Was the illumination paid for legally? MZGM explains

The documents obtained by the istotne.pl portal show that in 2024 spending on illuminations exceeded PLN 176,000 net, while in 2025 it amounted to nearly PLN 166,000. In both cases, the threshold was PLN 130,000, above which the Public Procurement Law must be applied. Despite this, most of the orders were placed without a tender..

We asked MZGM directly whether a single order had been divided into several smaller ones. The answer leaves little doubt about the way it operated.

“Each of the above orders was treated as a separate order whose value did not exceed the threshold for applying the Public Procurement Law,” admit Deputy Director Justyna Foremna and Head of the Operations and Municipal Affairs Department Janusz Kozioł.

At the same time, MZGM confirms something even more significant:

“No […] comprehensive estimate was prepared covering Easter decorations, Christmas decorations and supplementary purchases as a single order.”

This means that MZGM did not even try to calculate how much it would spend on illuminations over the course of a year.

Instead, as the response indicates, decisions were made on an ongoing basis, depending on the available funds:

“The orders were carried out at various times of the year […] taking into account current needs and available financial resources.”

Officials maintain that everything complied with the regulations and that the actions were not intended to circumvent them. They also argue that Easter and Christmas decorations are different tasks because they have different themes, dates and characteristics.

The problem is that in public procurement practice, what matters is not the calendar or the holiday theme, but whether the services are of the same type. Here, it is difficult not to notice a recurring pattern: the same illuminations, the same contractor, the same contracting authority—year after year.

And that is precisely why the fundamental question arises: instead of several smaller orders, should there not have been a single procedure covering all services in a given year?

Because if so, the total spending significantly exceeded the statutory threshold.

MZGM responds that this was not possible due to work organization and the budget. However, the regulations do not make the obligation to hold a tender dependent on when the money becomes available. What matters is what can be foreseen—and it is difficult to regard holiday illuminations as an unexpected expense.

The matter is therefore not closed. On the contrary, the authority’s response confirms the key facts: the lack of a combined estimate, the splitting of orders and the annual threshold being exceeded. These are precisely the elements that, in similar cases, come under the scrutiny of oversight institutions.

Detailed analysis of spending on illuminations

2024—partly through a tender procedure

• Easter: PLN 40,600 net
• Christmas (tender): PLN 125,354 net
• Additional purchases: PLN 10,260 net
  Total: PLN 176,215 net

One large tender was held, but only for Christmas. The total value of the illuminations exceeded the PLN 130,000 threshold. Some orders were placed outside the Public Procurement Law despite the threshold being exceeded on an annual basis

2025—all outside a tender procedure

• Easter: PLN 36,617 net
• Christmas: PLN 122,111 net
• Additional purchases: PLN 7,194 net
  Total: PLN 165,924 net

In 2025, there was no tender at all; each order was handled separately below the threshold. In total, the threshold was exceeded by approximately PLN 36,000.