Power Generation, Transmission and Distribution 2026

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

energy storage systems (BESS) are gaining consider- able importance as a means of ensuring grid stability, managing supply-demand imbalances, and providing ancillary services to the transmission system operator.

price in Poland is determined based on offers matched cross-border up to the available implicit cross-border capacity allocation. • The intraday market (IDM) encompasses three auc- tions and continuous trading, enabling participants to adjust positions after the DAM gate closure. The IDM is integrated with the pan-European SIDC mechanism. • The balancing market is operated by the TSO to resolve real-time supply-demand imbalances and to procure ancillary and reserve services. The bal- ancing market includes settlements for imbalances as well as the procurement of balancing energy and balancing capacity from generators, storage asset operators and demand-side response provid- ers. The balancing market represents a relatively limited share of the total traded volumes, and operates under regulatory mechanisms intended to incentivise balancing through commercial market transactions rather than reliance on balancing actions by the TSO. 2.2 Electricity Imports and Exports Imports and exports of electricity are permitted and form an integral part of the Polish electricity system’s operation. Poland is interconnected with Germany, the Czech Republic, Slovakia, Sweden (via the SwePol HVDC interconnector), Lithuania (through the LitPol Link interconnector) and Ukraine. Short-term cross-border trading is integrated through the SDAC and SIDC mechanisms, under which avail- able interconnection capacity is allocated through implicit market coupling. Long-term cross-border transmission rights are allocated through explicit auctions conducted via the Joint Allocation Office. PSE S.A. participates in the co-ordinated allocation of cross-border transmission capacity in accordance with applicable EU network codes and market cou- pling arrangements. Market participants engaging in cross-border electric- ity trading must satisfy applicable licensing, balancing and market access requirements. However, no sepa- rate governmental approval is generally required for individual import or export transactions.

2. Market Structure, Supply and Pricing 2.1 The Wholesale Electricity Market Market Structure and Trading Venues

The Polish wholesale electricity market is a competi- tive market with a single bidding zone covering the entire country. Pricing is zonal rather than nodal; con- gestion within the Polish grid is managed by the TSO, whilst cross-border congestion is addressed through price-coupling mechanisms embedded in the pan- European day-ahead and intraday coupling arrange- ments. Wholesale trading is conducted primarily on the Polish Power Exchange ( Towarowa Giełda Energii , or TGE), alongside trading platforms operated by other nomi- nated electricity market operators (NEMO), includ- ing EPEX Spot and Nord Pool. TGE accounts for the substantial majority of exchange-traded volume. The over-the-counter (OTC) market operates in parallel, comprising bilateral contracts negotiated directly between market participants; in 2024, OTC volumes (excluding intra-group transactions) amounted to approximately 19.9 TWh. Market Segments The wholesale market operates across four principal market segments. • The forward market: the TGE lists standardised physically settled forward products with settlement horizons of up to four years ahead (y+4), enabling participants to hedge price exposure over longer time horizons. OTC forward contracts are conclud- ed bilaterally and allow for more flexibility in terms of volumes, pricing and tenors. • The day-ahead market (DAM) encompasses two auctions and continuous trading with the availabil- ity of both hourly and quarterly (15-minute) prod- ucts. DAM is integrated with the pan-European SDAC mechanism, which means that the clearing

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