On 24 September 2026, the Senate adopted, without amendments, the act amending the Renewable Energy Sources Act and certain other acts. The new provisions are intended to support the development of the biomethane market, streamline the preparation of renewable energy investments and introduce a number of changes relevant to prosumers, energy cooperatives and investors developing wind projects. We have already reported on the work on the amendment to the Renewable Energy Sources Act in our previous Newsletters. On 15 October 2026, the Act was signed by the President.
The principal change is the introduction of an auction-based support scheme for biomethane production installations with a capacity exceeding 1 MW. In addition, the legislature has regulated the operation of direct pipelines used to transport biogas and biomethane and has made it possible to combine operating aid with selected forms of investment aid.
The amendment also contains measures intended to facilitate the implementation of renewable energy investments, including clarification of the rules for locating onshore wind farms on the basis of an integrated investment plan (ZPI) and alignment of public consultation procedures with the new spatial planning regulations.
The new provisions will take effect from the beginning of the month following the expiry of one month from their publication.
On 1 October 2026, the President of the Republic of Poland signed the act introducing a tax on extraordinary profits from the sale of liquid fuels, while announcing that it would be referred to the Constitutional Tribunal for ex post review. The regulation continues the earlier work on the windfall tax. We have already reported on the original draft regulation and the controversy surrounding its retroactive effect in previous issues of the Newsletter.
The tax will apply to undertakings operating in Poland in the field of liquid fuel production and to entities trading in liquid fuels under a licence for trading in liquid fuels with foreign countries. The levy is to apply to extraordinary profits generated between 1 March and 31 December 2026, even though the Act is scheduled to enter into force on 1 November 2026. The legislature has therefore decided to retain a measure that produces effects in respect of a period preceding the entry into force of the provisions.
The taxable amount will be the excess of actual revenue from the sale of fuels over hypothetical revenue calculated using an individual reference margin corresponding to the taxpayer’s average margin in 2025, increased by 20%. The tax rate will be 60% of the taxable amount so determined. The Ministry of Finance estimates the total proceeds from the new levy at approximately PLN 4 billion.
The next legislative step is to reduce fuel prices by changing excise duty rates. The relevant regulation of the Minister of Finance has already been adopted and provides for a temporary reduction in excise duty, which is intended to result in lower retail fuel prices for end users.
On 18 September 2026, the Sejm adopted an amendment to the Energy Law (UD446), which is currently awaiting the signature of the President. The primary purpose of the regulation is to safeguard the operation of the market in connection with the full implementation of CSIRE (the Central Energy Market Information System). It requires contingency plans to be prepared in the event that CSIRE or cooperating systems become unavailable and allows settlements to be temporarily conducted on the basis of data not registered in the system. In certain cases, the President of the Energy Regulatory Office will also be able to refrain from imposing penalties on distribution system operators for delays in implementing obligations related to CSIRE.
The Act requires contingency plans to be prepared in the event that CSIRE or systems cooperating with it become unavailable. Detailed rules are also to be introduced for conducting settlements in the event of system disruptions, together with new information and reporting obligations for market participants.
However, a significant part of the amendment extends beyond CSIRE itself. The new provisions clarify the obligations of generators and owners of generation sources and energy storage facilities to provide system operators with structural data, schedule data and real-time data, as well as to comply with system operator instructions. A particularly significant new power is granted to system operators: in the event of a serious breach of obligations concerning data or compliance with system operator instructions, the system operator will be able, for a period of up to 24 hours, to limit the injection or withdrawal of electricity or even disconnect the generation source or storage facility from the grid. No damages or compensation will be payable for such a restriction. Detailed criteria for a “serious breach” are to be specified in system operator instructions.
The changes are significant for renewable energy generators and owners of energy storage facilities because they increase the importance of properly providing system operators with data on the planned and current operation of installations. At the same time, empowering system operators to temporarily restrict the operation of, or disconnect, a unit strengthens the tools available to them for managing the operation of the power system.
On 29 September 2026, the Council of Ministers adopted a draft act concerning support for energy-intensive undertakings in connection with high electricity costs (UD459). The draft was referred to the Sejm. The new mechanism is intended to establish a national framework for aid granted primarily under the EU Clean Industrial Deal State Aid Framework (CISAF).
Support is intended for undertakings in sectors particularly exposed to a loss of competitiveness due to high energy costs, including the chemical, metallurgical, cement, glass and paper industries. The programme is to be competitive, with a total budget of approximately PLN 4.8 billion for 2027-2030.
A significant change introduced at the final stage of government work is the additional use of the temporary EU Middle East Crisis Temporary State Aid Framework (METSAF). This temporarily increases the maximum level of support for eligible electricity consumption costs from 50%, as provided for under the basic CISAF mechanism, to 70%.
However, the aid will not take the form of an unconditional energy subsidy. The beneficiary will be required to allocate at least 50% of the aid equivalent received to investment measures relating, among other things, to decarbonisation, energy efficiency, renewable energy sources, energy storage or increased demand-side flexibility. The support is therefore intended both to reduce current cost pressures and to stimulate investments that permanently reduce the energy intensity of undertakings.
From the industry’s perspective, the key issues will now be the further parliamentary work and the final rules of the aid programme, which will determine the practical availability of support and the conditions governing its use.
The Ministry of Energy has prepared a draft new regulation on energy market processes, which will replace the 2022 regulation and align the rules governing CSIRE with amendments to the Energy Law and experience from the system’s initial period of operation. The draft is currently at the consultation stage.
The draft comprehensively regulates 22 energy market processes carried out through CSIRE. These include, among other things, the handling of electricity sale and distribution agreements, supplier-of-last-resort sales, commercial balancing, management of metering points, and the exchange of metering and settlement data. The new processes also concern the renewable energy sector, including the provision of data on generation from renewable energy installations, the handling of information concerning energy cooperatives, and the determination of the amount of electricity generated by virtual and collective prosumers.
The regulation is intended to standardise the exchange and verification of data between market participants and increase transparency for customers. For system operators, suppliers and balance responsible parties, this will entail the need to adapt processes and IT systems to the new rules, with some of the new functionalities to be implemented in stages between 2027 and 2029.
On 27 September 2026, the provisions implementing Directive (EU) 2024/825 (EmpCo), one of the key elements of the EU strategy to combat greenwashing, began to apply in the Member States. The new regulations amend the rules on communicating environmental and sustainability claims to consumers, imposing significantly stricter requirements on undertakings as regards the presentation of the environmental benefits of products and services.
The Directive prohibits the use of generic environmental claims. The rules governing statements concerning future climate targets, including “net zero” commitments, have also been tightened and require such commitments to be based on detailed, verifiable implementation plans. The new requirements also cover environmental labels and certification schemes, which may operate only within schemes meeting specified criteria of transparency and independent monitoring.
For energy undertakings, the Directive means that marketing materials, websites, advertising campaigns and ESG strategies used in customer communications will need to be reviewed. In practice, EmpCo significantly increases the regulatory risk associated with greenwashing and constitutes another step towards harmonising environmental communication standards across the EU market.
On 3 October 2026, the key deadline expires for registration in the national register of the National Cybersecurity System (UKSC) by entities classified as “essential” and “important” within the meaning of the Act of 5 July 2018 on the National Cybersecurity System, implementing the NIS2 Directive. The self-registration obligation applies, among others, to entities in the energy sector, which has been classified as an essential sector due to its importance for national security and the continuity of services of fundamental importance to the economy and society.
For energy undertakings, this means the need to formally register in the KSC register if they have not been entered ex officio and, consequently, to comply with expanded requirements concerning risk management, business continuity, incident response and supply chain security. Failure to comply with the registration obligation and subsequent organisational and technical requirements may result in significant financial penalties as well as personal liability of management board members, making the new regulations a compliance priority for the entire energy sector.
JUDGMENTS
On 9 September 2026, the Voivodship Administrative Court in Warsaw dismissed the complaint brought by the Association for the Protection of Natural Coastal Areas “Bałtyckie S.O.S.” against the environmental decision concerning the construction of Poland’s first nuclear power plant at the Lubiatowo-Kopalino site in the Choczewo municipality (case file No. IV SA/Wa 878/25). The judgment is not final.
The environmental decision for Poland’s first nuclear power plant was issued by the General Director for Environmental Protection in 2023 and, in January 2025, following consideration of the appeals, was upheld in all material respects. The Association challenged, among other things, the correctness of the findings of fact and the completeness of the evidence, as well as the compliance of the environmental report with requirements concerning, inter alia, the analysis of project alternatives, landscape impacts and cumulative impacts. The allegations also concerned public participation in the proceedings and breaches of the Environmental Protection Law and the Atomic Law.
The Voivodship Administrative Court found no grounds to set aside the decision. The Court pointed to the detailed and comprehensive nature of the environmental impact assessment carried out for the project. The decision remains the basis for continuing the relevant proceedings and preparing the investment.
Although the judgment is not final, it is an important ruling for the continued implementation of one of Poland’s most significant strategic energy investments. Upholding the environmental decision may reduce the risk of further delays to the project, which is intended to play a key role in diversifying energy sources, strengthening energy security and decarbonising the domestic power sector.
Taxes in the energy sector
Individual ruling of 14 September 2026, issued by the Director of the National Tax Information Service, ref. no.: 0113-KDIPT1-2.4012.631.2026.2.MC
The Director of the National Tax Information Service (hereinafter: ‘DKIS’) deemed the Company’s position to be incorrect, according to which authorising a contractor to act on its behalf in relation to the acquisition and sale of energy efficiency certificates, known as white certificates, is not subject to VAT. The authority found that, in the model described, the Company provides the contractor with a service for consideration, consisting of the transfer of the right to acquire and sell certificates arising from an investment carried out by the Company. Consequently, the Company was obliged to document this transaction with an invoice.
Background to the case
The company carried out a project involving the modernisation of lighting, which enabled it to obtain energy efficiency certificates. In order to obtain them, it entered into a contract with a contractor who was to prepare an audit, documentation and an application to the President of the Energy Regulatory Office, and subsequently sell the certificates obtained on the Polish Power Exchange.
The contractor acted as an entity authorised by the Company. However, the certificates were issued in the contractor’s name, and the property rights arising from them were vested in him as the holder of the account in which the first entry in the register was made. The contractor sold the property rights as rights vested in him, and subsequently transferred the proceeds from the sale to the Company, after deducting a success fee and transaction costs.
The company argued that it had not provided any service to the contractor, and that the funds received were merely a transfer of the amount obtained from the sale of the certificates. In its view, the transaction was not subject to VAT and should not have been documented by an invoice.
DKIS’s position
DKIS did not agree with the Company’s position. The authority pointed out that, in the circumstances presented, the Company had provided services to the contractor for consideration. This service consisted of transferring the right to acquire and sell energy efficiency certificates arising from the investment carried out by the Company. In the authority’s view, the contractor was the direct recipient of the service, and the funds received by the Company from the sale of the certificates constituted remuneration for the service performed on the contractor’s behalf. The DKIS also emphasised that the legislation does not provide for a VAT exemption for such a transaction. Consequently, the Company was obliged to issue an invoice documenting the service subject to VAT.
Significance of the interpretation
The interpretation shows that the way in which a contract concerning white certificates is structured is of crucial importance for VAT settlements. If the certificates are issued to an authorised entity, the property rights vest in that entity, and the Company receives funds in connection with the transfer of the right to acquire and sell them, the tax authority may consider that the Company is providing services for consideration.
Practical implications
Entities using external firms to acquire and sell white certificates should carefully analyse the contractual model and the method of registering property rights. If the rights arising from the certificates are issued to the contractor and it is the contractor who disposes of them, the transfer to the contractor of the right to acquire and sell them may be regarded as a service subject to VAT.
Individual interpretation dated 22 September 2026 issued by: the Director of the National Tax Information Service, ref: 0111-KDIB1-1.4010.522.2026.1.AND
The Director of the National Tax Information Service (hereinafter: ‘DKIS’) confirmed that, in the case of an investment in a wind farm, the mere completion of construction works does not in itself determine whether assets can be recognised as fixed assets for corporate income tax purposes. Of key importance is the cumulative fulfilment of the conditions set out in the CIT Act, including completeness and fitness for use, as well as the possibility of legally and actually utilising the assets in business operations. In the case under consideration, the wind farm assets could be recognised as fixed assets at the earliest on the date of obtaining the licence to generate electricity.
Background to the case
The project company was carrying out an investment involving the construction of a wind farm comprising, amongst other things, turbines, foundations with towers, the main power collection point, medium- and high-voltage lines, roads, lighting, fencing and a technical security system.
The construction works were essentially completed in 2024; however, further activities relating to connection, technical commissioning, and the obtaining of operating licences and a licence for electricity generation continued until 2025. The company obtained a provisional ION permit on 3 February 2025, carried out the technical commissioning between 6 and 18 February 2025, and received the electricity generation licence on 19 February 2025.
DKIS’s Position
The DKIS accepted the Company’s position as correct and refrained from providing a legal justification for its interpretation. The authority confirmed that the assets constructed as part of the wind farm did not, as at 31 December 2024 or 1 January 2025, meet all the conditions for being classified as fixed assets within the meaning of the CIT Act.
The position that these assets met the criteria for classification as fixed assets at the earliest upon obtaining the licence to generate electricity, i.e. on 19 February 2025, was also deemed correct. Prior to that date, the investment could not be fully utilised in accordance with its economic purpose, namely the production of electricity.
The DKIS also accepted the allocation of indirect investment costs to the initial value of individual fixed assets according to a value-based allocation coefficient, based on the proportion of a given fixed asset’s direct costs in the direct costs of the entire investment.
Significance of the interpretation
The interpretation indicates that, in the case of complex energy projects, the date of completion of construction works need not coincide with the date on which a fixed asset comes into being for CIT purposes. What matters is not only the technical completion and completeness of the components, but also their suitability for actual and legal use in business operations.
In the case under consideration, the successful completion of the technical commissioning confirmed the technical readiness of the installation, but it was only upon obtaining the licence that operations relating to electricity generation could commence.
Practical implications
Taxpayers developing wind farms should assess the point at which assets are recognised in the fixed assets register by taking into account the entire investment commissioning process, rather than solely the date of completion of construction works.
Depreciation charges may only be made on fixed assets that cumulatively meet the conditions set out in Article 16a(1) of the CIT Act. If fixed assets were entered into the register in February 2025, tax depreciation should, as a general rule, commence from the month following the month in which they were entered into the register, i.e. from March 2025.
The interpretation also confirms that indirect investment costs which cannot be directly attributed to specific assets may be allocated proportionally according to the share of the direct costs of individual fixed assets in the direct costs of the entire investment.
Individual ruling of 8 September 2026, issued by the Director of the National Tax Information Service, ref. no.: 0114-KDIP1-1.4012.458.2026.1.ESZ
The Director of the National Tax Information Service (hereinafter: ‘DKIS’) confirmed that the sale of a photovoltaic farm may constitute the disposal of an organised part of an enterprise (hereinafter: ‘ZCP’) and, as such, fall outside the scope of VAT. Of key importance is the organisational, financial and functional separation of the farm, as well as the purchaser’s ability to continue operations on the basis of the acquired assets, rights and contracts. The authority also pointed out that the absence of a transfer of bank accounts, cash, financing or employees does not necessarily preclude the transaction from being classified as an OPE.
Background to the case
Two related companies, both active VAT taxpayers, operate in the field of solar energy and the distribution and trading of electricity from renewable energy sources. The vendor owns a photovoltaic farm, which it plans to separate organisationally and then sell to the purchaser as a ZCP. Following the transaction, the seller is to continue operating as a distribution system operator.
The subject matter of the transaction is to include, amongst other things, the technical components of the PV farm, technical and as-built documentation, rights to the property arising from the lease agreement, rights under guarantees and warranties, and agreements relating to the operation of the farm. Receivables and liabilities relating to the operations of the ZCP, which will become due after the transaction date, are also to be transferred to the purchaser.
DKIS’s Position
DKIS deemed the applicants’ position to be correct. The authority concluded that the set of tangible and intangible assets comprising the photovoltaic farm would meet the criteria for a ZCP, as it would be organisationally, financially and functionally separate and capable of conducting business activities independently.
Consequently, the sale of the PV farm will remain outside the scope of VAT pursuant to Article 6(1) of the VAT Act.
Significance of the interpretation
The interpretation confirms that a photovoltaic farm may constitute a ZCP if it comprises an organised set of assets enabling the continuation of business activities relating to the generation and sale of electricity. What is important is not so much the transfer of all assets held by the seller, but rather the actual ability of the purchaser to conduct business based on the acquired assets, rights and contracts.
Practical implications
The sale of a separate photovoltaic farm as a ZCP is not subject to VAT if the conditions for organisational, financial and functional separation are met, and the purchaser can continue operations without involving any significant additional components. The fact that bank accounts, cash, financing or staff are not transferred does not preclude such classification, provided they are not essential for the farm’s continued operation.
Individual ruling of 9 September 2026, issued by: the Director of the National Tax Information Service, ref. no.: 0114-KDIP1-2.4012.496.2026.1.JO
The Director of the National Tax Information Service (hereinafter: ‘DKIS’) confirmed that the Polish Exclusive Economic Zone (hereinafter: ‘EEZ’) may be treated as the territory of the country for VAT purposes in respect of activities relating to the construction and operation of an offshore wind farm, i.e. within the area where Poland exercises sovereign rights. Consequently, supplies of goods moved from Polish territory to the EEZ for the purposes of such an investment constitute domestic supplies of goods subject to VAT in Poland. This is not affected by the fact that, under customs regulations, the goods may be placed under an export procedure and lose their status as EU goods.
Background to the case
The company, which is a registered VAT payer and an EU VAT payer, is carrying out a project involving the construction and subsequent operation of an offshore wind farm in the Polish EEZ. The farm is intended for the production, distribution and sale of electricity.
As part of the investment, the company will purchase goods used for the construction and maintenance of the farm, which will be moved from the Polish mainland to the EEZ. The company has indicated that, in accordance with the position obtained regarding customs regulations, the EEZ does not form part of the customs territory of the European Union; therefore, the goods will, in principle, be placed under the export procedure and lose their status as Union goods.
DKIS’s Position
The DKIS deemed the Company’s position to be correct. The authority confirmed that the Polish WSE should be regarded as part of the national territory for VAT purposes in respect of activities over which Poland exercises sovereign rights, in particular those relating to the construction and operation of offshore wind farms.
Consequently, the supply of goods moved from Poland to the EEZ in connection with the construction of an offshore wind farm constitutes a supply of goods for consideration, taxable in Poland. The DKIS also confirmed the Company’s right to deduct input VAT from invoices documenting such purchases, provided that the goods are used for VAT-taxable activities and there are no grounds for exclusion under Article 88 of the VAT Act.
Significance of the interpretation
The interpretation confirms the special treatment of the Polish EEZ for VAT purposes in relation to offshore investments in which Poland exercises its sovereign rights. This is significant for the classification of supplies of goods used in the construction of offshore wind farms as domestic supplies, even though, for customs purposes, the goods may be subject to an export procedure.
Practical implications
Taxpayers carrying out offshore investments in the Polish EEZ may treat supplies of goods moved from Poland to the EEZ as domestic supplies for VAT purposes, provided they relate to activities covered by Poland’s sovereign rights. Placing goods under the export procedure and the loss of their EU goods status for customs purposes do not preclude the right to deduct input VAT, provided the goods are used for taxable activities.
Individual interpretation of 11 September 2026, issued by: the Director of the National Tax Information Service, ref. no.: 0113-KDIPT1-2.4012.549.2026.2.KT
The Director of the National Tax Information Service (hereinafter: ‘DKIS’) confirmed that an electricity broker may issue a single collective corrective invoice covering both ‘positive’ and ‘negative’ commission adjustments. This is subject to compliance with the requirements concerning corrective invoices and ensuring that the original invoices and the transactions covered by the correction can be unambiguously identified. At the same time, the DKIS pointed out that the inclusion of both increases and decreases in a single document does not mean that all corrections must be accounted for in the same period for VAT purposes.
Background to the case
The company provides intermediary services in the conclusion of electricity supply contracts with end customers. Its remuneration takes the form of a commission and is initially calculated on the basis of the estimated volume of energy consumption. The commission is subsequently adjusted once actual consumption has been determined or due to other circumstances, such as the contract not coming into force or its early termination. The company planned to simplify its accounting by issuing a single monthly collective adjustment invoice covering adjustments relating to previous invoices (both increasing and decreasing the remuneration).
DKIS’s position
The DKIS accepted the Company’s position as correct regarding the possibility of issuing a single collective corrective invoice covering both ‘positive’ and ‘negative’ adjustments. The authority pointed out that the regulations do not prohibit the inclusion in a single document of adjustments relating to multiple original invoices, provided that the document makes it possible to determine which invoices and transactions the individual adjustments relate to.
However, the DKIS did not agree that the entire summary corrective invoice should be recognised in the period in which it was issued. Increases and decreases should be accounted for separately, in accordance with the relevant rules. ‘Downward’ adjustments should be accounted for in accordance with the rules applicable to a reduction in the tax base, whilst ‘upward’ adjustments should be accounted for in the period in which the reason for the increase in the tax base arose.
Significance of the interpretation
The interpretation confirms the possibility of using summary corrective invoices in the settlement of an electricity broker’s commission, even where a single document includes both ‘positive’ and ‘negative’ adjustments. At the same time, the DKIS emphasised that the technical treatment of adjustments on a single document and the presentation of a single net amount does not determine a uniform timing for VAT settlement.
Practical implications
A taxpayer may reduce the number of documents by issuing a single collective corrective invoice, provided that the original invoices and individual corrections can be identified, e.g. by means of a detailed breakdown. However, issuing a single collective invoice does not automatically allow the entire balance of the correction to be accounted for in the period in which the document is issued. For VAT purposes, it is the nature of the individual corrections that matters, not the final balance of the invoice.
Calls for proposals for the energy transition
In the fourth quarter of 2026, businesses will be able to benefit from a range of instruments supporting the energy transition, including, amongst others, biogas and heat storage, energy-intensive industries, the green and digital transitions, environmental investments, cross-border projects and electromobility.
*Some of the information regarding the planned calls for proposals has been compiled on the basis of draft programmes, previous calls for proposals or announcements. The final terms and conditions of support may be subject to change following the publication of the competition documentation
Biogas and heat storage
Cogeneration from biogas produced from biomass
Status: call for proposals announced
Deadline: from August, 31st to November, 30th 2026
Who is eligible: enterprises
Support covers the construction or refurbishment of generation units with a total installed capacity of at least 1 MW, as well as the construction of new, or the extension or modernisation of existing, biomass fermentation plants with a view to using biogas for energy production in high-efficiency cogeneration.
Funding may take the form of a grant covering up to 40 % of eligible costs and a loan covering up to 100 % of eligible costs.
Heat storage in district heating *
Status: call for applications planned
Planned period: from December, 1st 2026 to March, 31st 2027
Who is eligible: enterprises generating or distributing heat as part of a public district heating network, holding the relevant licence
Funding is intended to cover heat storage facilities with a capacity of between 100 m³ and 300,000 m³, connection infrastructure, and activities related to the integration, configuration and adaptation of the storage facility. The planned grant covers up to 50 % of eligible costs, whilst the loan may cover up to 100 % of eligible costs.
* the call for applications documentation has not yet been published
Energy-intensive industry
Energy-intensive industry – renewable energy sources *
Status: call for proposals planned
Planned dates: from November, 2nd 2026 to April, 30th 2027
Who is eligible: enterprises covered by the greenhouse gas emissions trading scheme
The support is intended for the construction or refurbishment of units generating electricity from renewable energy sources, together with energy storage facilities or the connection of the installation to a plant, distribution or transmission network. The energy storage facility will have to be integrated with the source being developed in parallel, and at least 80 % of the energy generated should be used for the enterprise’s own needs.
The planned funding consists of a loan covering up to 100 % of eligible costs, with a bonus of up to 30 % of the amount disbursed, ranging from PLN 5 million to PLN 300 million.
* the call for applications documentation has not yet been published
Energy-intensive industry – temporary electricity price relief for energy-intensive users *
Who is eligible: energy-intensive enterprises operating in specific sectors, holding industrial consumer status and deriving the majority of their revenue from eligible activities
The scheme is intended to cover part of the costs of electricity purchased and consumed for a period of up to three years. At least 50 % of the support received must be allocated to investments in demand response, electrification, energy efficiency, renewable energy sources or resilient and flexible industrial infrastructure. The aid intensity is to amount to up to 70 % of eligible costs, covering 50 % of the volume of electricity purchased and consumed.
* Draft Act on support for businesses in energy-intensive sectors to cover electricity costs
Green and digital transformation
Loans for the green and digital transformation of businesses
Status: call for applications planned
Planned period: October 2026 – March 2029
Who is eligible: SMEs and large enterprises
Support for the transformation of business operations in the areas of digitalisation and environmentally friendly technologies. The call for applications provides for loans ranging from PLN 2.5 million to PLN 15 million, with an interest rate of 0.5% per annum, a repayment period of up to 15 years and a grace period of up to 24 months. No own contribution will be required, and it will also be possible to obtain a conditional grant to repay up to 15 % of the loan principal.
The loan may cover a wide range of investment projects supporting development, increased innovation and improved competitiveness of enterprises.
Investments aimed at improving the efficiency of the use of raw materials, materials and energy, and at reducing waste and emissions, including, amongst others:
modernisation of production processes to reduce waste or enable the reuse of raw materials and semi-finished products,
the redesign of production lines to enable a closed-loop raw material cycle (e.g. separation of material fractions, waste heat recovery),
the purchase of machinery and equipment for the processing, recycling, regeneration or recovery of materials,
the implementation of technologies to reduce water consumption or recover process water,
the application of eco-design principles to products or packaging (more durable, easier to recycle, made from recycled materials),
the implementation of digital tools for tracking the life cycle of products (LCA, PEF, carbon footprint).
Investments related to the automation, robotisation and digitalisation of business and production processes, including, amongst others:
the purchase and implementation of integrated production and logistics management systems (such as ERP, MES and SCADA),
the implementation of solutions based on the Internet of Things, artificial intelligence, cloud computing, predictive analytics, etc.
the digitisation of design and technological processes (e.g. CAD, CAM, CAE, digital twins),
automation of the collection and processing of production and environmental data,
purchase of industrial robots, automated manufacturing centres, workstations or AGVs,
the development of digital services supporting operational activities (e.g. B2B/B2C platforms, online configurators, e-services for customers and partners).
It will also be possible to combine components from the ‘digital’ and ‘green’ strands within a single final investment.
Green investments by businesses
Support for the preparation of CCUS projects
Planned date: Q4 2026
Who is eligible: enterprises.
Activities eligible for funding include:
the preparation of feasibility studies (i.e. analyses to assess whether a project makes technical and financial sense),
preparation of project concepts and FEED (Front-End Engineering Design – i.e. a detailed preliminary technical design) documentation for CCUS projects across the value chain (capture, transport, storage and utilisation of CO₂),
environmental impact assessments (analyses of the investment’s impact on the environment) and obtaining permits (i.e. official authorisations to carry out the project),
preparation of technical (relating to technology), economic (relating to costs and viability) and regulatory (relating to legal provisions) analyses, which are essential for project development.
Estimated value of project funding: EUR 500,000 – 4 million.
Energy storage
Planned date: Q4 2026
Who is eligible: enterprises generating energy from renewable sources in Poland, excluding transmission and distribution system operators.
Funding is to be provided for energy storage facilities with a capacity of between 1 and 10 MW, integrated with existing solar or wind farms.
Eligible costs include, amongst others:
- design and obtaining permits (as part of support for the preparatory phase),
- grid connections and integration with existing renewable energy infrastructure,
- construction and installation of energy storage systems,
- implementation of advanced energy management tools (BMS, EMS).
Estimated value of project funding: EUR 200,000 – 2.5 million.
Geothermal energy
Planned date: Q4 2026
Who is eligible: enterprises, including municipal companies
The scope of the investment includes the implementation of a geothermal heating system, including:
the construction of a new or the extension of an existing heat source utilising geothermal resources,
the conversion of an existing geothermal well (exploratory) for production purposes.
Furthermore, projects should:
include educational and training activities, carried out to complement the investment, with the aim of building knowledge and expertise in geothermal technologies.
Estimated value of project funding: EUR 300,000 - 1.2 million.
Circular water management
Planned period: from October, 15th 2026 to January, 30th 2027
Who is eligible: enterprises, including municipal companies
Support will be provided for:
projects combining implementation investments with educational and awareness-raising activities, so that technical solutions go hand in hand with changes in user behaviour.
Examples of initiatives:
- treatment and reuse of industrial water,
- closed-loop rainwater systems,
- innovative use of rainwater in municipal and industrial applications.
Estimated value of project funding: EUR 100,000 - 1 million.
Circular economy in the construction sector
Planned date: Q4 2026
Who is eligible: enterprises in the construction sector
Eligible activities include, amongst others:
- legal, technical and economic analyses relating to the reuse of construction materials;
- the development of guidelines, tools and certification schemes for circular construction;
- research and development projects, including the testing and implementation of new methods, tools and materials;
- education, training and awareness-raising activities for sector stakeholders;
- monitoring and evaluation studies;
- demonstration activities;
- bilateral cooperation with donor countries on the exchange of knowledge and good practice.
Estimated value of project funding: EUR 200,000 - 500,000.
Cross-border energy projects
Projects of Common Interest – PCI
Status: call for proposals announced
Deadline: November 13th, 2026
Who can apply: promoters of cross-border energy infrastructure projects linking European Union member states
The call covers projects relating to the transmission and storage of electricity and constitutes the first stage of the process for obtaining PCI status.
Projects of Mutual Interest – PMI
Status: call for proposals announced
Deadline: until December, 4th 2026
Who can apply: promoters of cross-border energy infrastructure projects connecting European Union member states
This call for proposals concerns smart electricity grids and smart gas networks and constitutes the first stage of the process for obtaining PMI status.
***
PCI/PMI status enables access to streamlined planning and authorisation procedures and allows applicants to apply for funding from the CEF.
PCI/PMI status enables applicants to apply for a grant from CEF Energy covering up to 50 % of the eligible costs of studies or works, and in specific cases up to 75 %.
The European Commission plans to adopt the third list of PCI and PMI projects by the end of 2027. It is scheduled to come into force in 2028. The call for proposals takes place once every two years.
Electromobility
Support for the purchase or leasing of zero-emission vehicles
Status: call for proposals announced
Deadline: by June, 30th 2029
Who is eligible: enterprises
The support applies to the purchase or leasing of new zero-emission vehicles in categories N2 and N3. Category N2 covers goods vehicles with a maximum gross vehicle weight of over 3.5 tonnes and under 12 tonnes, whilst category N3 covers vehicles with a gross vehicle weight of over 12 tonnes.
The aid takes the form of a grant towards the purchase of a vehicle or a contribution towards the initial payment in the case of leasing.
Charging stations for heavy goods vehicles
Status: call for applications planned
Planned date: Q4 2026
Who is eligible: enterprises
The programme aims to support the construction of charging stations along the TEN-T core network, at intervals of up to 3 km, as well as at logistics centres, operational bases and intermodal terminals. Each eligible station should have at least one charging point with an output of no less than 350 kW.
The grant may cover up to 100 % of eligible costs.
Anna Szczodra
Partner, Attorney-at-law, Co-Head of the KPMG Law in Poland, Head of Energy Sector at KPMG CEE Region
KPMG in Poland