In brief
Poland has been struggling to ease access to the electricity grid for renewable energy sources (RES). After a heated legislative process lasting several months, what is referred to as the Grid Act (UC84) was passed by the Sejm and Senate and is now awaiting signing by the Polish president. The legislation is designed to effect a broad overhaul of the rules for connecting installations to the national power grid and to address long‑standing expectations on the part of the energy sector regarding the streamlining of procedures, greater transparency and unlocking available connection capacity. It is a key element of the anti‑blackout package and is of fundamental importance for Poland’s energy transition. The new provisions are meant to resolve the problems that the industry has been struggling with for years: protracted proceedings, excessive formal requirements, limited connection capacity and low investment predictability.
Key takeaways
- General overview of conditions and measures to prevent the blocking of connection capacity: New tools will be introduced to limit the “booking” and blocking of connection capacity by projects that are not being implemented:
- An increase in the advance payment towards the connection fee
- A non‑refundable fee for submitting an application for grid connection conditions regarding networks above 1 kV that is set at PLN 1 per kW as specified in the application (up to PLN 100,000)
- An obligation to provide collateral securing performance of the connection agreement, which will be forfeited if the investment is not carried out
- Connection agreements will include an obligation to complete subsequent project stages (milestones); failure to comply will trigger automatic agreement expiry, and the released capacity will then be reallocated by way of an auction
- The validity of grid connection conditions will be shortened from two years to one year.
Transitional provisions include an obligation for entities that have received grid connection conditions before the entry into force of the Grid Act but have not yet signed a connection agreement to supplement their advance payment and provide collateral; otherwise, the conditions will expire. Representatives of the RES industry have underscored that these transitional rules, when applied to ongoing projects, effectively apply the law retroactively and infringe rights already acquired, and this is one of the most serious criticisms of the Grid Act.
- Performance security for connection agreements and preferences for ongoing projects: Collateral securing the performance of a connection agreement will amount to PLN 30 per kW for the first 100 MW and PLN 60 per kW above 100 MW:
- For offshore wind producers, the collateral will be lower than currently required under the Offshore Act, and a corresponding part of the collateral will be refunded within three months from the entry into force of the Grid Act.
- Investors who obtained grid connection conditions before the entry into force of the Grid Act but did not manage to sign a connection agreement will have the option of providing the entire amount of collateral after signing an agreement instead of paying the advance towards the connection fee. In this case, the operator must refund the advance previously paid within 30 days of receiving the collateral.
- For projects already in progress, relief is provided by way of allowing the provision of collateral corresponding to 25% of the stat
- Milestones and implementation deadlines, including extension fees: A final building permit will have to be obtained within 30 months for photovoltaic installations and energy storage facilities and within 42 months for onshore wind farms and biogas plants. If this milestone is not achieved, a connection agreement will expire by the operation of law and the collateral forefeited unless the delay is due to force majeure. A one‑time extension of such deadlines by up to 24 months is allowed upon payment of a fee calculated at a rate of PLN 60/kW and capped at PLN 12 million. In the case of projects for which conditions or agreements already exist, the fee is 50% of this base amount.
- Possible change of project location: The Grid Act allows for the modification of grid connection conditions in terms of project location, provided that the installation remains within the same municipality or is situated in directly adjacent municipalities. This limitation does not apply to the location of a substation forming part of the connected facility. This solution responds to investor demands by simplifying the optimization of project locations in the RES sector, facilitating the continuation of projects without losing connection rights while maintaining spatial‑planning coherence.
- Cable pooling and optimization of existing grid infrastructure: The cable pooling framework will be expanded to all types of installations, with a particular emphasis on energy storage, allowing shared use of a single connection and better utilization of grid capacity. The obligation to perform a grid impact study will be waived when adding another installation or increasing installed capacity, provided the connection capacity remains unchanged. Biogas plants connected to networks below 110 kV may also be exempted from a grid impact study if a commitment is given to operate in accordance with a schedule agreed with the operator and which reflects power system needs.
- Simplification of procedures and digitalization of the connection process: The proposed provisions reduce the formal requirements for applying for a grid connection. The number of documents submitted with an application has been reduced, including the removal of the obligation to attach a zoning decision. The entire process is to be handled electronically, which will improve communication with operators. Procedural deadlines have also been introduced: operators will have 60 days to request completion of an application, while the applicant will have six months to submit a refusal‑to‑connect case to the president of the Energy Regulatory Office (URE).
- Operator transparency: Operators will be required to publish information on available connection capacities and on the criteria and methodologies employed for calculating grid capacity as well as to share information about the status and method of processing connection applications. This is expected to facilitate the planning of new investment projects.
- Electronic application systems: Centralized IT platforms will be established for the electronic submission, handling and monitoring of applications, thereby improving transparency, predictability and overall efficiency of the connection process.
- Extended vacatio legis for projects under development: Responding to RES business concerns, a six‑month vacatio legis (suspension of entry into force) will apply to ongoing projects, with the Grid Act otherwise entering into force 14 days after publication. The aim is to allow more projects with existing grid connection conditions to benefit from the more favorable transitional provisions, giving them an additional six months to adjust to the new requirements and to accelerate their investment work.
Background
The draft Grid Act was added to the legislative agenda in January 2025 and submitted to the Government Legislation Centre in March. Although the Ministry of Energy emphasised its priority character, work on the Grid Act was significantly prolonged, and the proposal faced substantial criticism from the RES sector from the outset. It was only in March 2026 that the draft was ultimately passed by the Polish Parliament and submitted to the president for signing.
The principal objective of the reform was to unlock grid connection capacity and make administrative procedures related to connecting renewable energy sources more flexible. According to data from the Ministry of Energy, grid connection conditions have been issued for approximately 240 GW — around 150 GW for RES installations and about 90 GW for energy storage facilities. However, a substantial number of these projects are inactive, effectively “freezing” available connection capacity. These inactive initiatives are commonly referred to as “phantom projects” or “zombie projects”, which, in the view of the Ministry of Energy and PSE (the Polish power transmission system operator), block the development of new investments.
The industry, however, has pointed out that measures aimed at eliminating phantom projects may in practice also affect real but capital‑intensive projects that require longer development timelines. New obligations regarding financial security and shortened deadlines may particularly hinder market entry for smaller players and, in extreme cases, lead to the loss of rights already acquired for projects already in progress.
This divergence in assessments became one of the main factors prolonging work on the act. The Ministry of Energy and PSE consistently argued that the reform’s purpose is to release capacity blocked by inactive projects to enable the development of new sources, including RES and battery energy storage systems (BESS) in particular. Investors, on the other hand, maintained that the current situation results largely from past decisions on the part of grid operators, and that the proposed changes attempt to remedy long‑standing systemic shortcomings at the expense of active projects.
Conclusions
The aim of the Grid Act is to ensure the more efficient allocation of grid capacity by eliminating projects that do not progress to the implementation phase and by reinforcing schedule discipline. The package of financial and administrative instruments (shorter validity of connection conditions, application fee, performance collateral for connection agreements, milestones) is intended to make declared connection capacities more realistic and to streamline access to grid connections. The expected outcome is faster verification and the release of technically available capacity along with greater predictability for both operators and investors.
At the same time, the amendment introduces increased capital and organizational requirements, which may limit the activity of smaller market participants and pose a substantial hazard for projects with longer development cycles. The industry has expressed particular concerns regarding the risk of losing acquired rights, the excessive burden placed on early‑stage projects, and the potential discouragement of investment in large, complex or innovative projects that naturally require extended preparation. It is also noted that the obligation to promptly provide financial security and the shorter validity period of grid connection conditions may lead to early project attrition based not on technical quality but on an investor’s ability to bear costs at a very early stage of a project.