agreement signed on 14 April 2026, lists as its
mandatory output indicator "Nie dotyczy (produkt)" with a target of 0.0000, and one indicator of its own:
eighteen information Saturdays, to be measured by "payment requests".

6. Two clocks. The 135 payment requests of the sixteen 2024 projects were all approved, none rejected, in a
median of 27 days from submission, with no statutory deadline governing that step. The applicant on the other
side of the same offices has a statutory limit of 60 days and, in 2026, actual averages of 236 to 647 days.

Taken together these documents describe one thing: the figure that measures the outcome is precise enough
to divide the money between sixteen regions, and absent from every level of reporting on what the money
achieved - the project indicator, the final report, and the annual report to the Commission.

The legal lever. Annexes V and VIII to Regulation (EU) 2021/1147 contain, for every specific objective, no
indicator of the duration of any procedure; all count persons, places, items or projects. Article 33(5) empowers
the Commission to adopt delegated acts amending Annex VIII "in order to review or complement those
indicators". Under Article 37(2) that power is conferred only until 31 December 2027, and under the last
sentence of Article 33(5) any amendment applies solely to projects selected after its entry into force. Whatever
is not added by that date will not apply to this programming period at all.
In my message of 11 September I referred to Recommendation 4 of the Court of Auditors' Special Report
26/2024, under which the Commission is to analyse by the end of 2026 how to improve the reporting
framework. My request is confined to what the Secretariat can do: that this note be kept on file with the earlier
one, and that, when the Commission reports on that recommendation, the question be put whether a duration
indicator for residence procedures will be added to Annex VIII under Article 33(5) while the power to do so still
exists.

Attached is the single document behind point 3, as released by the Polish intermediate body on 2 September
2026: the indicator record of project FAMI.02.01-IZ.00-0013/24, in which the sole result indicator is the one
named "brak możliwości usunięcia" - "cannot be deleted". The remaining documents cited above are available
on request.

Yours faithfully,
[imię i nazwisko usunięte]
