Ambulance equipment does not stem from a single document, but from three independent sources of law, which do not always say the same thing.
For an emergency medical services provider, a hospital fleet administrator, or an organization planning to purchase an ambulance, this question has practical consequences. The ministerial regulation sets the framework for guaranteed services. The Order of the President of the National Health Fund (NFZ) translates them into a specific, operational equipment list — and it is this very list that changes most often, sometimes several times within a single year. The PN-EN 1789 standard does not mention a defibrillator or a ventilator at all — it regulates the construction of the vehicle itself as a medical compartment.
Three independent levels regulate ambulance equipment
Whoever asks “what must I have in the ambulance” is essentially asking about three different things at once — and rarely notices it.
| Source of law | What it regulates | How often it changes |
| Regulation of the Minister of Health on guaranteed services in the field of emergency medical services | Conditions regarding personnel and equipment for specific types of teams | Rarely, by means of a full amendment |
| Order of the President of the NFZ No. 179/2020/DSM (with subsequent amendments) | An operational, detailed list of equipment and conditions for the execution of contractual agreements | Often, even several times a year |
| PN-EN 1789 | Construction, testing, and performance of the ambulance itself as a vehicle | In accordance with the revision cycle of the European standard |
The regulation sets the legal framework within which the NFZ operates. The Order of the President of the NFZ fills this framework with specifics — and it is its content that one must look at when planning to purchase equipment for today, not the content of the regulation itself. The technical standard operates alongside, regardless of what the NFZ happens to be changing — it answers an entirely different question, whether the vehicle itself is suitable for transporting a patient.
The separation of these three levels has practical significance. It happens that an item makes it onto the NFZ list even though no technical standard requires it — it stems solely from an administrative decision made in response to a specific event. Below, we show exactly where this boundary lies.
How the Regulation of the Minister of Health divides requirements for teams
The foundation is the Regulation of the Minister of Health of February 4, 2019, on guaranteed services in the field of emergency medical services (Journal of Laws, item 237). It specifies the conditions for providing services separately for each type of team, including requirements for personnel and equipment — in separate annexes for each type of team.
The amendment of November 13, 2025 (Journal of Laws 2025, item 1552) changed this structure in a way that is significant for manufacturers and fleet operators. Until now, the basic team was treated uniformly. Following the change, the regulation distinguishes between:
- a basic two-person emergency medical services team — conditions are specified in the existing Annex No. 2;
- a basic three-person emergency medical services team — a new Annex No. 2a was added for it;
- a new Annex No. 4, added by the same amendment — its scope is currently poorly described in publicly available commentaries on the change, so before citing details, it is worth checking the current text of the regulation.
This division is not cosmetic. The personnel composition of the team translates directly into how much space in the medical compartment must be provided for the staff to work — and therefore into the design of the ambulance’s interior, not just the equipment list on paper.
The regulation itself is responsible for the legal framework of guaranteed services. The current, detailed purchasing list is the responsibility of the Order of the President of the NFZ, described below.
What exactly the Order of the President of the NFZ mandates
The operational equipment list can be found in the Order of the President of the NFZ No. 179/2020/DSM on defining the conditions for concluding and implementing contracts in the type of emergency medical services — specifically in Annex No. 3, part 5. This is a document that the NFZ changes regularly, and it is here, not in the ministerial regulation, that one must look for the current legal status prior to a purchase.
The scale of changes can be considerable. In the last dozen or so months alone, the order has been amended multiple times — including by Order No. 61/2025/DSM of July 22, 2025, Order No. 90/2025/DSM of November 7, 2025, Order No. 37/2026/DSM of April 8, 2026, and a separate amendment of May 13, 2026, regarding motorcycle ambulances.
The most instructive example of how this layer of law works concerns spike- and stab-resistant vests. Their introduction does not result from any technical standard — it is an administrative decision by the NFZ, taken in direct reaction to a single event: the fatal stabbing of a paramedic during an intervention in Siedlce on January 25, 2025. The deadline for implementing this obligation has changed twice since then:
- Order No. 61/2025/DSM (July 22, 2025) introduced the obligation with an initial deadline of January 1, 2026;
- Order No. 90/2025/DSM (November 7, 2025) postponed the deadline to March 31, 2026;
- Order No. 37/2026/DSM (April 8, 2026) postponed it a second time, to December 31, 2026.
At the same time, the Ministry of Health declares that the vests themselves are to physically reach the teams by the end of May 2026, regardless of the formal date the obligation enters into force — however, this is an operational announcement, not a legal deadline. It is also worth remembering: it is the NFZ order, not the ministerial regulation, that assigns the vests to the composition of the team as a whole, not to a specific person, which in practice means they are used on a rotational basis.
This example shows what cannot be seen in the technical standard itself — some items end up on the list for personnel safety reasons, and not because the vehicle’s construction requires it.
What the PN-EN 1789 standard covers
PN-EN 1789 says nothing about a defibrillator or a ventilator. It regulates the construction of the vehicle itself as a means of transport and a place for providing aid, including:
- dimensions and layout of the medical compartment;
- vehicle performance and conditions for its testing;
- classification of ambulance types (A, B, C).
This distinction has legal significance extending beyond the technical specification itself. The standard is referenced independently in the Public Procurement Law. Pursuant to Article 101, paragraph 4 of the Public Procurement Law, if a contracting authority refers in the description of the subject of the contract to a standard such as PN-EN 1789, it must simultaneously allow equivalent solutions — such a reference must be accompanied by the words “or equivalent”. The burden of proving equivalence then rests on the contractor, usually through specific means of proof attached to the bid.
A similar division can be seen in tax interpretations regarding excise tax exemption — an ambulance can be sold before first registration without a full set of medical equipment and still benefit from the exemption appropriate for a special purpose vehicle. The status of the vehicle here is determined by compliance with the construction standard, not the state of equipment at a given moment.
The standard itself, however, does not determine whether a specific infusion pump must be in the ambulance, or how many defibrillators are allocated per team. These are decided by the two previous levels.
Does every ambulance have identical equipment?
Yes, the equipment actually differs between ambulances — and this happens legally. The difference results primarily from the type of team the vehicle is assigned to: different requirements apply to a two-person team, different ones to a three-person team, and still different ones to a specialized team with a system physician.
Added to this is above-standard equipment — gear that the provider supplies on their own initiative, above the minimum requirements. The decision regarding it usually depends on:
- the provider’s budget;
- the profile of their activity;
- local needs and the specific nature of the area served.
Such a decision can differ regionally even between two stations of the same team type, and the case law of the National Appeal Chamber confirms that medical entities can demand higher than standard parameters if it is objectively justified by patient safety. This does not apply to the basic level, however — the minimum that cannot be gone below is determined jointly by the ministerial regulation and the current Order of the President of the NFZ.
What are the consequences of equipment non-compliance?
The consequences depend on the level at which the non-compliance occurred, and are primarily contractual, not penal in nature:
- non-compliance with the Order of the President of the NFZ — risk on the side of the contract with the Fund: post-inspection remarks, financial corrections, risk to the conditions of further contract implementation in a given type of services;
- non-compliance during purchase with public funds — risk of the bid being rejected as early as the procurement procedure stage, before the contract is signed, especially when the equipment does not meet the requirements of the description of the subject of the contract, including the PN-EN 1789 standard without demonstrated equivalence.
Full compliance with the technical standard of the vehicle is not the same, however, as fulfilling the current NFZ contractual requirements regarding medical equipment — both levels must be checked separately.
FAQ
Not entirely — the minimum is identical for the same type of team across the country, but above this level, providers can add equipment at their own discretion, so the actual equipment varies from station to station.
Since the amendment of the regulation in November 2025, both variants have separate annexes specifying the requirements for personnel and equipment — previously, the basic team was treated uniformly. The personnel composition also translates into how much space in the medical compartment must be provided for the team’s work on the patient.
The obligation formally exists, but its deadline has already been postponed twice: first from January 1 to March 31, 2026, and then, by Order No. 37/2026/DSM, to December 31, 2026. The Ministry of Health declares that the vests themselves are to physically reach the teams by the end of May 2026, but this is an operational announcement, not a legal deadline for the obligation to enter into force — before making a purchasing decision, it is worth verifying the current wording of the order directly on the NFZ website.
The construction, dimensions, and performance of the vehicle are regulated by PN-EN 1789. The specific list of medical equipment is determined by the Order of the President of the NFZ based on the legal framework from the Regulation of the Minister of Health — these are two independent sources that must be met separately.
