Rethinking R&D Centers: Is CBR status still worth it?

The Ministry of Development is turning its attention to another component of the ecosystem designed to boost the innovativeness of Poland’s economy. Following the launch of consultations on a new startup strategy, the time has come to evaluate the system of R&D tax incentives.

We have already written about the new startup strategy being prepared by the Ministry of Development in close cooperation with the startup ecosystem. One of the cornerstones of building an innovation market in Poland is the development of a modern research and development base. That is why, in parallel with work on the startup strategy, the ministry intends to take stock of the current model of support for companies engaged in R&D activity.

The Ministry to review the instrument

The ministry intends to carry out an evaluation of R&D Centers (CBRs—Centra Badawczo-Rozwojowe). These are companies engaged in research and development that have been granted a special status by ministerial decision under the Act on Certain Forms of Supporting Innovative Activity.

Why does this rather cumbersome “affiliation” matter? Because while many companies and institutions conduct R&D in Poland, only a small number hold CBR status. The government therefore wants to assess how the market views this instrument and to decide what its future should be.

In March, the ministry plans to announce a tender and select a firm to prepare a comprehensive evaluation of the scheme.

“We want to hear from entities that already hold CBR status – how these solutions are working today and what, in their view, should be improved. From companies that also conduct R&D but do not have CBR status, we want to learn what would need to change for them to take an interest,” says Zbysław Ziemacki, Director of the Department of Innovation and Space Policy at the Ministry of Development and Technology.

The ministry also aims to assess the effectiveness, durability, and efficiency of the CBR framework through the lens of the benefits gained by entities that have made use of their R&D services.

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The core question: What do we get from CBRs?

The fundamental question the Ministry of Development and Technology (MRiT) must ask itself is straightforward: what is the purpose of R&D Centers (CBRs) today as a separate category of entities conducting research and development?

When the concept was introduced – nearly 20 years ago, alongside the 2008 Act – there were few companies in Poland capable of carrying out the research needed for growth on their own. CBRs were meant to fill that gap. One of the conditions for obtaining CBR status was the provision of services to third parties. In return, the centers could benefit from more generous tax relief than other companies investing in R&D.

Today, the market looks very different. Research and development activity is carried out by far more entities than just the CBRs listed in the government register. The ministry is well aware of this shift. Hence the need to evaluate the instrument and to answer the question of whether, in its current form, it still delivers the objectives for which it was originally introduced, as emphasized by Zbysław Ziemacki, Director at the Ministry of Development and Technology.

Outside large corporations, most companies still do not even have in-house research units. Without any form of potential access to R&D, many will not attempt to move up the development ladder at all. Of more than 2.8 million business entities operating in Poland, nearly 96 percent are microenterprises. Data from Statistics Poland show that 99 percent of companies in Poland report no R&D activity whatsoever. Such activity is extremely concentrated in a narrow group of just 7,000–8,000 leaders.

This leads to a fundamental question: can R&D Centers (CBRs) realistically make a difference?

Others get the same support

At the end of January this year, just 58 companies in Poland held CBR status. Only 58. The list includes, among others, Asseco Data Systems, CD Projekt, Ryvu Therapeutics, Selvita, KGHM Cuprum, Techland, and GSK Commercial. Most, however, are much smaller entities. In just six months, the list has shrunk by three companies.

Why, then, are large investors – spending tens or even hundreds of millions of zlotys on R&D in Poland – not interested in CBR status? Samsung, which values its investments in Poland to date at around USD 2 billion, has never applied for CBR status.

“It does not create benefits for this type of large-scale corporate investment,” writes Olaf Krynicki, spokesperson for Samsung Poland, in a written comment.

Assessments from our interlocutors suggest that, in practice, tax relief available to CBRs and to other entities conducting R&D has largely converged. Whether research is carried out for a company’s own needs or on behalf of third parties, the level of public support today is very similar.

“Existing regulations provide such extensive support that we are satisfied with it and see no need to look for alternative options,” says Przemysław Zakrzewski, Director of the Corporate Technology Center at ABB in Kraków.

Without tangible benefits?

As part of changes covering the entire R&D sector in Poland, the cap on eligible costs related to remuneration of employees engaged in R&D has been raised to 200 percent for all taxpayers. In practice, this largely aligns the deductions available to ordinary companies with those previously reserved for CBRs, as payroll costs typically account for the largest share of R&D project budgets.

As a result, the tax advantage associated with holding CBR status has to a large extent been diluted.

Demonstrating the 20 percent revenue threshold from R&D activity required to obtain CBR status often demands real contortions on the company’s side – especially when R&D is not its core commercial activity.

“Proving the required 20 percent share of revenue from R&D to obtain CBR status often requires genuine gymnastics, particularly if R&D is not the company’s main line of business. In a typical manufacturing company, the R&D department primarily generates costs, while revenues – if they appear at all – account for a fraction of a percent of total turnover,” says Tomasz Stypułkowski, CEO of the Institute of Innovation and Technology, a special-purpose vehicle of Bialystok University of Technology operating with CBR status.

CD Projekt is satisfied…

Despite these limitations, CD Projekt, one of Poland’s most recognizable game developers, continues to make use of CBR status and has no plans to give it up.

“Access to the R&D tax credit for entities conducting R&D in Poland is currently broad. Both the definition of R&D activity and the catalogue of eligible costs that can serve as the basis for a tax deduction have been expanded. In the case of CBRs, this catalogue has been extended even further and includes, among other things, the costs of expert opinions or advisory services,” says Adam Korgul, a director in CD Projekt’s tax team.

…But also points to what needs to change

Adam Korgul points to the same issue raised by the head of the university spin-off – and one that may effectively discourage many companies from applying for CBR status in the first place.

“The difficulty is that the provision allowing CBRs to benefit from an expanded catalogue of eligible costs is unclear and complex. In practice, classifying some expenses required us to obtain an individual tax ruling, and ultimately it was only court proceedings that confirmed the possibility of deducting the costs of certain services,” Mr. Korgul says.

As he emphasizes, these ambiguities constitute a real barrier for companies that might otherwise consider applying for CBR status but are unable to clearly assess what tangible benefits it actually brings. This is precisely the area that could be addressed first if the public authorities decide they want to maintain and further develop the CBR framework as part of the innovation support system.

It is also worth noting that CD Projekt does not provide R&D services to other companies – further illustrating how far the role and rationale of CBR status have evolved compared with the original assumptions made more than a decade ago.

When the tax break isn’t worth revealing your hand

Arguments against applying for CBR status are often non-tax-related. The process of obtaining or renewing CBR status repeats annually. It requires a significant investment of work – sometimes involving multiple staff members – and the disclosure of information that companies consider sensitive. Firms are reluctant to reveal too much about their operations, especially if they do not see a clear benefit.

“For large, reputable, and efficiently run companies, the tax advantage alone can be too small to justify the need to disclose detailed financial data. Not every company wants to reveal what they have ‘inside.’ Maintaining CBR status requires, to some extent, the disclosure of substantive information – for example, about ongoing R&D activities or how they are conducted,” says Tomasz Stypułkowski.

This risk is often compared to the patenting process, which requires revealing the essence of an invention.

“Many Polish companies struggle with such far-reaching disclosure,” adds Mr. Stypułkowski.

No bonus for the effort

Companies that have obtained CBR status – which in itself is no small feat – also point to the lack of additional benefits in state-run competitions for grants and subsidies supporting innovation.

“On the one hand, the state expects our work to add value to the development of the entire economy. On the other hand, when it comes to public competitions, we practically do not count. The National Centre for Research and Development (NCBR) may not recognize a CBR as a research entity because we are not subject to the same evaluation as scientific institutions, such as universities, research institutes, or the Polish Academy of Sciences,” says the head of a laboratory in Małopolska, speaking on condition of anonymity.

Similar conclusions emerge from conversations with other companies conducting R&D. Holding CBR status rarely provides any tangible advantage.

“As a CBR, we have practically received nothing beyond what any R&D company operating in the market gets. We have not participated in any public project as a research partner. CBRs remain largely invisible to most institutions funding cooperation between science and business,” emphasizes Tomasz Stypułkowski.

Preferences reserved for CBRs

CBR status signifies confirmed, formally verified R&D activity. In other words, these are not “shell companies” designed to churn through subsidies, but entities with real research capabilities and proven teams.

As CD Projekt’s legal counsel emphasizes, if CBR status were additionally rewarded in evaluations, it could become a tangible asset.

“Introducing this type of additional preference for CBRs could positively influence how companies perceive the scheme,” says Adam Korgul.

He also believes a proposal already discussed in debates on strengthening innovation support in Poland is worth reconsidering.

“Because not all sectors are highly profitable – or profits are spread over time – it would be worthwhile to introduce a mechanism allowing the R&D tax credit to be compensated in ways other than reducing tax liability. Specifically, a system in which a credit unused in a given year – or over several years – due to insufficient income would be refunded to the taxpayer in cash,” Mr. Korgul explains.

He adds that this could be an additional benefit reserved exclusively for CBRs. Such a solution would encourage companies to increase R&D spending while limiting the risk associated with unsuccessful research projects.

“It’s a model that works successfully in other jurisdictions, such as Germany or France,” emphasizes Mr. Korgul.

Don’t throw the baby out with the bathwater

Why maintain an instrument that attracts so little interest? The answer is simple: it still supports R&D, and any form of backing that develops this sector in Poland is valuable. According to the latest data from Statistics Poland (GUS), R&D spending in Poland has declined. On the European TOP800 list of the largest R&D investors, only three Polish companies appear – one of them being CD Projekt.

International corporations are unlikely to be interested in providing R&D services on demand for the market. Large domestic companies, however, could do so more willingly, for instance within sectoral clusters. To achieve this, they need more flexible rules.

A sales rep needed immediately

The evaluation could result either in the elimination of the instrument or in the expansion of its preferences. Maintaining CBR status will make sense only if the state offers new incentives while simultaneously setting clear requirements. What these should be is exactly what the ministry hopes to discover through the planned evaluation contract.

Several of our interlocutors proposed the same idea: CBRs need to be more active in securing new contracts. Universities are already expected by the state to actively promote their research work. This promotion is meant to lead to the real transfer of knowledge to business – through licenses, patents, and revenue. Achieving this requires a more proactive role for knowledge brokers. A similar model could apply to CBRs.

“The service broker has to operate a bit like a traveling salesman: going door to door with an offer that brings companies tangible, real benefits. CBRs must advertise themselves, but the government has to clear the way for them,” says the head of a laboratory in Małopolska.

Not everyone will like this approach. Yet it can be the most effective, as noted in an interview with XYZ by the head of a university spin-off at Nicolaus Copernicus University.

“We do not turn down any opportunity for good cooperation with business. One day I’m talking about space, the next I’m at a meeting in rubber boots on a farm,” says Alina Jaworska, CEO of Startova, a university spin-off of UMK responsible for transferring innovations to the market.

In light of the decline in R&D spending reported by Statistics Poland in December 2025, it is clear that Poland still has much ground to make up in this area. In 2024, only about 0.25 percent of all companies operating in the country conducted formalized R&D. Among large firms (over 250 employees), fewer than half – around 48 percent – had dedicated R&D structures, even though the vast majority declared that they carried out innovation activities.

Key Takeaways

1. Recommendations and the Future. Market practitioners propose, among other measures, awarding additional points to CBRs in grant competitions, allowing unused R&D tax credits to be refunded in cash, and more actively promoting the services offered by CBRs. The evaluation, set to begin in March, will determine whether the instrument will be strengthened, restructured, or phased out.
2. Evaluation of R&D Centers. The Ministry of Development is launching a comprehensive assessment of the status of R&D Centers (CBRs). Following the start of consultations on a new startup strategy, the ministry aims to evaluate the effectiveness, durability, and appeal of this instrument. A tender for the evaluation is scheduled to be announced in March. The report will also assess the benefits that clients derive from working with CBRs.
3. Has CBR Status Lost Its Appeal? Introduced nearly two decades ago, CBR status was designed to offer higher tax relief for conducting and providing R&D services. Today, however, tax benefits available across the R&D market are largely similar, while CBRs must meet additional obligations, including annual reporting. CBRs are also not favored in grant competitions. Large companies, such as Samsung and ABB, show little interest in the status, and some current CBRs are considering giving it up.