Is the WITD (Voivodeship Road Transport Inspector) a PEP?
Short answer: no. The Wojewódzki Inspektor Transportu Drogowego (WITD, voivodeship road transport inspector) heads an office of integrated government administration that reports to the voivode, and is not on the PEP list. The national-level Główny Inspektor Transportu Drogowego, by contrast, is a PEP.
The distinction between integrated and special government administration is the key to most of these questions.
Integrated versus special administration
Territorial government administration in Poland is split into two branches:
- Integrated administration is subordinate to the voivode. Its heads are not PEPs.
- Special (non-integrated) administration is subordinate directly to a minister or a central body, not to the voivode. Its heads are PEPs.
The 2021 regulation (Dz.U. 2021 poz. 1381) makes this concrete. It lists the national inspectorates as PEP positions, including the Główny Inspektor Transportu Drogowego (item 83) and their deputies (item 84), but it does not list the voivodeship-level inspectors.
Where the WITD sits
The voivodeship road transport inspectorate is part of the integrated services, inspections and guards headed by the voivode. Because the WITD is not a head of a field office of special administration, and is not named in the regulation, the WITD is not a PEP.
For completeness, other integrated administration heads that are likewise not PEPs include the voivodeship police commander, the voivodeship fire service commander, the education superintendent, the voivodeship sanitary inspector, the voivodeship veterinary officer and the voivodeship monument conservator.
Where the line is drawn
Heads of special administration that are PEPs include, among others, the directors of tax administration chambers, tax office heads, directors of regional mining offices, directors of statistical offices, directors of maritime offices, regional directors for environmental protection, and the national chief inspectors.
The counter-intuitive result is that the voivodeship environmental protection inspector is not a PEP, while the regional director for environmental protection is.
Screening in practice
Because the rule turns on administrative structure rather than on job title, manual assessment is unreliable. A screening service that carries the current PEP list applies the distinction for you. Hyperflow offers PEP screening through an API so the check can run automatically.
UK perspective
The UK approach is function based rather than structural. The Money Laundering Regulations 2017 list senior public functions, and roles comparable to the Polish voivodeship inspectors are assessed against that list rather than against administrative subdivisions.