Between Conservation and Utilization: Legal Frameworks Governing Crop Wild Relatives and Habitats Directive Species in Poland

Abstract

Ex situ plant conservation in Poland is shaped by a dual institutional framework that distinguishes between agricultural genetic resources and the protection of rare and endangered wild flora. The National Centre for Plant Genetic Resources (NCPGR) focuses on cultivated taxa and Crop Wild Relatives (CWRs), whereas the PAS Botanical Garden Seed Bank prioritizes wild species of high conservation concern, including those listed under the EU Habitats Directive (HD). This review examines the legal and institutional foundations of ex situ conservation in Poland within global and regional regimes (CBD, ITPGRFA, EU Habitats Directive) and analyzes a harmonized dataset of 1458 species. Comparative analyses show significant discrepancies in institutional holdings: CWRs are relatively well represented in the gene bank, whereas many HD species remain underrepresented, particularly those producing non-orthodox seeds that cannot be stored by conventional methods. Conversely, rare wild taxa maintained in the Seed Bank often fall outside agricultural genetic resource frameworks. The limited overlap between these collections highlights gaps in coordination, data integration, and methodological development. Strengthening institutional synergy, developing approaches for non-orthodox seeds, and enhancing international cooperation will be crucial for Poland to meet the goals of the Kunming–Montreal Global Biodiversity Framework and the Global Strategy for Plant Conservation.

1. Introduction

Plants represent the fundamental structural and functional basis of terrestrial ecosystems. They sustain primary productivity through photosynthesis, underpinning oxygen release, carbon sequestration, soil formation, hydrological regulation, and the stability of trophic networks. Beyond their ecological functions, plant diversity provides indispensable contributions to human well-being, encompassing food security, health, and cultural values [1,2]. Modern economic sectors—including agriculture, forestry, pharmacology, and biotechnology—remain critically dependent on the genetic and biochemical resources embedded in plant taxa, which constitute an irreplaceable reservoir of traits essential for adaptation and innovation [3,4].

In the face of accelerating climate change, habitat degradation, and increasing anthropogenic pressures, safeguarding plant diversity has become a global conservation priority. Crop Wild Relatives (CWRs) are of particular importance, as they represent unique reservoirs of allelic diversity that enhance crop resilience to biotic and abiotic stresses and contribute to yield stability, nutritional value, and climate adaptability [5,6].

CWR and species listed under the EU Habitats Directive (HD) together illustrate the dual challenge of conserving both genetic resources and threatened wild flora. While CWR occupy a transitional space between biodiversity conservation and agricultural use, HD species are legally protected for their ecological or biogeographical importance, even when not immediately at risk of extinction [7].

Despite their vital role, plant biodiversity is currently experiencing one of its most critical declines in history. Recent global assessments estimate that nearly 39% of vascular plant species may be threatened with extinction [8,9]. Similarly, approximately 30% of tree species worldwide are at risk [10], posing systemic risks to ecosystem structure and function. Alarmingly, projections indicate that as many as 75% of undescribed plant taxa may already face extinction before being formally documented [9]. Anthropogenic drivers such as habitat loss and fragmentation, overexploitation, invasive alien species, pollution, and climate change continue to accelerate biodiversity decline [2,11]. Focusing specifically on plant biodiversity, within just a few decades, the proportion of plant species at risk of extinction has increased from 20% to 40% of the estimated 380,000 vascular plant species currently recognized worldwide, representing the core of global terrestrial biodiversity [12]. Forward-looking conservation scenarios, including projections to the year 2080, indicate that up to 50% of Europe’s vascular flora may face extinction risk due to ongoing environmental change [13].

The effective conservation of plant diversity requires a comprehensive, multifaceted approach that integrates both in situ and ex situ strategies to address the complex and escalating threats faced by wild and cultivated plant taxa. In situ conservation is of particular importance, as it maintains species within their natural habitats and thus preserves the ecological and evolutionary processes that underpin their adaptive potential in the face of dynamic environmental change [5,14]. By allowing populations to persist and evolve under natural selection, this approach supports the maintenance of genetic diversity that may prove essential for future species adaptation and resilience to climate change [2,6]. Yet, in situ conservation alone is often inadequate, as habitat degradation, land-use change, and climate pressures can leave populations fragmented or extinct [11,15]. In such contexts, complementary ex situ strategies—including seed banks and gene banks—are indispensable for ensuring the long-term preservation of critical genetic resources [16,17]. Therefore, the development of an integrated conservation framework that effectively combines in situ and ex situ strategies is indispensable for securing plant diversity and sustaining both global food systems and ecosystem resilience.

At present, ex situ conservation is primarily undertaken by specialized institutions such as botanical gardens, arboreta, seed banks, and cryopreservation facilities [18,19]. These institutions curate a broad spectrum of plant genetic resources—including living collections, tissue cultures, seeds, and dormant propagules—thereby ensuring their accessibility for both long-term conservation and scientific research. Among these approaches, conventional seed banking has emerged as the most widely adopted and cost-effective method for safeguarding plant genetic diversity, with critical implications for food security, human health, and ecosystem sustainability [20,21]. Globally, it is estimated that approximately 1750 seed banks and gene banks are currently in operation, collectively securing between 50,000 and 60,000 wild taxa [21,22].

Legal Frameworks for Ex Situ Conservation in Poland

From a species and habitat conservation perspective, Poland is characterized by relatively high biotic and phytocoenotic diversity, particularly in regions with limited anthropogenic transformation. Poland’s native vascular flora includes approximately 2844 species, demonstrating high floristic richness within Central Europe. Nearly 30% of these taxa are classified as threatened [23,24]. Many of these taxa have been granted legal conservation or included in active conservation programs. Within the Polish territory, approximately 1458 taxa—including four subspecies—have been identified as CWRs, constituting a strategically important genetic pool for national and pan-European conservation and breeding programs [25]. These two groups partly overlap: many threatened taxa are simultaneously listed as legally protected, reflecting an attempt to integrate conservation law with risk assessment.

Plant diversity conservation in Poland is primarily guided by international agreements and the country’s commitments as a member of the European Union. Within this framework, a clear distinction is made between wild plant species, whose protection is embedded in nature conservation law and EU habitat directives, and cultivated species and Crop Wild Relatives (CWRs), which are safeguarded through strategies for the conservation of genetic resources and specialized institutional programs. These complementary approaches form the legal and institutional foundation for the long-term conservation of plant diversity, addressing both ecological integrity and agrobiodiversity.

At the global level, the importance of conserving plant genetic resources and wild flora has been formally recognized in key international frameworks, most notably the Convention on Biological Diversity (CBD) and the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA) [26,27]. The CBD, ratified by Poland in 1995, provides a comprehensive framework for biodiversity conservation across genetic, species, and ecosystem levels. Its Strategic Plan for Biodiversity 2011–2020 established the Aichi Biodiversity Targets, including Target 12 (preventing extinction of known threatened species) and Target 13 (maintaining genetic diversity of cultivated plants and their wild relatives) [28]. The CBD also launched the Global Strategy for Plant Conservation (GSPC), whose Target 8 called for at least 75% of threatened plant species to be conserved ex situ by 2020 [29]. Despite substantial progress in expanding ex situ collections, the Plant Conservation Report 2020 and Global Biodiversity Outlook 5 concluded that these goals were only partially achieved [29,30]. In response, the Kunming–Montreal Global Biodiversity Framework (2022) was adopted as the successor to the Aichi Targets, with a renewed focus on implementation, monitoring, and resource mobilization, as well as a reinforced emphasis on the conservation of CWRs [31].

A particularly significant legally binding instrument in the context of ex situ conservation of PGRFA is the ITPGRFA, adopted in 2001 under FAO auspices and entering into force in 2004 [26]. Beyond promoting conservation and sustainable use, the Treaty established a mechanism for the fair and equitable sharing of benefits arising from the use of PGRFA [32]. Its Multilateral System (MLS) of Access and Benefit-Sharing grants standardized access to a global pool of 64 key crops and forages (Annex I), governed through the Standard Material Transfer Agreement (SMTA). Species not included in Annex I fall under the scope of the CBD and ABS frameworks, with their exchange governed by bilateral agreements and the domestic regulations of the participating countries. By 2023, more than 6.4 million samples had been exchanged worldwide under SMTAs, underscoring the central role of the MLS in germplasm exchange [33]. Another important achievement of the Treaty is the Digital Object Identifier (DOI) system, developed under the Global Information System (GLIS) to enhance the traceability of genetic resources and their associated data. As of 2023, over 5.5 million DOIs had been assigned to PGRFA accessions globally [33], including thousands from Polish collections maintained by the National Centre for Plant Genetic Resources (NCPGR, IHAR-PIB), which also serves as the national focal point for the ITPGRFA. At the same time, Digital Sequence Information (DSI) has emerged as a central theme in international debates. Although DSI is not explicitly covered by the Treaty, its growing role in plant breeding and biotechnology raises complex legal and ethical questions regarding Access and Benefit-Sharing. Recent discussions within both the CBD and the FAO Commission on Genetic Resources for Food and Agriculture (CGRFA, 2025) [34] highlight the urgent need to establish equitable mechanisms for sharing benefits derived from the use of DSI [35,36]. The parallel development of the Cali Fund under the CBD (2025) is expected to influence the future architecture of the ITPGRFA, particularly in relation to the Benefit-Sharing Fund (BSF) and its integration with digital resource governance.

At the European level, the Habitats Directive (92/43/EEC) and the Natura 2000 network provide one of the most extensive regional frameworks for biodiversity conservation, safeguarding wild species and habitats, many of which are of key importance for maintaining plant diversity, including CWRs.

At the national level, the Constitution of the Republic of Poland (1997) [37] establishes the state’s overarching responsibility to safeguard the natural environment in accordance with the principle of sustainable development (Article 5) (Figure 1). This constitutional mandate is implemented primarily through the Nature Conservation Act of 16 April 2004 (as amended) [38], which provides the legal framework for the designation and management of protected areas, the protection of species, and the establishment and operation of ex situ institutions such as botanical gardens, arboreta, and gene banks. A key complementary instrument is the Regulation of the Minister of the Environment of 9 October 2014 on the protection of plant species [39], which sets out detailed provisions for species-specific protection, including restrictions on the collection, propagation, trade, and ex situ storage of threatened taxa. Additional legislation reinforces these measures, notably the Environmental Protection Law of 2001 (as amended) [40], and the Regulation of the Council of Ministers of 9 December 2022 on invasive alien species [41], which establishes binding obligations concerning the prevention of introductions, control, and eradication of species that pose risks to biodiversity.

The National Centre for Plant Genetic Resources (NCPGR), operating within the Plant Breeding and Acclimatization Institute–National Research Institute (IHAR-PIB), serves as the central node of Poland’s system for the conservation of plant genetic resources. As an active participant in the Multilateral System (MLS) of the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA), the NCPGR ensures standardized and transparent access to genetic materials. Prior to distribution, all accessions are taxonomically verified against Annex I of the Treaty and screened for potential legal restrictions, including provisions of national species protection and intellectual property rights. Dissemination of materials is carried out under the Standard Material Transfer Agreement (SMTA), which provides a uniform contractual framework aligned with international Access and Benefit-Sharing (ABS) regulations. As of 2024, the NCPGR database contained 57,996 accessions falling under the MLS framework. Distribution statistics highlight a marked increase in the institution’s activity: between 2013 and 2017, a total of 4263 accessions were released to users, whereas in the period 2018–2024, this number rose sharply to 28,078. This dynamic expansion reflects both the growing demand for genetic resources and the strengthening role of the NCPGR as a national and international provider of plant germplasm.

The Seed Bank of the PAS Botanical Garden—Centre for Biological Diversity Conservation has been active in ex situ preservation of wild plants for over 30 years and currently maintains nearly 30% of Poland’s native flora, including over 58% of threatened taxa with endangered gene pools. This positions it among the leading European repositories for wild plant genetic resources [42]. Its achievements align closely with the Global Strategy for Plant Conservation (GSPC) Target 8, demonstrating both the effectiveness of its long-term approach and the potential of coordinated ex situ conservation efforts at national and international levels [42].

The present study seeks to critically examine the conservation status of Crop Wild Relatives (CWR) and species listed under the EU Habitats Directive (HD) in Poland, with particular attention to the capacity of the country’s key ex situ institutions to safeguard taxa of both potential utilitarian and ecological significance. These two groups, while conceptually distinct, are equally important: CWR may serve as reservoirs of genetic variability valuable for future plant breeding and food security, whereas HD species are prioritized under European conservation law for their role in sustaining ecosystem integrity and biodiversity. Thus, the central challenge lies in determining whether and to what extent Poland’s key ex situ institutions can jointly provide comprehensive coverage of both CWR and HD species, and in identifying the institutional, legal, and technical barriers that prevent effective integration.

By addressing these questions, this study seeks to provide an evidence-based assessment of the synergies and mismatches between current approaches, thereby informing more coherent strategies for safeguarding both genetic resources and wild plant diversity.

2. Materials and Methods

2.1. Data Sources

This study is based on the integration of primary datasets and official legal documents relevant to the conservation of plant genetic resources and wild and threatened taxa in Poland. The analytical approach involved a comparative cross-referencing of vascular plant lists with the EU Habitats Directive (HD; Annexes II, IV, and V; Council Directive 92/43/EEC) and its national implementation through the Regulation of the Minister of the Environment of 6 October 2014 on natural habitats and species of Community interest (Journal of Laws 2014, item 1713) in Poland with the national list of Crop Wild Relatives [25]. Taxa included in Annex I of the ITPGRFA were also reviewed for context but were not incorporated into the analytical comparisons. Two main data sources obtained from institutional internal servers were used: (1) The list of accessions was obtained from the database of the National Centre for Plant Genetic Resources at the Institute of Plant Genetics and Crop Plant Breeding (IHAR–PIB, Radzików). The NCPGR maintains ex situ collections of seeds and cultivated plants, including Crop Wild Relatives (CWR). (2) The list of taxa conserved in the Seed Bank was derived from the dataset of the Polish Academy of Sciences Botanical Garden—Centre for Biological Diversity Conservation in Powsin (PAS BG), which maintains ex situ collections of native and protected plant species. The harmonized list of taxa used in our analysis is a species-level dataset. The full list of analyzed species is available in the Supplementary Materials (Table S1).

2.2. Taxonomic Harmonization Protocol

To ensure comparability across datasets, all species names were standardized according to the currently accepted taxonomy in Plants of the World Online (POWO, Kew Science, https://powo.science.kew.org/ accessed 15 August 2025) as the primary authority. Species names were checked manually using POWO’s synonymy and accepted-name functions. Preliminary name matching was assisted by the taxize R package (v.4.5.1) [43] to identify possible synonyms and outdated entries, which were subsequently verified manually in POWO. Ambiguous taxa (e.g., unresolved infraspecific groups) were checked manually and only taxa occurring in both national datasets (NCPGR and PAS BG) were retained to reduce classification bias.

2.3. Statistical Analysis and Data Visualization

All analyses were performed in R version 4.5.1 [43]. Data was processed with dplyr [44] (accessed on 3 September 2025) and janitor [45] (accessed on 3 September 2025) packages. Each taxon was as-signed indicators for inclusion in the Gene Bank of National Centre for Plant Genetic Re-sources (NCPGR), the Seed Bank of PAS Botanical Garden Seed Bank (PAS BG), as a Crop Wild Relative (CWR), and under the EU Habitats Directive (HD). Statistical significance was evaluated by applying the Pearson’s Chi-square test for independence, supplemented by Fisher’s Exact Test. The level of significance was set at α = 0.05. Proportions and 95% confidence intervals were estimated using the Wilson score method implemented in the binom [46] (accessed on 3 September 2025), Euler diagrams were generated with the eulerr [47] (accessed on 3 September 2025), and subsequently refined and formatted for publication using Canva (www.canva.com, accessed on 7 September 2025).

3. Results

We compiled a harmonized list of 1458 Crop Wild Relatives (CWR) occurring in Po-land, including taxa listed under the EU Habitats Directive (HD), and evaluated their representation across two national ex situ repositories—the National Centre for Plant Genetic Resources (NCPGR; Gene Bank) and the PAS Botanical Garden Seed Bank (Seed Bank)—as well as the overlap between these categories (Table S1).

In summary, the analysis showed that only 2.9% of Habitats Directive (HD) species were represented in the NCPGR collection (p = 0.00023), whereas 73.5% were present in the PAS BG (p = 5.25 × 10⁻²¹), reflecting the complementary but institutionally distinct focus of these repositories. The overall ex situ coverage across all taxa reached 76% (95% CI: 71.7–79.8%), indicating substantial progress in safeguarding national plant diversity. Among Crop Wild Relatives (CWR), representation reached 32.3% in the NCPGR (p = 0.0071) and 15.3% in the PAS BG (p = 0.0027), resulting in a combined ex situ coverage of 47%. In total, 467 CWR were recorded in the NCPGR, 221 in the Seed Bank PAS BG, and 20 were also listed under the HD (Figure 2 and Figure 3). The NCPGR thus secures a markedly larger proportion of the national CWR pool, reflecting its agricultural mandate and long-standing role as the primary institution for genetic resource management. By contrast, the Seed Bank PAS BG contributes more specialized coverage of taxa associated with rare or threatened habitats, although its overall representation of the national CWR flora remains smaller.

The intersection between the two ex situ repositories was limited. Only 50 CWR species were jointly maintained in both institutions, indicating that redundancy—the strategic duplication of accessions—is minimal within the Polish system (Figure 2). While this overlap provides some level of security against accidental loss, the majority of accessions remain unique to one institution. This asymmetry underscores the complementarity of the two repositories but also exposes systemic vulnerability due to the absence of broader duplication strategies.

The intersection of ex situ collections with the EU Habitats Directive species reveals a more critical conservation gap (Figure 3). Of the 34 HD-listed species assessed, only one (Pulsatilla patens (L.) Mill.) is stored in the Gene Bank, whereas 13 species are conserved in the Seed Bank. Notably, none of the HD species are represented in both repositories simultaneously. Furthermore, among the 9 taxa that fall within the HD versus CWR category, five remain entirely absent from ex situ collections. These include species of high conservation concern that combine ecological and potential utilitarian value, making them clear priorities for targeted collection and long-term preservation (Aldrovanda vesiculosa L, Luronium natans (L.) Raf., Najas flexilis (Willd.) Rostk. & W.L.E.Schmidt, Lindernia procumbens (Krock.) Philcox, Cypripedium calceolus L., Gentianella bohemica Skalický, Liparis loeselii (L.) Rich.). Within the NCPGR collection, 131 taxa are distributed under the Standard Material Transfer Agreement (SMTA) in accordance with the International Treaty on Plant Genetic Resources for Food and Agriculture (ITPGRFA).

4. Discussion

Ex situ conservation of plant genetic resources and wild threatened flora represent key pillars of a comprehensive approach to safeguarding plant diversity. In this context, the representation of Crop Wild Relatives (CWR) and species protected under the EU Habitats Directive (HD) within national repositories provides an important measure of a country’s conservation effectiveness. The results of this study reveal a marked imbalance between institutional mandates: while the PAS Botanical Garden Seed Bank (PAS BG) plays a dominant role in conservation wild, rare and threatened species (Figure 3), the National Centre for Plant Genetic Resources (NCPGR) primarily focuses on taxa of agricultural and economic significance (Figure 2). Although the national ex situ system conserves a substantial proportion of plant diversity, the analysis revealed pronounced asymmetries between institutional collections. Only 2.9% of Habitats Directive (HD) species were represented in the NCPGR, whereas 73.5% were present in the PAS BG, reflecting their complementary but distinct conservation mandates—agricultural versus habitat-oriented. The overall ex situ coverage across all HD taxa reached 76%. Among Crop Wild Relatives (CWR), representation was 32.3% in NCPGR and 15.3% in PAS BG, corresponding to a combined ex situ coverage of 47%, which highlights an expanding yet still incomplete conservation of the country’s agrobiodiversity.

When benchmarked against other European nations, Poland’s overall ex situ cover-age appears moderate but improving. Finland has achieved over 60% conservation of threatened plants, including prioritized CWR through a coordinated national strategy [48], while Lithuania reports nearly 55% coverage CWRs via integrated in situ–ex situ actions [49]. Western European countries such as Germany could conserve up to 85% of CWR in situ, and the United Kingdom maintain ca 55% representation, benefiting from long-established CWR inventories and strong institutional integration [50,51]. In contrast, ex situ coverage across West Asia and North Africa averages below 35% [52], positioning Poland above the regional mean yet still below the European frontrunners.

The case study of Polish ex situ conservation reveals a system that, while advanced in many respects, is constrained by several structural, technical, and institutional challenges. In particular, the legal framework governing the protection of wild flora and genetic resources remains highly complex, fragmented across multiple acts and regulations, and often difficult to navigate in practice. This regulatory complexity not only creates administrative burdens for institutions but also slows down and complicates the process of collecting plant material from natural habitats, thereby limiting the efficiency and timeliness of ex situ conservation efforts (see Figure 1). These limitations mirror broader patterns documented in international assessments of plant genetic resource conservation [53,54].

A major obstacle is the fragmentation of data infrastructures. The National Centre for Plant Genetic Resources (NCPGR) and the PAS Botanical Garden Seed Bank (PAS BG) maintain independent databases that differ in scope, and accessibility. The absence of interoperable platforms restricts information flow between repositories and hampers effective priority-setting, as conservation planners cannot easily verify which CWR or HD species are already secured in one collection when planning complementary collecting missions for another. This duplication gap increases the risk of redundant effort while leaving some taxa entirely unrepresented, as institutions cannot easily identify which taxa are already conserved elsewhere or remain uncollected. Similar challenges are observed worldwide, where heterogeneous data systems undermine strategic conservation planning [53].

Another critical challenge concerns the limited overlap between repositories, which weakens the resilience of the national conservation system. Duplication of accessions across institutions is recognized as essential for safeguarding against accidental loss and ensuring long-term viability [15]. In Poland, however, overlap between the CWR collections of the NCPGR and the PAS BG Seed Bank remains minimal, and no HD species are jointly represented in both repositories. Comparable gaps have been documented in other European seed banks, where insufficient duplication threatens the security of ex situ holdings [15,54].

Beyond the physical dimension, the digital continuity of genetic resources is becoming equally crucial. The growing reliance on genomic, transcriptomic, and proteomic data—the so-called Digital Sequence Information (DSI)—has transformed how genetic resources are used, shared, and governed. DSI encompasses DNA and RNA sequences, protein structures, and associated metadata derived from biological material that can be stored, analyzed, and exchanged independently of the physical specimens. These data are increasingly used for breeding, ecological genomics, and biotechnology, yet they also raise complex questions of ownership, traceability, and benefit-sharing. The digital dimension thus underscores the need for centralized, interoperable data infrastructures that connect physical germplasm accessions to their digital counterparts. While the Multilateral System (MLS) of the ITPGRFA—implemented through the Standard Material Transfer Agreement (SMTA)—has already enabled the global exchange of more than 6.4 million samples by 2023, including significant Polish contributions [33], the future governance of Digital Sequence Information (DSI) introduces unprecedented demands for harmonization. Of the 1353 CWR taxa analyzed in this study, 131 are maintained in the NCPGR collection and distributed under the SMTA within the framework of the ITPGRFA (Table S1), primarily corresponding to Annex I crops and forages. The remaining non-Annex I taxa fall under the CBD and ABS framework, reflecting dual implementation of international obligations in the management of genetic resources. Given this overlapping legal landscape, each accession requires case-by-case consideration, as many taxa simultaneously qualify as legally protected species and as Crop Wild Relatives (CWR). This dual status underscores the need for harmonized and simplified procedures for material exchange between gene banks and botanical repositories, to ensure legal compliance while facilitating secure and efficient circulation of genetic resources. However, without an integrated approach linking ex situ collections, sequence databases, and metadata systems, countries risk fragmentation, data loss, and exclusion from future benefit-sharing mechanisms based on digital genetic resources. Ongoing negotiations within the CBD and ITPGRFA, and deliberations of the FAO Commission on Genetic Resources for Food and Agriculture (CGRFA, 2025) emphasize that the next phase of global conservation will hinge on the ability to manage both material and digital components of biodiversity in an interoperable, transparent manner. For Poland, strengthening coordination between national repositories, standardizing digital documentation, and ensuring linkage between physical accessions and DSI records represent strategic steps toward securing full participation in global frameworks for biodiversity governance and equitable benefit-sharing [34,35,36].

Institutional fragmentation also manifests in governance arrangements. The NCPGR, operating within the Plant Breeding and Acclimatization Institute (IHAR-PIB) under the Ministry of Agriculture and Rural Development, is primarily oriented toward agrobiodiversity and PGRFA. In contrast, the PAS Botanical Garden—Centre for Biological Diversity Conservation (CBDC) reports through the General Directorate for Environmental Protection (GDOŚ) under the Ministry of Climate and Environment, focusing on wild and threatened taxa. These distinct administrative affiliations result in differing funding mechanisms, reporting obligations, and strategic priorities. While complementary, this division reinforces fragmentation and limits the potential for integrated planning.

The issue of taxonomic coverage and methodological limitations further complicates the Polish context. Several high-priority taxa, particularly HD-listed and legally protected CWR such as Cypripedium calceolus L. and Aldrovanda vesiculosa L. remain absent from both repositories. Orchids, like C. calceolus pose major ex situ challenges because their dust-like seeds lack endosperm and depend on specific mycorrhizal fungi for germination, while Aldrovanda vesiculosa produces recalcitrant, short-lived seeds and requires highly specific aquatic conditions for survival. This gap is not accidental: the majority of missing species belong to non-orthodox seed categories, including orchids, aquatic plants, and bryophytes, which cannot be stored effectively under conventional seed bank conditions. This reflects a global trend, as many countries face similar difficulties in conserving taxa with recalcitrant seeds [15,54]. In Poland, the existing cryobank infrastructure already provides a valuable foundation: the PAS Botanical Garden in Powsin and the Kostrzyca Forest Gene Bank maintain cryo-genic collections of plant tissues, including shoot tips, dormant buds or somatic embryos [55]. These facilities have developed and implemented vitrification and/or encapsulation-dehydration methods that enable long-term storage of vegetatively propagated and plant taxa. Moreover, recent technological advances [56] demonstrate significant improvements in vitrification, encapsulation-dehydration, and embryo rescue protocols—approaches directly applicable to Crop Wild Relatives (CWR) and other wild species with non-orthodox seed physiology. In a broader context, Panis et al., (2020) [57] emphasize the integration of cryopreservation and in vitro culture within global conservation frameworks, highlighting their critical role in safeguarding recalcitrant and clonally propagated species.

In summary, while Poland has established a solid basis for the ex situ conservation of both CWR and HD species, several systemic shortcomings persist: fragmented databases, limited duplication across repositories, incomplete representation of non-orthodox taxa, and divided governance structures. These challenges mirror global patterns, underscoring that Poland’s situation is emblematic of wider tensions between agricultural genetic resource management and nature conservation approaches. Future efforts must therefore prioritize institutional integration, database harmonization, and methodological innovation—particularly in the field of non-orthodox seed conservation and digital genetic resources. Strengthening these areas will be essential for building a resilient, future-oriented conservation system that contributes effectively to both European and global biodiversity and food security agendas.

5. Conclusions

Currently, 47% of Poland’s Crop Wild Relatives (CWR) and 76% of species listed under the EU Habitats Directive (HD) are represented in national ex situ repositories, indicating considerable progress but also revealing persistent gaps in coverage. The dual institutional framework—comprising the National Centre for Plant Genetic Resources (NCPGR) and the PAS Botanical Garden Seed Bank (PAS BG)—provides complementary but uneven conservation outcomes. While the NCPGR effectively secures agricultural and CWR taxa, the PAS BG plays a crucial role in safeguarding rare and protected species; however, no HD taxa are duplicated across both repositories, reducing overall system resilience.

Poland’s ex situ conservation system, though grounded in strong legal and institutional frameworks, remains fragmented and uneven. Ensuring comprehensive protection of Crop Wild Relatives (CWRs) and Habitats Directive (HD) species will require stronger coordination between agricultural and environmental sectors, greater redundancy across repositories, interoperable data systems, and the application of advanced biotechnological methods for non-orthodox taxa. Active engagement in international processes on Digital Sequence Information (DSI) and Access and Benefit-Sharing (ABS) is also vital to secure equitable participation in global conservation frameworks. The transition toward digital biodiversity governance demands greater attention. As DSI increasingly shapes research, breeding, and benefit-sharing frameworks, the lack of standardized, interoperable data systems linking physical germplasm with digital genetic records poses a critical limitation. Establishing integrated information infrastructures will therefore be key not only for enhancing transparency and coordination within Poland’s conservation system, but also for ensuring effective participation in future international frameworks for DSI governance and equitable benefit-sharing. Strengthening these dimensions will align national efforts with the Kunming–Montreal Global Biodiversity Framework, the Global Strategy for Plant Conservation, and the EU Biodiversity Strategy for 2030, reinforcing Poland’s contribution to the long-term preservation of plant diversity.