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The draft ‘Digital Competence Development Programme for 2030’ accurately identifies the challenges associated with developing the digital competences of the Polish population, but fails to show how the planned measures are intended to lead to the achievement of the ambitious goals of the Digital Decade. The comments presented highlight the need to introduce measures to assess the effectiveness of public spending, annual milestones, systemic reforms and better use of local institutions and educational tools, so that the programme becomes a genuine instrument for managing change, rather than merely a collection of initiatives funded by various institutions.
In connection with the consultation on the draft ‘Digital Skills Development Programme for 2030’ (hereinafter referred to as the ‘Programme’), we submit the following comments and recommendations.
We welcome the attempt to coordinate government action in the field of digital skills development, in particular by identifying the bodies responsible for specific measures, establishing the Centre for Digital Skills Development, and appointing a team to coordinate the implementation of the Programme. We would, however, point out that the mere creation of coordination structures will not guarantee the achievement of the intended results. In our view, the Programme needs to be supplemented with mechanisms to assess the effectiveness of public interventions and the actual impact of individual measures on the public’s digital skills.
Lack of assessment of the effectiveness of public spending
The draft indicates that the estimated cost of implementing the Programme between 2022 and 2030 will amount to approximately 3.985 billion PLN, of which over 75 per cent is to be provided by the European Union. The document also sets out the costs allocated to individual priorities. However, it does not answer the fundamental question regarding the effectiveness of this expenditure: namely, what proportion of the anticipated improvement in individual indicators is to be achieved through the allocation of a specific amount of public funds.
The Programme should include indicators enabling the determination, amongst other things, of the cost of improving the digital skills of a single participant, the cost of achieving a lasting improvement in their skills, the cost of increasing the main indicator by one percentage point, and the relationship between expenditure on individual measures and their impact on the Programme’s main objectives. Simply stating the number of training courses delivered, accounts created in systems, materials developed or participants in events does not allow for an assessment of the effectiveness of the proposed public policy intervention.
Poland allocates considerable funds to digital education; however, in our view, the results remain unsatisfactory. In 2025, 50 per cent of Polish residents aged 16–74 possessed at least basic digital competences, compared with an EU average of around 60 per cent. Meanwhile, 24 per cent of Polish residents possessed above-basic competences, compared with around 31 per cent in the European Union. The situation is particularly worrying for those aged 65–74, among whom only 12 per cent possessed at least basic digital skills and 3 per cent possessed above-basic digital skills.
The 2030 targets remain out of reach with current measures
The data and charts presented in Chapter 8 of the draft Programme indicate that, at the current rate of change, Poland will not achieve any of the Programme’s four quantitative targets set for 2030. This applies both to achieving a level of 80 per cent of people with at least basic digital skills, 40 per cent with advanced digital skills, 6 per cent of ICT specialists amongst the workforce, and 29 per cent of women amongst ICT specialists. In 2025, these figures stood at 50 per cent, 24 per cent, 4.5 per cent and approximately 17 per cent respectively.
However, the Programme does not set out a roadmap for progressing from the current indicators to the target ones. It lacks annual milestones, a definition of the necessary rate of improvement, and an indication of what proportion of the envisaged change is to result from specific measures. Consequently, the document lists ambitious targets alongside a catalogue of various projects, but fails to demonstrate a causal link between them.
It is therefore appropriate to supplement the Programme with annual targets for the years 2026–2030 and to assign each measure a measurable contribution towards the achievement of one or more key objectives. If current forecasts indicate that the achievement of the objective is at risk, the Programme should set out a mechanism for the automatic adjustment of interventions, including changes to the scope of activities, an increase in their scale, or the reallocation of funds to projects yielding better results. Furthermore, knowing the cost of the basic intervention per participant makes it possible to estimate the total real expenditure required to achieve the objective. At present, a significant proportion of funding has been allocated to devices such as laptops and tablets, whilst considerably less has gone towards training; this makes it all the more difficult to estimate the scale of expenditure required to achieve the objectives of the Digital Decade 2030.
Lack of alignment between activities and GUS and Eurostat indicators
The draft Programme does not demonstrate how individual activities are intended to lead to a sustainable improvement in the digital skills of the population, nor what their anticipated impact will be on the key indicators measured by GUS and Eurostat. The table of activity implementation indicators focuses primarily on outputs, such as the number of participants, the number of campaigns, meetings, activated accounts on the platform or the number of materials produced. However, it does not allow us to determine whether participants have actually acquired new skills, whether they are able to use them, or whether the effect persists after the support has ended.
Each activity should be linked to a measurable change in digital competence between before and after participation in the project. It is essential to use pre- and post-tests, and in the case of larger-scale interventions, also to conduct studies on the sustainability of the effects six or twelve months later. The results should be benchmarked against the latest version of the DigComp methodology and the indicators used by the Central Statistical Office (GUS) and Eurostat. This would enable a shift from measuring institutional activity to measuring actual social outcomes.
Insufficient use of local institutions in rural areas
The project accurately identifies the scale of digital exclusion in rural areas. Rural residents account for over half of those who have never used the internet, and 57 per cent of rural residents lack even basic digital skills. Among farmers, this figure stands at 66 per cent, and among those aged 65–74, as high as 88 per cent.
Despite this assessment, the Programme does not propose a systematic model for reaching out to older people, farmers and other digitally excluded individuals in rural areas. The planned measures rely primarily on general competitions, Digital Development Clubs, information campaigns and the voluntary involvement of local government bodies and non-governmental organisations. There is a lack of engagement with institutions that have established relationships with local communities.
We recommend the creation of a digital education programme in rural areas, implemented in collaboration with, amongst others, rural women’s clubs, voluntary fire brigades, libraries, local cultural centres, organisations for older people, social welfare centres and local non-governmental organisations. These organisations can effectively bring participants together, identify their needs and build the trust necessary to overcome psychological barriers. In our view, the Digital Development Clubs project requires appropriate redesign.
At the same time, administrative barriers hindering access to local organisations must be removed. One example is the Register of Rural Women’s Clubs maintained by the Agency for Restructuring and Modernisation of Agriculture, which does not provide universal access to the clubs’ electronic contact details, including email addresses or addresses for e-delivery. The programme should provide for changes to the regulations and standards governing the maintenance of public registers so that institutions carrying out educational activities can, whilst respecting data protection principles, communicate electronically with organisations representing local communities.
Lack of legislative measures and systemic reforms
The draft remains largely a compilation of programmes, campaigns, training courses and institutional projects. However, it does not contain a comprehensive package of legislative changes or systemic reforms capable of permanently raising the level of digital literacy amongst the public. Such measures are just as necessary as the allocation of funds.
In particular, the programme should address the introduction of compulsory and measurable elements of media literacy in schools, covering the critical evaluation of information, the functioning of online platforms, disinformation, digital safety, digital hygiene and the informed use of artificial intelligence. A nationwide standard for assessing pupils’ digital literacy is also needed. The draft itself acknowledges that the state’s knowledge of pupils’ actual digital competences is insufficient, and that Poland did not participate in the last two editions of the ICILS survey.
It is reasonable to consider a compulsory digital competence test to be conducted at a specific stage of education and to incorporate these competences into the external examination system. The test should serve primarily to assess needs and plan support, rather than to create yet another educational barrier.
Nor does the programme present a sufficiently concrete model for the use of devices and infrastructure provided to schools under public programmes. The updated ‘Digital Pupil’ initiative (as an update to the ‘laptop for every Year 4 pupil’ programme) envisages the use of modern teaching aids and equipment acquired under the National Recovery Plan; however, it does not specify a minimum frequency of use, expected educational outcomes, or a standardised method for monitoring the impact of these investments on pupils’ competences.
A similar issue concerns educational platforms. The draft states that approximately 181,000 users have actively used the OSE IT Szkoła platform and completed at least one course, although the platform offers 237 courses and over 150 other resources. This scale remains disproportionate to the number of pupils, teachers and parents who are potential users.
The programme should set out mechanisms for the widespread use of public educational platforms in schools, for example by incorporating selected courses into the core curriculum, compulsory teacher training or preventative programmes. It also requires the development of a system of micro-credentials that would confirm specific competences acquired through short educational modules and could be recognised by schools, universities, public administration and employers.
Fragmentation of state-run e-learning platforms
We view the efforts to coordinate the activities of various institutions positively. At the same time, the Programme perpetuates the fragmentation of state educational resources. Individual institutions are developing their own websites and training systems. PARP uses the Development Services Database; the public administration has an e-learning system for the civil service; NASK is developing OSE IT School; the e-Health Centre is planning a dedicated LMS platform; and other entities are creating further portals and courses.
This approach increases maintenance costs, fragments the user base, hinders the promotion of the state’s offerings and leads to duplicate funding of similar functionalities. The programme should provide for the creation of a single central government e-learning platform, or at least a common access layer, ensuring a single sign-on, a course catalogue, a search engine, quality standards, analytics, micro-credentials and the ability to transfer learning outcomes between systems.
A single, recognisable platform would make it easier for citizens to find the right materials, reduce technological and promotional costs, and enable the effectiveness of courses to be compared regardless of the institution that developed them. Existing systems could continue to perform specialised functions, but should be integrated within a shared ecosystem.
Lack of appropriate indicators for the kompetencjecyfrowe.gov.pl portal
In the case of the initiative concerning the kompetencjecyfrowe.gov.pl portal, the only indicator adopted was the number of final reports on annual grants approved by the Minister for Digitalisation. This is a purely administrative indicator which says nothing about the portal’s popularity, usefulness or impact on users’ digital competences.
For the portal, indicators should be defined covering at least the number of users, the number of returning users, the number of courses started and completed, the course completion rate, the number of micro-certificates obtained, the cost of acquiring an active user, and the results of competence tests. It is also advisable to conduct satisfaction and usability surveys and to publish the data in the form of an open monitoring dashboard.
Lack of reflection on the impact of digital devices and AI on children’s learning
The Programme lacks an in-depth reflection on the impact of digital devices and artificial intelligence on children’s learning. The document assumes that the use of modern technologies in education generally always promotes the development of digital competences; however, it does not sufficiently analyse the risk that the premature or inappropriate use of devices and generative AI may impair concentration, reading comprehension, memory, independent problem-solving and the ability to formulate one’s own arguments. Meanwhile, the development of digital competences must not come at the expense of basic cognitive competences.
The entry into force on 1 September 2026 of regulations restricting the use of smartphones and other electronic devices in primary schools and nurseries should be viewed positively. This is a necessary adjustment to the existing approach. However, the programme does not provide for monitoring the outcomes of this change or for a systematic analysis of the experiences of other countries which, after years of intensive digitisation of education, are beginning to limit the presence of screens in schools.
Particular attention should be paid to Norway’s experience, as the country was for years one of Europe’s leaders in the digitisation of education and made extensive use of computers and tablets in schools. However, a decline in pupils’ results, including reading skills, prompted a reassessment of this policy, an increase in funding for traditional books and printed materials, and a restriction on the use of smartphones and screen-based devices. Norway has also adopted an approach that differentiates access to generative AI according to pupils’ age. The youngest pupils are primarily expected to master reading, writing, arithmetic and problem-solving independently, whilst older pupils may use AI under the supervision of a teacher and in a manner tailored to their stage of development. The most important lesson from the Norwegian experience boils down to the principle that AI can reinforce existing skills, but should not replace the process of acquiring them.
Similar conclusions emerge from the study ‘The Generative AI Learning Penalty’, which covered 26,811 Chinese pupils in Years 7–12 observed over a 30-month period. After they began using AI, marks for homework improved by an average of 18 per cent, whilst the time spent on tasks fell by 30 per cent. However, this improvement proved to be illusory. After six months, results in exams taken without access to AI fell by around 20 per cent, whilst results in secondary school and university entrance exams fell by 18 per cent and 24 per cent respectively. The greatest declines were observed among pupils who relied on AI to complete tasks, rather than using it to obtain explanations, guidance and feedback. Among pupils who used AI but still devoted a similar amount of time to independent study, the negative effect was significantly smaller.
These findings indicate that, from an educational perspective, it is not the use of AI itself that is crucial, but rather how it is used. A tool that solves a problem for the pupil shortens the learning process and may improve current marks, but it does not develop lasting skills. AI acting as a tutor – explaining concepts, asking questions and guiding pupils towards a solution – can, however, support the teaching process without depriving pupils of cognitive effort. The programme should clearly distinguish between these two models.
We recommend supplementing the Programme with a system to monitor the impact of digital devices and AI on educational outcomes, concentration, reading comprehension, independence and pupils’ wellbeing. Guidelines for the use of generative AI, tailored to different age groups, should also be drawn up; situations in which its use should be prohibited should be defined; and a teaching standard should be established requiring that AI supports the process of arriving at a solution rather than doing the work for the pupil. At the same time, the state should monitor policies in other countries and periodically assess whether a further increase in the number of devices in schools actually improves educational outcomes.
Spending on equipment should be conditional upon the presentation of a model for its use, the training of teachers and the demonstration of educational outcomes. Under the National Reconstruction Plan (KPO), Poland is allocating over 5 billion zlotys to equipment for schools, including approximately 1.86 billion zlotys for 12,000 AI laboratories. Such a large investment requires more than simply monitoring the number of devices supplied. It should be subject to an independent evaluation that addresses the question of whether the technology helps pupils acquire knowledge and develop independence, or whether it merely increases the presence of screens in the teaching process.
Summary
The draft Programme contains an accurate assessment of many problems and numerous necessary initiatives. Its fundamental weakness, however, remains the lack of a clear link between objectives, actions, expenditure and outcomes. The document sets out what the administration intends to do, but does not sufficiently explain how these actions will translate into improvements in GUS and Eurostat indicators, nor how much it will cost to achieve the intended outcomes.
We recommend supplementing the Programme with annual milestones, a cost-effectiveness assessment model, outcome indicators based on actual skills development, a system for correcting ineffective measures, legislative reforms in education, a programme to reach out to older people and rural residents through local trusted institutions, the development of micro-credentials, and the integration of public e-learning platforms.
Only once these elements have been introduced can the Programme become a genuine tool for managing change, rather than merely a catalogue of measures funded by various institutions.