Power Generation, Transmission and Distribution 2026

POLAND Law and Practice Contributed by: Tomasz Młodawski, Krzysztof Cichocki, Łukasz Wyszomirski and Krzysztof Fasula, Sołtysiński Kawecki & Szlęzak

Sołtysiński Kawecki & Szlęzak 26 Jasna Street 00-054 Warsaw Poland

Tel: 0048 22 608 70 00 Fax: 0048 22 608 70 01 Email: office@skslegal.pl Web: www.skslegal.pl

1. Structure and Ownership of the Power Industry 1.1 Law Governing the Structure and Ownership of the Power Industry General Overview of the System Poland operates one of the largest electricity markets in Central and Eastern Europe, with total gross elec- tricity demand in Poland corresponding to approxi- mately 175 TWh per annum as of 2025. Both produc- tion and consumption are in a long-term upward trend. The transmission system operator (TSO) forecasts a steady growth in demand up to 194 TWh by 2030, and 264 TWh by 2040 (respective increases of 11% and 60% compared to 2025 levels). This growth is driven primarily by the electrification of transport, digitalisa- tion and the expansion of energy-intensive industries. Poland is integrated into the European electric- ity market through the Single Day-Ahead Coupling (SDAC) and Single Intraday Coupling (SIDC) mech- anisms, meaning that significant volumes of power are exchanged with neighbouring countries, and the domestic wholesale prices are closely correlated with those in neighbouring markets. In terms of price lev- els, Poland sits within the Central European mid-range band. The 2025 generation mix was still heavily coal- dependent: coal and lignite accounted for 52.2% of total generation, while natural gas accounted for 13.2%, and renewable energy sources for 31.4%. Poland’s energy transition strategy targets a 53.9% reduction in GHG emissions by 2030 compared to

1990 levels, with a 51.8% share of renewables in elec- tricity generation by 2030 and approximately 65% by 2040. Reduction of the carbon footprint should also be boosted by commissioning the first nuclear reactor in 2036 and an increase in the total nuclear capacity up to 6 GW by 2040. Coal-fired generation is expected to exit progressively, with approximately 5–8 GW of coal capacity projected to leave the mar- ket by 2030 as subsidy schemes and capacity market contracts expire, with the coal fleet to be substantially phased out by approximately 2040 and the last coal mine scheduled for closure by 2049. A combination of ambitious renewable targets, a structured coal phase- out timeline, and the planned entry of nuclear capac- ity creates a substantial and well-defined pipeline of investment opportunities in generation, storage and grid infrastructure. Market Architecture, Segments and Ownership The electricity market encompasses: • a regulated natural monopoly segment covering transmission and distribution infrastructure; and • a competitive segment involving generation, storage, trading, and supply- and demand-side response. Prices within the monopoly segment are regulated by way of tariffs approved by the President of the Energy Regulatory Office (ERO). For the competitive segment, prices are determined by market forces. The generation and retail supply segments are domi- nated by four state-controlled integrated energy

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