Belgium has initiated enforcement proceedings against Poland, demanding payment of nearly 200 million zlotys (about 39.6 million euro) in connection with a court ruling on unpaid Covid-19 vaccines. The main judgment, issued on April 1, 2026, by the French-speaking Court of First Instance in Brussels, obliges Poland to pay approximately 1.3 billion euro (about 5.65 billion zlotys) to Pfizer and BioNTech for 60 million uncollected vaccine doses. Now, the Belgian tax authorities are seeking an additional 3 percent registration fee on the awarded amount, plus enforcement costs.
The dispute stems from a 2023 lawsuit filed by Pfizer and BioNTech against Poland in a Brussels court. The contract for joint vaccine purchases by EU member states was negotiated and signed by the European Commission under Belgian law. Poland argued that it had notified Pfizer of force majeure due to Russia’s aggression against Ukraine on April 12, 2022, seeking to halt vaccine deliveries and production. However, the court found no grounds for changing or annulling the contractual obligations, ordering Poland to pay around 1.3 billion euro.
Poland’s Ministry of Health stated that it intends to use all available legal means to challenge the ruling. – We will take further steps after a thorough analysis of the judgment and inter-ministerial consultations, in cooperation with our legal representative and the General Counsel of the Republic of Poland – the ministry said.
The Belgian tax demand
Beyond the main judgment, Belgium has sent a note demanding payment of a 3 percent registration tax on the awarded amount, which equals about 39.57 million euro (170 million zlotys). Additionally, enforcement fees of 11,022.70 euro and technical/administrative costs of 63.68 euro were added. The Polish Ministry of Health has not paid this sum and has lodged a diplomatic note with Belgian authorities, asking whether the mandatory tax applies to disputes involving EU member states. No response has been received yet.
The question of who will ultimately bear the cost remains unresolved. The Ministry of Finance points to the Ministry of Health, while the Ministry of Health argues that the payment should come from the state budget. If the burden falls on the health ministry’s budget, it would exacerbate existing financial pressures, which have already led to cuts in diagnostic funding by the National Health Fund, sparking political criticism from the opposition.
Political and financial implications
The total amount at stake, including the main judgment and additional taxes, exceeds 5.8 billion zlotys. The Polish government is seeking to shift all payments to the central budget to avoid further strain on the healthcare system. Meanwhile, the lack of response from Belgian authorities leaves Poland in a precarious position, potentially facing accelerated enforcement measures. The case highlights the complex legal and financial entanglements arising from EU-wide vaccine procurement contracts signed under Belgian jurisdiction.
– The Ministry of Health has indicated that Poland has not paid the demanded tax and has requested clarification through diplomatic channels – a ministry spokesperson said. The ministry also confirmed that negotiations with Pfizer and BioNTech in 2023 failed to reach a settlement.
Źródło: WNP.PL, Fot. PTWP
