Is a District Construction Supervision Inspector a PEP?
Short answer: no. The Powiatowy Inspektor Nadzoru Budowlanego (district construction supervision inspector) is appointed by the starosta and heads an office subordinate to him, not a field office of special government administration or a central body. The position is therefore not on the PEP list.
The national Główny Inspektor Nadzoru Budowlanego, on the other hand, is a PEP.
The legal test
The 2021 regulation (Dz.U. 2021 poz. 1381) lists as PEPs the national chief inspectors and their deputies, including the Główny Inspektor Nadzoru Budowlanego (item 73) and their deputy (item 74). It also lists general directors and heads of field offices of special government administration.
What it does not list is the powiat-level construction supervision office. The reason is structural. Under the Construction Law, the higher-level authority for the district inspector is the voivodeship construction supervision inspector, and the district inspector is appointed by the starosta from at least three candidates proposed by the voivodeship inspector. The office is tied to the powiat, an organ of local government rather than central government.
Why that matters
A PEP position, in this context, is a national or special-administration role, or a directly elected or government-appointed high office. An office appointed by and reporting to a local authority does not meet that test. The same logic that keeps the district inspector off the list keeps other local officials off it, except where the regulation names them explicitly.
A note on local officials
Since the 2021 regulation, several local positions are explicitly PEPs, including wójt, burmistrz, prezydent miasta, their deputies and starosta. So “local” is not automatically “not a PEP”. The only reliable test is whether the specific position appears on the list.
Screening in practice
This granularity is exactly why automated screening helps. A tool carrying the current PEP list applies the right rule to each position. Hyperflow exposes PEP screening through an API so that onboarding and periodic checks run without manual list reading.
UK perspective
Similarly in the UK, PEP status follows the function, not the office name. The Money Laundering Regulations 2017 set out the public functions that count, and the FCA expects enhanced due diligence where a person falls within them.