prof . Ph.D. ​Jan Fazlagić, 10/06/2024

In the official document of the Ministry of Foreign Affairs of the Republic of Poland entitled ‘White Paper on Actions Necessary to Eliminate Irregularities in the Polish Visa System,’ there is a significant number of simplifications of reality and statements not supported by statistics. The document incorrectly addresses issues related to the labor market and internationalization of Polish universities en bloc in many places.

Furthermore, the document abstracts from pertinent conditions and contexts, omits international statistics and documents from international organizations, including the European Commission, regarding the internationalization of higher education. The Polish legal system has certain imperfections, but it is difficult to agree with the statement that there are ‘completely no legislative and systemic solutions.’ One could get the impression that the authors of the document, having familiarized themselves with certain pathologies and individual cases for which only a small number of Polish universities are responsible, suggest introducing new regulations that would somewhat ‘reveal’ the entire environment and real, honest candidates for studies as pathologies detected in a small percentage of Polish universities. Imperfections in the law are a permanent feature of legal systems in a rapidly changing reality, and one should not make accusations solely on this basis, but rather undertake constructive actions based on reliable information (evidence-based), which are lacking in the aforementioned document.

The document mentions the ‘pressure’ from employers and the academic community. The existence of ‘pressure’ stemming from objective needs should not be construed as an accusation against any social group. By ‘pressure,’ one should simply understand the submission of new ideas for the development of internationalization in Poland by both groups of stakeholders (employers and universities). Importantly, ideas originating from the Polish university environment usually have strong foundations in documents and reports from international organizations, higher-order regulations, and directives (including those from the EC, UNESCO, OECD) and should not be considered controversial or anti-systemic, as one might infer from the content of the White Paper. It is the role of the legislator and the government to create a system of solutions that will satisfy these needs. One should not ‘punish the messenger’ and stigmatize universities for publicizing their needs and for providing the public with facts regarding the challenges faced by Polish employers and universities.

The statement at the very beginning of the document regarding the ‘misconceived idea of internationalization of Polish universities’ is detrimental to the efforts of Polish higher education authorities to align with global trends and those set by the European Commission. The European Union strongly supports the internationalization of higher education, considering it a key element of education and research development strategy. The EU’s position on this issue focuses on several key goals. According to the European Commission, actions towards internationalization aim to strengthen the position of European universities internationally, including developing cooperation with institutions outside Europe and promoting mobility of students and academic staff. All these actions aim to create a more integrated and competitive European higher education sector, better prepared to meet global challenges.

The authors of the White Paper probably are not aware that internationalization of universities concerns not only students but also teaching programs, faculty, engagement in international research, international accreditation, and many other aspects. Furthermore, these aspects are interconnected, and the analysis should not be limited solely to the narrow issue of visas for foreign students. Research results on internationalization demonstrate many long-term positive benefits and synergies resulting from opening the higher education system to foreign students, such as the prospect of continuing an academic career for the most talented students or supplying the labor market with highly qualified specialists. There are well-known cases of businesses being founded by students, with Elon Musk being a prominent example, who studied in the United States after moving there from South Africa. According to the National Foundation for American Policy (NFAP) report, one-fourth of American “billion-dollar companies” were founded by entrepreneurs who studied at American universities as international students. These entrepreneurs significantly contributed to economic development and job creation.

The assertion that issuing study permits ‘on request,’ detached from the priorities of Polish foreign policy and security, is an abuse. It is in the interest of the Polish economy for Polish entrepreneurs to have the opportunity to develop their businesses based on the workforce resources lacking in the Polish labor market. Every legally employed worker benefits the economy. Of course, the presence of some of these individuals carries certain risks to security, but the issue of labor migration should not be viewed in black-and-white terms.

The authors of the White Paper argue: ‘Abuse of too easy recruitment for studies’ – however, they did not specify what they mean by ‘abuse’ – if recruitment is ‘easy,’ then there is probably no need to ‘abuse’ it. This is a serious accusation against Polish universities – though formulated in an insufficiently precise manner. The authors of the White Paper did not specify which universities have ‘too easy recruitment,’ what the parameters of ‘easy recruitment’ are, and what constitutes the authors’ idea of proper, i.e., ‘not easy’ (?) recruitment. Certainly, one cannot agree with the purported cause-and-effect relationship presented in the document that a high percentage of foreign students in the general student population of a given university (first table in the White Paper (no title)) would be evidence of ‘easy recruitment.’

In the second table of the White Paper, a list of the 10 universities with the highest number of foreigners from 2022 is presented immediately after the argument about the abuse of too easy recruitment for studies. Such juxtaposition of information can be considered manipulative, as there is no evidence that a large proportion of foreign students is a result of too easy recruitment. According to the authors of the White Paper, a low percentage of foreign students among students would be evidence of difficult recruitment. Incidentally, it is worth noting that the student numbers given in the table do not exceed 6,000, while leading universities worldwide have five-figure student populations. The absolute numbers provided are surprisingly low and cannot substantiate any reasonably motivated hypothesis about the abuse of ‘too easy recruitment for studies.’ Moreover, numerical data presented in the first table of the White Paper take on an entirely different meaning when compared with data in table 1. In reference to the above, it would be worth comparing data on the number of work permits issued with the number of foreign students from a given country. With a few exceptions concerning countries from which the absolute number of students is a few hundred people (e.g., Kenya), the percentage of foreigners studying in the first year of studies in relation to the number of work permits from the same country is in many cases less than 1% (e.g., Nepal, Turkmenistan, Philippines). For India, this value is 3%, meaning that 97% of citizens of this country who had work permits in the years 2018-2023 did not study in Poland. For Bangladesh, this value is 99.2%, etc. It is therefore evident that foreign students constitute only a small part of the population of citizens of a given country residing in Poland.

Table 1. Number of work permits issued compared to the number of students from a given country 

Citizenship		2018	2019	2020	2021	2022	2023	Total
Pakistan	Number of work permits issued	1065	911	815	1526	4645	7393	8962
	1st year foreign students	52	49	61	56	99		317
India	Number of work permits issued	8362	8063	8184	15326	41640	45998	81575
	1st year foreign students	810	588	388	471	577		2834
Nepal	Number of work permits issued	19912	9175	5708	10853	20045	35287	65693
	1st year foreign students	118	35	9	8	25		195
Bangladesh	Number of work permits issued	8341	6986	3758	7524	13539	27896	40148
	1st year foreign students	91	68	52	50	69		330
Turkmenistan	Number of work permits issued	42	317	961	2648	11919	8779	15887
	1st year foreign students	23	23	15	22	21		104
Uzbekistan	Number of work permits issued	2634	6309	5873	15002	33373	27959	63191
	1st year foreign students	206	619	817	1138	1005		3785
Philippines	Number of work permits issued	2057	6317	7391	13279	22557	29154	51601
	1st year foreign students	7	12	17	6	23		65
Nigeria	Number of work permits issued	80	268	554	987	1611	1420	3500
	1st year foreign students	58	164	358	697	356		1633
Tanzania	Number of work permits issued	2	20	22	66	196	344	306
	1st year foreign students	10	15	36	36	56		153
Kenya	Number of work permits issued	20	104	186	779	2091	1727	3180
	1st year foreign students	20	43	33	50	48		194
Zimbabwe	Number of work permits issued	13	40	116	360	815	5017	1344
	1st year foreign students	210	406	561	1331	1543		4051
Rwanda	Number of work permits issued	6	22	309	686	977	1216	2000
	1st year foreign students	80	104	212	272	372		1040
Total	Number of work permits issued	42534	38532	33877	69036	153408	192190
	1st year foreign students	1685	2126	2559	4137	4194
		3.96%	5.52%	7.55%	5.99%	2.73%
2018-2022 total	Number of work permits issued			337387
	1st year foreign students			14701
				4.36%

Source: APUI study based on Central Statistical Office data: https://stat.gov.pl/obszary-tematyczne/edukacja/edukacja/szkolnictwo-wyzsze-i-jego-finanse-w-2022-roku,2,19.html

From Table 1, it is clear, without needing to conduct complex analyses, that the ratio of the number of students from a given country to the number of work permits issued is marginal. Exceptions are countries with a small absolute number of students, such as Tanzania (153 students vs. 306 work permits). Summarizing, the number of foreign students in Poland in the years 2018-2022 constitutes only 4.36% of the issued work permits. Contrary to the narrative promoted in the White Paper, linking visa issues for workers in Poland with student visas is unfounded, and the percentage of students among the number of work permits (700,000) is marginal (Table 1).

As shown by the data in Table 2, the percentage of residence permits issued for educational purposes in Poland is still very low compared to other European/EU countries – Poland ranked 3rd among countries with the lowest percentage of visas issued for this purpose.

Table 2. Percentage of residence permits issued for education purposes.

	Permits issued (number)	Family		Education		Employment		Other
		(number)	(% of total permits issued)	(number)	(% of total permits issued)	(number)	(% of total permits issued)	(number)	(% of total permits issued)
EU	3,454,684	896,099	25.9%	456,801	13.2%	1,241,093	35.9%	860,691	24.9%
Belgium	68,522	33,313	48.6%	9,297	13.6%	8,144	11.9%	17,768	25.9%
Bulgaria	15,839	5,345	33.7%	1,923	12.1%	4,621	29.2%	3,950	24.9%
Czechia	53,809	14,250	26.5%	10,128	18.8%	24,582	45.7%	4,839	9.0%
Denmark	40,467	11,236	27.8%	10,932	27.0%	14,801	36.6%	3,498	8.6%
Germany	538,690	188,367	35.0%	70,072	13.0%	81,795	15.2%	198,456	36.8%
Estonia	8,425	3,117	37.0%	579	6.9%	2,341	27.8%	2,388	28.3%
Ireland (1)	85,793	3,997	4.7%	41,506	48.4%	19,502	22.7%	20,788	24.2%
Greece	35,391	15,935	45.0%	893	2.5%	5,649	16.0%	12,914	36.5%
Spain	466,712	174,532	37.4%	58,418	12.5%	140,034	30.0%	93,728	20.1%
France (2)	324,200	96,598	29.8%	104,777	32.3%	54,885	16.9%	67,940	21.0%
Croatia	57,330	2,710	4.7%	328	0.6%	53,471	93.3%	821	1.4%
Italy	337,788	131,275	38.9%	25,466	7.5%	66,791	19.8%	114,256	33.8%
Cyprus	38,917	8,371	21.5%	1,956	5.0%	19,221	49.4%	9,369	24.1%
Latvia	8,790	2,203	25.1%	1,985	22.6%	3,549	40.4%	1,053	12.0%
Lithuania	31,232	2,468	7.9%	1,970	6.3%	22,346	71.5%	4,448	14.2%
Luxembourg	9,245	4,181	45.2%	633	6.8%	3,204	34.7%	1,227	13.3%
Hungary	57,286	5,485	9.6%	10,148	17.7%	35,986	62.8%	5,667	9.9%
Malta	37,851	2,693	7.1%	5,260	13.9%	27,549	72.8%	2,349	0.6%
Netherlands	137,200	45,870	33.4%	21,871	15.9%	32,123	23.4%	37,336	27.2%
Austria	55,258	17,369	31.4%	4,743	8.6%	5,437	9.8%	27,709	50.1%
Poland	700,264	19,004	2.7%	33,342	4.8%	447,225	63.9%	200,693	28.7%
Portugal	108,684	38,602	35.5%	9,712	8.9%	53,194	48.9%	7,176	6.6%
Romania	42,207	4,224	10.0%	4,851	11.5%	31,079	73.6%	2,053	4.9%
Slovenia	32,781	7,499	22.9%	2,424	7.4%	22,517	68.7%	341	1.0%
Slovakia	27,441	4,062	14.8%	3,345	12.2%	19,339	70.5%	695	2.5%
Finland	49,774	17,228	34.6%	9,314	18.7%	17,616	35.4%	5,616	11.3%
Sweden	84,788	36,165	42.7%	10,928	12.9%	24,082	28.4%	13,613	16.1%
Iceland	3,394	931	27.4%	585	17.2%	599	17.6%	1,279	37.7%
Lichtenstein	902	688	76.3%	22	2.4%	124	13.7%	68	7.5%
Norway	28,145	11,817	42.0%	5,232	18.6%	6,024	21.4%	5,072	18.0%
Switzerland	49,257	20,258	41.1%	12,981	26.4%	13,273	26.9%	2,745	5.6%
(1) unreliable data
(2) provisional data except for family reason

Source: Eurostat

It is also worth making comparisons (benchmarking) with other countries and universities, especially in the “Old Union.” Do the authors of the White Paper believe that recruitment in those countries is (sufficiently) “difficult”? Instead of using journalistic arguments, it would be better for the Ministry to issue specific recommendations for Polish universities on how, in its view, recruitment should be conducted to invalidate the Ministry’s accusation. The arguments presented at the end of the White Paper seem unconvincing and fraught with many question marks.

The percentage of foreign students can and should be considered in a much broader context than as evidence of allegedly low recruitment criteria. Attracting a foreign student requires universities to have high marketing competencies, knowledge of educational markets, preparation of staff for marketing activities outside Poland, etc. Not all Polish universities have such competencies, so the low internationalization rate of the student population in other Polish universities could equally be used as evidence of low competencies in the field of internationalization. Polish universities compete with dozens of other universities in the region and beyond in international markets. To provide a reliable picture of the situation, analogous statistics should be presented for the most internationalized universities in Europe, such as in Germany, France, the Netherlands, or Italy, and then such comparisons should be made.

It is worth noting that the list also includes four public universities with long traditions, namely universities from Warsaw, Krakow, and Poznań. How should their position in this ranking be interpreted against the background of other universities? To summarize, the statistical data presented in the first two tables of the White Paper do little to contribute to an objective understanding of the undoubtedly necessary debate on the internationalization of Polish higher education. These data completely abstract from international statistics – the recipient of this document does not know how to interpret the data – the only interpretation is the one imposed by the Ministry in the document – this interpretation is not reliable. Table 3 presents the number of students studying in other EU countries, and these numbers are much higher than for Poland.

Table 3. Number of foreign students in selected European countries

Country	Number of foreign students	Source
Germany	458,210	https://www.mavenconsultingservices.com/article/top-10-european-countries-for-international-students-where-should-you-study/
France	412,000	https://www.studies-overseas.com/news/france-welcomes-412000-international-students
Spain	224,080	https://monitor.icef.com/2024/02/new-policies-erasmus-and-booming-tourism-boost-spains-international-education-sector/
Netherlands	123,000	https://longreads.cbs.nl/the-netherlands-in-numbers-2023/where-do-international-students-in-the-netherlands-come-from/#:~:text=Nearly%20123%20thousand% 20international%20students,vocational%20college%20(HBO)%20students.&text=University%20and%20vocational%20college%20students,a%20bachelor’s%20or%20master’s%20degree.
Italy	109,681	https://erudera.com/statistics/italy/italy-international-student-statistics/

In the further part of the White Paper, it is stated that the Polish visa is “easily accessible and relatively cheap.” Since detailed statistics on the number of students in Polish universities are presented, it would be worthwhile to also present this thesis in the form of a table/ranking of the “cheapest visas” and show what the position (price) of the Polish visa is compared to other countries to prove the thesis that one of the reasons why Poland is an attractive country for immigrants is the low price of the visa compared to other countries.

The existence of alleged “dishonest intermediaries” is an abuse because:

1. The operation of intermediaries in obtaining a visa is a widespread practice in many countries around the world and has its justification in terms of the economics of the functioning of the diplomatic service;
2. Having the status of an intermediary should not automatically stigmatize every intermediary as dishonest. The concept of “intermediary” should be separated from “dishonest intermediary.” Honest intermediaries act in favor of our country because they help reduce transaction costs between the applicant and the Polish state. The alternative would be to maintain additional highly paid officials delegated from Poland in Polish foreign missions, subsidize their stay with their families, business trips, and even that would not guarantee the complete elimination of corruption. The White Paper states about the “selective satisfaction of demands for speeding up the visa procedure.” However, it does not specify what types of visas these corruption phenomena concerned. Did they concern student visas or work visas? The issuance of a student visa takes place at the consulate level, and the university is not involved in this process in any way. All decisions to grant or not grant a student visa are made by the Polish diplomatic service without consulting the host university. Therefore, it is an abuse to suggest that universities are involved in the visa issuance process, let alone suggest that universities could be involved in corrupt processes when issuing student visas. Since this polemic mainly concerns aspects related to the internationalization of universities, and the Ministry’s document concerns both the labor market and the internationalization of universities, the analysis of potential corruption phenomena should be separated and indicate whether they also concerned the issuance of student visas – it can be assumed that this phenomenon did not concern student visas, especially since the earlier statements of the White Paper mention “too easy recruitment for studies in Poland.” Since recruitment was “too easy” (as can be assumed at the level of specific universities), there was probably no need for applicants to use corrupt methods (at the diplomatic service level). This, in turn, leads to the suggestion to the Ministry to clearly indicate that corruption in issuing visas did not concern student visas or, if the Ministry has evidence of this, to specifically indicate which universities accepted students who used corrupt methods to obtain a student visa in Poland.

At the end of the White Paper, nine recommendations of measures are listed – the first four refer strictly to the labor market, and the remaining five concern higher education:

• Ad. Conducting mandatory pre-selection of foreign students – such a requirement strikes at the autonomy of higher education institutions, which is one of the foundations of the education system in Poland. In Poland, there are several hundred universities with extremely diverse profiles, local conditions, and histories. These universities have different development strategies, conduct research in various scientific disciplines. This, in turn, implies the need to adapt the functioning conditions of these universities to local requirements. Recruitment criteria are usually set by the Senate of a given university, and depriving senators of these powers can be seen as a violation of the autonomy of higher education institutions in Poland.
• Ad. Not using minimal recruitment criteria – the likely source of this recommendation is the detection of pathologies in the recruitment of students for studies in Poland by a few universities. Collective responsibility should not be applied but consequences should be drawn against specific universities and individuals responsible for the occurrence of pathological phenomena. The vast majority of universities in Poland use reliable recruitment criteria. If the Ministry’s recommendations are implemented, many new problems will arise regarding what exactly these criteria should be, given the diverse profiles of various universities. Should a medical university apply the same criteria as a small higher education institution in a former provincial city teaching sociology or physiotherapy? Centralization of solutions regarding education always entails many new problems because education is an area of the economy that requires a particularly large degree of autonomy.
• Ad. Increased administrative costs of universities should be reflected in increased tuition fees – in Poland, there is a belief that studies in our country are significantly cheaper than in the countries of the so-called “Old Union,” which is not true. In countries with significantly higher per capita income (e.g., the Netherlands), which is also reflected in university personnel costs, tuition fees for one year of study amount to about 3000-4000 €, which is only slightly lower than for comparable studies at good Polish universities. The ongoing economic growth in our country also leads to the equalization of differences in wages between the “Old” and “New Union.” To summarize, the argument that Polish studies are significantly cheaper than in other countries is becoming less and less relevant year by year. Perpetuating the myth of cheap studies in Poland does not serve to build the reputation of our country as a place to study because we should emphasize the quality of our education system, not only operate with the criterion of tuition fees in the debate on the internationalization of higher education. Table 4 presents examples of tuition fees from European higher education institutions.

Table 4. Examples of tuition fees from European universities.

School	Average tuition fee per year of study (Euro)	Number of foreign students at the university	Source
KU Leuven (Belgium)	2,505	14457	https://feb.kuleuven.be/eng/prospective-students/bachelor-of-business-engineering/overview
Autonomous University of Barcelona ( Spain )	3000-4500	10000	https://www.uab.cat/web/estudiar/ehea-degrees/general-information/bioinformatics-uab/upc/ub/upf-1216708259085.html?param1=1345910563150
University of Amsterdam (Netherlands)	2530-4000	13800	https://www.uva.nl/en/education/fees-and-funding/tuition-fees/tuition-fees.html?cb
Heidelberg University (Germany)	3000	5546	https://www.uni-heidelberg.de/en/study/management-of-studies/semester-fees/tuition-fees-for-international-students
Technical University of Munich ( Germany )	0-4000	23422	https://www.tum.de/en/studies/fees/tuition

• Ad. Centralized Pre-selection System for Foreign Candidates – It is not true that in Germany (DAAD) there is an operator of a centralized system for the pre-selection of foreign candidates for studies. The German Academic Exchange Service (DAAD) only performs certain specific verification tasks, such as checking the authenticity of diplomas, but it does not control the language competencies of students. This responsibility lies with the German universities. In the United Kingdom, there is a certain centralized system, but ultimately each university is responsible for setting its own recruitment criteria.
• Ad. Consideration of Restricting Access of Foreign Students to the Polish Labor Market – This is a justified recommendation, however, the current legal system addresses this need. It should be noted that the activity of students at the university and their student status is checked by the Voivodeship Office during the procedure for issuing a residence card. A student who drops out of studies loses the right to work. In many European countries, foreign students can legally work up to 20 hours a week, which is a compromise between regulating labor market access and meeting the needs of employers and students. In the case of Poland, a potential compromise in this area could primarily concern students studying at the first degree (Bachelor’s) level and should be developed in consultation with employers. However, introducing a deposit system, where a student is required to have an account with a blocked minimum amount of required funds, is a concept fraught with many negative consequences. Firstly, this amount would have to be somehow related to the income level in the country of origin. If this amount were uniform for all students, it would be a form of discrimination, as students, particularly from countries of the former Soviet Union, could face an insurmountable financial barrier. The European Commission’s plans to expand the EU to new countries would be in direct conflict with this deposit system, as it would financially discriminate against students from countries seeking accession.

In conclusion, this document provides a comprehensive response to the theses and suggestions contained in the Ministry of Foreign Affairs’ White Paper. Many of these theses are based on journalistic arguments that are not confirmed by facts and figures. Ensuring the security of the state and the rule of law in the area of higher education is also in the interest of the vast majority of Polish universities and it is unjustified to present them as agents of negative processes. On the contrary, Polish universities are concerned with maintaining the highest standards in the internationalization of higher education in Poland. The development of new solutions and innovations should take place within the framework of a substantive debate based on facts and evidence.

About the author:

Prof. Dr. hab. Jan Fazlagić from the University of Economics in Poznań specializes in intellectual capital issues, knowledge management, education internationalization, and local government management. He is a member of the Steering Committee that developed the assumptions for the new Higher Education Law (Law 2.0) at the Allerhand Institute. He is the Vice-President of the Association for the Internationalization of Polish Universities (APUI) and an expert of the European Commission (Lead Expert in the URBACT III program of the European Commission).

He authored the first doctoral dissertation (2001) and the first habilitation thesis in Poland on knowledge management in the service sector. He also authored the first report on the intellectual capital of universities in Poland (2004). He has extensive experience in implementing numerous European projects in the field of education and intellectual capital development. He is a member of the Think Tank at the President of the City of Poznań. He is the author of over 300 scientific and popular science publications, including 15 books, such as “The Handbook of the Innovative Local Government Official,” recognized as one of the best books of 2018.

About APUI:

APUI stands for the Association of Polish Universities for Internationalization. It is a non-profit organization founded in 2017 to support the internationalization process of Polish higher education institutions. APUI acts as a representative body bringing together Polish universities and facilitating their international cooperation and attracting foreign students. The key goals of APUI are to promote Polish universities on the international stage, increase student and academic staff mobility, and develop programs taught in foreign languages, particularly English.