Beginning in 2019, many subnational governments in Poland created discriminatory, so-called “LGBT Free Zones.” Against trends of expanding minority rights in much of the world in recent decades, the Polish example shows the persistence and even expansion of discriminatory policies against minoritized groups, especially on the less-visible level of subnational politics. Our paper seeks to understand where subnational governments pursue these discriminatory policies. To maximize leverage and comparability, we analyze variation in the establishment of local-level discriminatory policies across 2,477 Polish municipalities, which have occurred against a national-level backdrop of democratic backsliding under the conservative Law and Justice (PiS) party. Local zones are most likely to be implemented through direct diffusion channels, where PiS officials hold municipal offices and where higher-level units (counties) also implement such zones. We contribute to our understanding of government-led discrimination against minoritized populations as well as subnational rule of law violations in EU member states.