Tax Alert: Loans to support energy transition

Loans to support energy transition under the National Recovery and Resilience Plan (RRP) The new facility comes from the Energy Support Fund established in September 2024 by the Ministry of Climate and Environment. Loans can be used to finance investment projects related to energy transition, including construction of RES and electricity storage facilities. Over PLN 7 billion in funding has been allocated to support the implementation of the aforementioned objectives.

The conditions for energy transition loans are as follows:

• Minimum loan amount: PLN 200 million;
• Term of the loan: in principle, 15 years; however, no longer than until the end of 2053;
• Funds availability period: until 2029 with the possibility of clearing the project by 2031;
• Interest rate: Preferential interest rate, not lower than the National Bank of Poland’s reference rate, less 200 basis points or market interest rate, fixed or floating, but not lower than 1%;
• Grace period: In principle, not longer than 1 year of the project completion;
• Amount of support: up to 90% of eligible costs;
• Own contribution: from non-public funds, not less than 10% of eligible expenses;
• no origination fee for the loan;
• applicants may apply for more than one loan, subject to the rules on state aid, the availability of funds, and the achievement of the instrument’s indicators; applications may be submitted no more than once per month.

According to the assumptions, loans can only be used to finance projects contributing to expediting the decarbonization process through gradual phase-out of fossil fuels and replacing them with renewable energy sources (RES), improvement of energy efficiency and development of green industry through switching the focus to green innovation.

Eligible projects:

• Creation/modernization of heating and gas grids (for decarbonized gases);
• Construction of RES (including renewable hydrogen production and electricity storage facilities) in the electric power and heating industry;
• Construction of electricity storage facilities to foster the integration of RES into the electricity system;
• Increasing energy efficiency of businesses and buildings, along with RES and electricity storage facilities;
• Facilities lowering emissions and energy consumption of businesses;
• Construction of infrastructure to produce biomethane, 2nd generation biofuels and renewable hydrogen for transport purposes.

Moreover, projects covered by the funding must comply with relevant EU and national provisions on environmental protection and the Do No Significant Harm (DNSH) principle, as stipulated by Article 2(6) of the Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility.

Importantly, the loans may not be used to finance expenditures previously declared for reimbursement under the National Recovery and Resilience Plan or as eligible under other EU or national support programs; VAT on goods and services; or project financial costs.

Loans to support the energy transition may be applied for by the following entities:

• Private and public enterprises intending to carry out investments included in the application;
• Companies or partnerships acting as direct owners or co-owners, exercising immediate control over the entity implementing the project and holding more than 50% of its shares.

The call for applications is open and continuous. It may, however, be terminated or suspended. Loans will be granted to finance projects that have not yet started or that commenced no earlier than 1 February 2022. For projects receiving State aid, additional requirements may apply.

Applications for energy transition loans must be submitted electronically via the designated online application tool. 

KPMG provides support at every stage of the investment process, from the funding application and ongoing assistance during implementation to the final settlement.

Our Team remains at your disposal for any further information you might require.