Poland is following in the footsteps of Turkey by approving draft legislation penalising suggestions of complicity in the Nazi Holocaust on its soil during World War Two, Hungarian historian Laszlo Karsai says.

Violators could face three years in prison for a mention of 'Polish death camps'.

Some experts believe the new law could have the opposite effect and highlight Poland's collaboration with the Nazi regime, euronews says.

"It is unacceptable for me, a historian and a liberal person, to threaten someone with prison because they give their opinion based on research," said Karsai.

"Polish lawmakers are using the 'Turkish' way. They are faking their own history. You can get three years in prison if you say there was an Armenian genocide in Turkey."