Warsaw, September 8, 2026

Dear Dr. Mieczysław Błoński, President of the Management Board

Polish Union of Education

Dear Mr. President,

I would like to thank you for forwarding the position of the Polish Educational Union on the draft act amending the Law on Higher Education and Science in the field of a new model for the evaluation of scientific activity. I am pleased to accept the support for the direction of the reform, in particular for reducing the excessive focus of the system on the number of publications and taking into account the quality of achievements, the social impact of science, popularization and knowledge transfer more broadly.

The presented postulates are largely in line with the assumptions of the proposed changes. The reduction in the number of achievements subject to evaluation and the change in the rules for determining the number of N and the limits of achievements are intended to reduce the pressure on mass publication and to focus the evaluation more strongly on achievements of the highest value. At the same time, the adopted solutions should counteract the building of the result of discipline primarily on the achievements of a small number of people.

The evaluation of scientific activity carried out in disciplines will remain comparative and parametric. The draft does not provide for the replacement of the point assessment of all achievements with a full expert assessment, which, due to the scale of the national evaluation, could lead to excessive costs and inconsistency of assessments. Expert evaluation will be of significant importance primarily as part of the assessment of the potential of the entity and in relation to the elements requiring qualitative assessment. The selection of experts will take into account their qualifications, experience, impartiality and the need to exclude conflicts of interest.

The proposed solutions are also intended to reduce the benefits of fragmenting research results, publishing a large number of papers of limited importance and over-focusing the result on the achievements of individual people. In addition, it will be possible to take into account solutions related to ethics, scientific integrity and responsible publication practices in the assessment of the entity's potential.

In addition, it will be possible to take into account solutions related to ethics, scientific integrity and responsible publication practices in the assessment of the entity's potential.

The new model will take into account activities that popularise science and counteract scientific disinformation more clearly. Cooperation with schools, cultural institutions, public administration and social organisations, as well as the preparation of educational materials and the organisation of popular science events, will be able to be evaluated. A distinction should be made between the dissemination of knowledge and the documented impact of scientific activity on society and the economy.

The project also provides for a broader consideration of the commercialisation of research results, knowledge transfer and achievements in the field of industrial property. However, these criteria will not be applied equally in all disciplines. In the humanities, social sciences and the arts, the impact of scientific activity may manifest itself primarily in culture, education, public debate, heritage protection or the activities of public institutions.

The designed system will be based on two complementary pillars: evaluation of the quality of scientific activity carried out in disciplines and expert assessment of the potential of the entity. This structure is to enable the combination of measurability and comparability of results with the assessment of qualitative and institutional aspects of scientific activity.

The comments of the Polish Education Union regarding the quality of achievements, research reliability, popularization of science, social impact and knowledge transfer will be used in further work on the draft act and implementing regulations.

Thank you for your involvement in the debate on the reform of the system for the evaluation of scientific activity and for presenting proposals aimed at strengthening the quality and social responsibility of Polish science.

Yours sincerely,

Krzysztof Bakuła

Director