In 2010, Poland launched a new national strategy for regional development which is seen as an assertion of Poland’s domestic regional development vision, informed by, but distinct from, EU cohesion policy which has dominated Polish regional policy since accession. A key question is whether a new model of policy implementation is emerging. The strategy includes a commitment to a place-based regional policy model. This implies spatially sensitive policy implementation capable of mobilising the potentials of all territories. However, the concept is vague. Moreover, in Poland this agenda is being launched in a context of entrenched territorial disparities, traditionally constrained policy implementation capacity and institutional change. What are the defining characteristics of place-based implementation systems? What are the challenges to the institutionalisation of the place-based model? Are these evident in delivery frameworks being developed in Poland?