What is local counsel and when does a Swedish law firm need a Polish advocate?

Providing legal services in cross-border matters requires a precise combination of knowledge of the client’s legal system and practical familiarity with the procedures applicable in the relevant jurisdiction. When a Swedish business or law firm faces a legal matter before a Polish court or authority, the support of an experienced Polish advocate can be essential. In this context, the Polish advocate acts as local counsel: a legal advisor who handles the Polish legal and procedural aspects of the matter, while allowing the Swedish law firm to maintain its direct relationship with the client. In this article, you will learn how this cooperation works in practice and when the support of local counsel becomes necessary.

Let’s discuss cooperation based on the local counsel model in Poland.

TL;DR – What is local counsel?

• The key point: The role of local counsel allows a Swedish law firm to remain the client’s primary advisor and retain control over the client relationship, while entrusting the Polish legal and procedural aspects of the matter to a Polish advocate.
• In practice: Delegating the Polish part of a matter to local counsel reduces the risk of procedural errors in proceedings before Polish courts and administrative authorities.
• Who is it for? Swedish law firms, business advisors and companies handling cross-border matters involving Poland.
• The benefit: Local procedural support in Poland, better cost control and efficient handling of the matter without having to transfer the entire mandate to a large international law firm.
• Last updated: 10 October 2026

What is local counsel and what role does a Polish advocate play in a cross-border dispute?

The term local counsel does not refer to a separate professional status under Polish law. Instead, it describes a functional B2B role commonly used in international legal transactions. In practice, this model involves cooperation in which the Swedish law firm coordinates the client’s overall strategy, while the Polish advocate acts as a local legal and procedural expert. The Polish advocate handles matters requiring knowledge of local case law, language, court practice and the requirements of Polish civil or commercial proceedings. Where necessary, local counsel can also support the Swedish partner in assessing legal risks, conducting negotiations and developing an appropriate strategy for the Polish aspects of the matter.

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Scope of work and operational standards of local counsel

The main tasks performed by a Polish advocate acting as local counsel include analysing Polish law and local legal risks, reviewing legal and business documentation, supporting strategy development, preparing court submissions and representing clients before Polish courts.Local counsel may also assess the enforceability of a future judgment in Poland and coordinate communication with Polish courts, enforcement officers, public authorities and counterparties.

The cooperation is based on clear operational standards:

• Confidentiality and conflict checks: potential conflicts of interest are checked immediately upon receipt of an initial enquiry.
• Working language: day-to-day communication, reports and analyses are prepared in English or Swedish.
• Transparency of the relationship: the Polish advocate reports directly to the Swedish law firm without interfering with its relationship with the end client.

This structure ensures an efficient flow of information and confidentiality, while allowing the Swedish law firm to remain the client’s primary advisor and main point of contact.

Legal basis for representation and limits of authority

Cooperation with a Polish advocate is governed by the Polish Law on the Bar, which provides for professional secrecy and professional independence.

Under the Polish Code of Civil Procedure, formally submitting court submissions and appearing before Polish courts requires the relevant professional qualifications of an advocate or legal counsel. The Polish Act on the Provision of Legal Assistance by Foreign Lawyers defines the scope within which Swedish lawyers may practise independently in Poland.

In the context of commercial agreements and determining court jurisdiction, EU regulations also play an important role. These include the Brussels I bis Regulation (EU No 1215/2012), which governs jurisdiction and the recognition and enforcement of judgments, and the Rome I Regulation (EC No 593/2008), which determines the law applicable to contractual obligations.

You can read more about this here:

• EUR-Lex – Directive 98/5/EC on practising law in another Member State.
• EUR-Lex – Brussels I bis: jurisdiction and enforcement of judgments.
• EUR-Lex – Rome I: law applicable to contractual obligations.

What are the billing models and how much does it cost to work with a business lawyer in Poland?

The cost of working with a business lawyer depends on the billing model, the complexity of the matter and the course of the proceedings. In B2B relationships between law firms, flexible billing arrangements are used to reflect the scope of the engagement and the Swedish client’s budget.Fees and billing terms are agreed before the cooperation begins to ensure cost transparency and avoid unexpected expenses.

Below is an overview of the most common billing models used in local counsel arrangements: 

Worth reading:

• CCBE – guidance on foreign counsel instructions and responsibility for fees.
• Swedish Bar Association – professional conduct, fees and client loyalty.
• European e-Justice – legal representation and litigation costs in Poland.

When does a Swedish advisor need a Polish advocate?

A local specialist should be brought in when a matter requires the application of Polish law, an assessment of local legal risks or knowledge of Polish procedural requirements. Hans Corell, a distinguished Swedish lawyer and former Legal Counsel of the United Nations, has emphasised the importance of cooperation between lawyers working in an international environment. In cross-border practice, such cooperation combines the strategic perspective of the law firm leading the matter with local knowledge of the law, procedural rules and legal culture.

Typical situations in which the involvement of local counsel becomes particularly important include:

1. Litigation with a Polish counterparty: bringing a claim before a Polish commercial court or defending against an unjustified claim.
2. Securing assets in Poland: obtaining an urgent court order to secure the debtor’s bank accounts or real estate.
3. A dispute between shareholders in a Polish company: handling a conflict within a Polish company in which a Swedish entity holds shares.
4. Enforcement of a Swedish judgment: taking the necessary steps to have a Swedish judgment recognised or enforced in Poland and coordinating enforcement proceedings with a Polish enforcement officer.

In such matters, an experienced Polish local counsel can help identify the appropriate legal measures, reduce procedural risks and effectively protect the Swedish client’s interests in Poland.

Further information is available here:

• European e-Justice – securing assets and interim relief in Poland.
• European e-Justice – enforcement of court decisions in Poland.
• Chambers – Litigation 2026: Polish procedure and commercial disputes.

Step by step: How to establish cooperation with local counsel in Poland

If you represent a Swedish law firm or company and need ad hoc legal support in Poland, cooperation can be established in a few straightforward steps:

1. Send an outline of the case and the relevant documents: Provide the key documents and a description of the facts in English or Swedish.
2. Conflict check: The Polish advocate promptly checks for any conflicts of interest involving the parties to the dispute.
3. Agree on the scope and budget: Choose an appropriate billing model (e.g. a fixed fee per stage) and clearly define the division of responsibilities between the law firms.
4. Grant a power of attorney or substitution: Prepare the documents authorising the Polish advocate to act before Polish courts or public authorities.
5. Ongoing reporting: Receive concise updates after each procedural step or negotiation session, while retaining full control over the matter.

This model allows legal support in Poland to be put in place quickly, without unnecessary formalities or delays. At the same time, the Swedish law firm retains control over the strategy, budget and relationship with the end client.

Worth reading:

• CCBE – Code of Conduct for European Lawyers: cooperation and confidentiality.
• European e-Justice – finding a qualified legal professional.
• Government of Sweden – powers of attorney, certification and apostilles.

FAQ: What is local counsel?

What else should you know about the role of local counsel and when a Polish advocate may be needed?

When working within a  local counsel model, it is important to consider data protection requirements under the GDPR when exchanging procedural documents across borders. Secure document transfer and an efficient flow of information are essential to maintaining high standards of confidentiality. An experienced Polish advocate provides not only legal expertise but also established procedures for secure communication and document handling. This allows a Swedish law firm to offer its clients comprehensive cross-border legal support without the cost of establishing its own office in Poland.

Operational flexibility is also particularly important in urgent situations, such as securing evidence at short notice or conducting time-sensitive settlement negotiations. Familiarity with the business environment in both countries can help overcome linguistic and cultural barriers between Polish and Swedish counterparties. By combining the strategic expertise of Swedish lead counsel with the local knowledge and procedural experience of a Polish advocate, clients benefit from coordinated protection of their business interests. This approach also enables law firms to strengthen their cross-border capabilities in an international legal environment.

Worth reading:

• EDPB – securing personal data and confidential communications.
• EDPB – identifying controller and processor responsibilities.
• EUR-Lex – GDPR, including security of processing under Article 32.

Summary: What is local counsel and when does a Swedish law firm need a Polish advocate?

Local counsel is a locally qualified lawyer who provides a foreign law firm with legal support in accordance with the law and legal practice of the relevant jurisdiction. In Poland, this role may be performed by a Polish lawyer or advocate familiar with local court and administrative procedures.The involvement of local counsel is particularly useful when a matter requires an analysis of Polish law, an assessment of local legal risks and strategy, the preparation of procedural documents, representation before Polish courts or communication with local authorities. Polish local counsel can also assist Swedish counsel with securing claims, negotiations and the enforcement of judgments.This model allows a Swedish law firm to handle matters in Poland efficiently while retaining control over the overall strategy and its relationship with the client.

If you represent a Swedish law firm or company and are looking for a trusted partner in Poland under a local counsel model, please contact me to discuss how we can work together. Visit kowalicki.com to find out how we can work together to protect your client’s interests and support their business objectives in Poland.