
The purpose of this study is to present the most significant procedural proposals included in the draft Act amending the Act of 5 July 2018 on the national cybersecurity system, which aims to align Polish law with the requirements of the NIS2 Directive, and to evaluate these proposals from the axiological perspective of administrative procedure. The paper primarily highlights solutions that constitute a normative novelty or represent a departure from the classical jurisdictional model of administrative proceedings as regulated by the Code of Administrative Procedure. Particular attention is devoted to such proposed measures as: the application of simplified procedures to ex officio proceedings; the issuance of automatically generated decisions imposing financial penalties; the exclusion of the Code definition of a party in proceedings concerning recognition as a high-risk supplier and the introduction of a new category of entity granted party rights; the selective delivery of notifications regarding the initiation of proceedings in cases concerning high-risk supplier recognition, the exclusion from participation in the taking of evidence and the publication of such decisions; the exclusion of the possibility to challenge the position taken by a cooperating authority under Article 106 of the Code of Administrative Procedure; the extension of the enforceability of decisions on recognition as a high-risk supplier; the exclusion of the principle of two-instance administrative proceedings; the problem of illusory judicial-administrative review; and the protective order as a general administrative decision.