SecProbe.io

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October 21, 2022

VIA EDGAR

    United States Securities
    and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn:
    Katherine Hsu

    Michael Coco

    Re:
    State Treasury of the Republic of Poland

    Schedule B filed on September 6, 2022

    File No. 333-267287

Dear Ms. Hsu and Mr. Coco:

On behalf of our client,
the State Treasury of the Republic of Poland (“Poland”), we are writing to submit Poland’s responses to the
comments of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Staff”)
with respect to the above-referenced Registration Statement under Schedule B filed on September 6, 2022 (the “Registration
Statement”), contained in the Staff’s letter dated September 30, 2022 (the “Comment Letter”).

Poland has filed Amendment
No. 1 to the Registration Statement under Schedule B (“Amendment No. 1”) via EDGAR, which reflects Poland’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below in bold and is followed by Poland’s response. All page references in the responses set forth
below refer to page numbers in Amendment No. 1.

Schedule B

The Economy,
page 15

 1. We note your disclosure that certain
                                            data are not entirely comparable to 2021 data due to changes in methodology. To the extent
                                            possible, describe the change in methodology and/or the material impact that such change
                                            would have on the more recent data.

Response:
Poland calculates its unemployment rates and other data on the labor force in accordance with the methodology of the European Union Labor
Force Survey (“LFS”). In 2021, the LFS introduced methodological changes that amended the definitions of employed,
unemployed and economically inactive persons in order to increase data quality and comparability across European Union member states.

For example, under the new methodology,
the term “employed population” includes:

 ● unpaid
                                            family workers  performing work for family members not belonging to their own households
                                            (conducting economic activity outside agriculture or private agricultural farms);

 ● persons
                                            performing some of their work off-season; and

 ● persons
                                            having a job, albeit not performing work in the reference week (in case of the reasons for
                                            some absences— simplifying the criteria for classifying persons as employed,
                                            e.g., including persons taking childcare leave).

Under
the new methodology, the employed population excludes self-employed persons employed in private agriculture
who allocate the effects of their work exclusively or mainly for their own consumption and do not have any other job. In
addition, for data from 2021 onwards, the reference population changed from people aged 15 years and over to people aged from 15 to 89
years.

    United States Securities and Exchange Commission

October 21, 2022

Following the implementation of these
methodological changes, Poland recalculated its labor force data for the years 2010 to 2020 in accordance with the LFS methodology in
force from 2021. Therefore, all LFS data from 2010 onwards is comparable. However, Poland has not re-calculated pre-2010 LFS data. Therefore,
pre-2010 LFS data is not comparable with post-2010 LFS data, although the change in methodology has not had a material impact on labor
market data.

Poland has clarified these points in
brief in the footnote to the macroeconomic statistics table on page 16 of Amendment No. 1.

Meeting of
Holders of Debt Securities; Modification, page 63

 2. On page 64, the prospectus discusses
                                            certain types of collective action clauses. Please identify the collective action clause
                                            provisions under a separate caption or refer to the collective action clauses in the current
                                            caption.

Response:
In response to the Staff’s comment, Poland has changed the heading from “Meetings of Holders of Debt Securities; Modification”
to “Collective Action Clauses” and added references to the section of the Fiscal Agency Agreement that contain collective
action clause provisions on page 63 of Amendment No. 1.

Exhibits, Legal
Opinion, Page II-4

 3. We note your representation in Part II
                                            that the issuer agrees to furnish a copy of the opinion of the Director of the Legal Department
                                            of the Ministry of Finance, Republic of Poland as to the legality of each issue of the securities.
                                            Please confirm to us that you will file clean legal opinions of all relevant parties as to
                                            the legality of the issue of the securities at the time of each takedown.

Response:
Poland confirms that it intends to file clean legal opinions of all relevant parties as to the legality of the issue of securities at
the time of each takedown.

 General

 4. To the extent possible, please update
                                            all information and statistics in the registration statement to provide the most recent data
                                            possible. This may include, for example, your use of "preliminary data" throughout
                                            the prospectus

Response:
In response to the Staff’s comment, Poland has updated all information and statistics in the Registration Statement for which more
recent data was available. The information currently included in Amendment No. 1 is based on the most recent data available.

Please
do not hesitate to contact Jill Concannon (Tel: +44 20 7532 1534; E-mail: jill.christie@whitecase.com) or Doron Loewinger (Tel:
+44 20 7532 1551; E-mail: doron.loewinger@whitecase.com) of White & Case LLP with any questions or comments regarding this letter.

Sincerely,

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    United States Securities and Exchange Commission

October 21, 2022

/s/ White & Case LLP

White & Case LLP

cc:
Sebastian Skuza, Secretary of State of the State Treasury of the Republic of Poland

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