07/03/2026
EUCA - TAK, ŚWIADCZENIE MIESZKANIOWE DLA SCS CHRONIĄCEJ GRANICE UE - NIE - PYTAMY INSTYTUCJE UE
Związek Zawodowy Warsaw, 06 March 2026 year
Celnicy PL
Mailing address:
01-433 Warsaw
ul. Erazm Ciołek 14a e-mail: [email protected]
Ref: ZZ Celnicy PL-ZG-13 / 2026
Mr Thomas Gerassimos
Director-General
Directorate-General for Taxation and Customs Union
European Commission
Rue Joseph II 79
1000 Brussels, PO Box 1049
Dear Director-General,
The National Board of the Customs Officers Trade Union PL, which represents the largest number of members within the National Revenue Administration (hereinafter: NRA), respectfully requests your intervention to halt the further degradation of the potential of the Customs and Tax Control Service and to prevent discrimination against its officers in comparison with officers of other uniformed services in Poland.
In response to Parliamentary Interpellation No. 14802 regarding the exclusion of officers of the Customs and Tax Control Service from housing benefit regulations applicable to officers subordinate to the Minister of the Interior and Administration, the Minister of Justice, and to officers of the Marshal’s Guard, the Minister of Finance and Economy of the Republic of Poland stated that:
‘(…) by decision of the Council of the European Union, Poland is subject to the Excessive Deficit Procedure and is obliged to present realistic measures aimed at reducing budgetary expenditure. The Ministry of Finance has a special position here as the department responsible for overseeing the state budget and the level of public debt. Consequently, the 2026 Budget Act does not provide financial resources for the implementation of a housing allowance for officers of the Customs and Tax Control Service.’
However, it should be noted that the European Commission placed Poland under the Excessive
Deficit Procedure in June 2024. As reported by Prawo.pl: PL
https://www.prawo.pl/podatki/polska-objeta-procedura-nadmiernego-deficytu,527535.html
’Being subject to the procedure means that each of these countries must present a corrective action plan to reduce the deficit. The EU Commissioner for Economy, Paolo Gentiloni, reassured that being placed under the Excessive Deficit Procedure does not automatically require budget cuts. The Polish government argues that the deficit is linked to defence spending. In discussions with the European Commission, the Polish government maintained that Poland allocates significant funds to defence, which – under the new rules – Brussels should treat as ‘mitigating factors’ when assessing deficits and their limits by the member states.’
Despite Poland being placed under the Excessive Deficit Procedure in June 2024, housing benefits were introduced for officers of all uniformed services except the Customs and Tax Control Service:
- by the Act of 12 September 2025 amending certain acts in connection with determining accommodation rules for officers of the Police, Border Guard, State Fire Service, Internal Security Agency, Intelligence Agency, Military Counterintelligence Service, Military Intelligence Service, State Protection Service, and improving certain service conditions (Journal of Laws
2025, item 1366);
- by the Act of 21 November 2025 amending the Act on the Prison Service and certain other acts (Journal of Laws 2025, item 1823).
According to data from the Ministry of the Interior and Administration and subordinate formations, approximately 140,000–150,000 officers currently serve in Poland, including over 97,000 in the Police, approximately 30,000 in the State Fire Service, and nearly 16,000 in the Border Guard. Including the special services (Internal Security Agency, Intelligence Agency, Military Counterintelligence Service, Military Intelligence Service, and the State Protection Service), the total number of uniformed officers covered by housing benefits amounts to approximately 200,000.
Expenditure for additional benefits for officers of the Marshal’s Guard has also been planned in the 2026 budget, with the following justification:
‘We want to standardize, as far as possible, various types of allowances existing in other services so that they are also introduced in the Marshal’s Guard, where they currently do not exist,” said Mr Jacek Cichocki. He added that this includes, among others, housing allowances and leave-related allowances. The Head of the Chancellery of the Sejm justified this by stating that the aim is to prevent officers of the Marshal’s Guard from transferring to other services where such allowances already exist.’
The Customs and Tax Control Service is an armed formation participating in various activities and operations together with other services both domestically and abroad. The housing situation of this group of officers does not differ in any way from that of officers in other services who have been granted this allowance. In the opinion of the Board of the Customs Officers Trade Union PL, excluding the Customs and Tax Control Service leads to a sense of unequal treatment, deepens frustration within the customs community, and may negatively affect the personnel stability of the National Revenue Administration and violate constitutional principles of the Republic of Poland.
If housing benefits are in fact considered defence-related expenditures, and officers of all services (Police, Border Guard, Prison Service, State Protection Service, State Fire Service, Customs and Tax Control Service, Internal Security Agency, Intelligence Agency), including the Customs and Tax Control Service – in accordance with the Act on the Defence of the Homeland – are subject to militarization during mobilization and wartime and perform tasks for the security of the state under stricter regimes, then there are no grounds for discriminating against officers of the Customs and Tax Control Service.
Since officers of the Customs and Tax Control Service perform defence-related tasks both in peacetime and wartime, there are no rational arguments for denying them housing benefits analogous to those granted in all other services.
Not long ago, in April 2025 in Kraków, during a meeting with Directors-General of EU Customs Administrations and representatives of the European Commission, including DG TAXUD, OLAF and Europol, the Head of NRA, Secretary of State at the Ministry of Finance, Mr Marcin Łoboda, stated:
‘As the host of this important event, Poland confirms its key role in building security and ensuring effective customs control at the external borders of the European Union.
Joint efforts will not only improve the functioning of customs administrations but will also contribute to strengthening the security of Europe as a whole
In the face of changing trends in cross-border crime, we cannot ignore the challenges that pose real threats to our security.
As customs services, we have the tools to effectively secure the borders of the European Union. However, to achieve the desired results, effective international cooperation and a common strategy of action are essential,’ added the Head of the National Revenue Administration.
One of the significant challenges facing customs administrations is the effective enforcement of EU sanctions imposed on Russia and Belarus. Customs control activities are of particular importance in this respect.’
In light of the above, it must be concluded that the Head of NRA, Secretary of State at the Ministry of Finance, Mr Marcin Łoboda, presents differing assessments of the nature of the tasks and the impact of the Customs and Tax Control Service on the security of Poland and the EU, and as the only head of a uniformed service in Poland consistently pursues a policy leading to divergence in the service pragmatics of the Customs and Tax Control Service compared with other services.
When Polish state authorities seek the European Commission’s approval for establishing the seat of the EU Customs Authority (EUCA – 250 jobs for so-called European officials), the Customs and Tax Control Service is described as crucial for the security of Europe. However, when it comes to granting housing benefits, there are allegedly no funds for approximately 11,000 officers of the Customs and Tax Control Service, despite their performance of tasks essential for the entire EU.
We interpret the actions of the Head of NRA, Secretary of State at the Ministry of Finance, Mr
Marcin Łoboda, regarding the introduction of housing benefits for officers of the Customs and Tax Control Service as another step towards weakening and degrading the Polish (EU) customs service , which has already resulted in the departure of the most experienced officers to other services or the private sector. Yet, ‘the Customs Union should function efficiently (…), have a geopolitical dimension and better defend the financial interest of the EU and its Member States as well as EU’s security, safety, health, economic or environmental interests and values, to coordinate trade restrictions and shape international customs cooperation (…)”³
We kindly request that the authority responsible for EU customs policy undertake intervention in this matter.
We kindly ask for a response to be sent to: [email protected]
Yours sincerely,
On behalf of the Board
CC:
1. Addressee
2. a/a
For the attention of:
1. Petr Klement Director General - OLAF – European Commission European Anti-Fraud Office (OLAF) – 1049 Brussels Belgium
2. Catherine De Bolle Executive Director -Europol – P.O. Box 908 50, 2509 LW Haga – the Netherlands
3. Mr Donald Tusk, Prime Minister
4. Mr Andrzej Domański, Minister of Finance and Economy,
5. Mr Marcin Łoboda, Head of the National Revenue Administration
³ Communication from the Commission to the European Parliament, the Council and the European Economic and
Social Committee ‘Customs reform: Taking the Customs Union to the next level’, Brussels, 17.5.2023, COM(2023) 257 final
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