Zum Hauptinhalt springen

What the Public Consultation reveals about Poland’s Updated National Energy and Climate Plan

CATF's recommendations

January 9, 2025 Category: Policy
warsaw

Poland’s power sector must undergo a complete U-turn, shifting from its current 70% reliance on coal generation to almost the same percentage of zero-carbon sources by mid-century. This monumental task—essential for meeting ambitious climate targets —will remain out of reach unless Poland rethinks its energy planning and implementation of key policies, including its updated National Energy and Climate Plan (NECP).  

NECPs are critical planning documents meant to outline EU Member States’ targets, policies, and measures that will enable them to reach the 2030 EU climate targets. Countries have been revising these plans to reflect more ambitious targets and final updates were due for submission by 30 June 2024.1 At the time of writing, 5 countries2 have yet to submit their final plans to the European Commission, prompting infringement procedures.  

Poland is among the countries that missed the deadline. As an EU Member State, it has an obligation to adjust its energy policy to achieve EU policy goals. Such transposition presents both a challenge and a transformative opportunity for Poland’s entire economic prosperity and competitiveness.  

Poland is the third largest emitter in the EU, following Germany and Italy, in terms of total annual emissions. Despite some recent progress in renewable energy development, emissions reductions, and energy efficiency measures, 85% of Poland’s energy still comes from fossil fuels, making its energy sector one of the most carbon-intensive in Europe. 

As the nation stands at a critical juncture in its energy transition, moving away from coal, it is essential that the final updated NECP is ambitious, coherent and well-designed to steer investments towards the long-overdue clean energy transition. In the broader EU picture, this update comes at a crucial moment, marked by significant geopolitical shifts and a renewed focus on industrial competitiveness in Europe. This element, together with the planning of the net-zero infrastructure should be approached with precision and should strategically reflect on newly enacted legislation3 that will ultimately support Poland’s leadership in industrial decarbonisation. This effort is even more critical as Poland currently holds the six-month presidency of the Council of the European Union until 30 June 2025—a chance to lead by example.

How can Poland lead the energy transformation?   

To address Poland’s energy transformation, the government held a public consultation on its updated NECP, based on a more ambitious scenario that includes additional measures (WAM) to meet the 2030 climate targets. CATF contributed technical input during the consultation period, which ran from mid-October to mid-November 2024. While acknowledging progress in the draft plan, significant gaps remain in both planning and policy to meet decarbonisation goals.  

This briefing distils the 600-page plan, identifying key shortcomings and offering actionable recommendations to strengthen it, all while ensuring clean firm power and sustaining industrial competitiveness. 

Summary of key recommendations to improve the updated Polish NECP:

  • Poland’s decarbonisation pathway: Support the deployment of a diverse portfolio of low- and zero-carbon technologies, with an option-based approach, to hedge against the risks of underperformance by a single technology. 
  • Modelling: Develop scenarios representing a range of possible futures for Poland’s electricity system. 
  • Clean Hydrogen: Ensure suitable volumes of clean hydrogen are produced to meet Poland’s needs, through all available clean hydrogen production pathways, prioritising its deployment in end-uses with limited to no other decarbonisation options available. 
  • Clean Technologies: Create a supportive regulatory and financial framework for Carbon Capture and Storage (CCS) and Small Modular Reactors (SMRs) development. 
  • Methane Emission Reductions: Delineate clear, actionable steps to curb methane emissions and work towards the implementation of the Methane Regulation. 
  • Financing:  Provide detailed national objectives and targets on funding for clean technologies and consider supporting long-term contracts like CCfD.   
  • Research, Development and Innovation: Increase budgetary spending on R&D and clearly articulate clean energy R&D&I needs, objectives and funding targets for clean energy technologies.  

Key recommendations to improve the Polish NECP

1. Poland’s decarbonisation pathway

    The energy crisis in Europe, amplified by Russia’s war in Ukraine, has exposed the perils of over-reliance on a single energy supplier and technological pathways. It has also questioned the related decarbonisation narrative in the European Union, which, for years, has been characterised by a narrow set of clean technology options. The new geopolitical reality is starting to shift perceptions of energy security, industrialisation and decarbonisation, with a new awareness of the need to assess strategies and plans through the lenses of economic growth, competitiveness, innovation, and renewed partnerships.   

    Looking at the updated NECP, (figure 1), there is an increased interest in diversifying Poland’s clean technology portfolio, moving away from the historical dominance of coal to progressively incorporating other options. Concretely, the Ministry of Climate and Environment is planning to prioritise achieving a 32.6% share of RES as a key commitment and a large part of the emissions reduction towards net zero, primarily through wind and solar power. Despite these ambitious goals, renewables cannot cover all the abatement needed and they have limits in terms of deployment pace, transmission planning, land use, supply chain bottlenecks and access to critical minerals and applications to decarbonise specific industries. While this could be an accomplishing buildout, Poland will also require substantial amounts of non-weather-dependent, always-available zero-carbon power, i.e. clean firm power, to maintain reliability and contain costs. As such, other technologies should be rigorously evaluated based on their potential for emissions reduction, scalability, and affordability.  



    By embracing a diverse set of clean firm energy generation pathways with tailored support mechanisms into its final NECP, Poland will improve its changes of succeeding towards the path to net zero by hedging risks. Some examples of such climate-protecting technologies include clean hydrogen and ammonia, carbon capture, removal, and storage, small modular reactors (SMRs), and innovations such as superhot rock geothermal energy and fusion energy. Achieving climate neutrality in Poland will require the availability and deployment of a wide range of technologies, ensuring sector-specific decarbonisation with appropriate tools for specific situations and challenges.

    Recommendations: 

    • Support the deployment of a diverse portfolio of low- and zero-carbon technologies, with an option-based approach, to hedge against the risks of underperformance by a single technology. 

    2. Modelling 

    According to the Governance Regulation, Member State NECPs should model decarbonisation trajectories to 2030 and beyond using two scenarios – a scenario “with existing measures” (WEM) and a scenario “with additional measures” (WAM) reflecting the requirements from the Fit for 55 Package. According to the Europea Commission guidance, Member States are also encouraged to make use of the most up-to-date modelling tools and approaches. In February, Poland presented the plan based on a WEM scenario and recently submitted the WAM scenario for consultation, which incorporates key elements essential for building a low-carbon energy system. Among others, the WAM scenario includes a significant increase in the share of renewable energy sources in gross final energy consumption by 2030—moving from 29.8% from the previous plan (WEM) to 32.6%. It also assumes that the country will cut greenhouse gas emissions by 50.4% relative to 1990. A welcomed increase that, however, still falls short from the 55% target set the by the EU. Given Poland’s unique electricity mix (Figure 1) this is a commendable effort from the 23% achieved greenhouse gas reductions in 2022. Moreover, in the ambitious NECP scenario (WAM), it is assumed that nuclear power plants will be commissioned on schedule. According to the adopted plans, the first reactor of a nuclear power plant is expected to be operational in 2035, with subsequent reactors coming online in 2036, 2037, 2039, 2041, and 2043. Additionally, two reactors of Korean design are anticipated to be commissioned in 2039 and 2041.  


    2030 Target (WAM Scenario) 2030 EU Target 
    GHG Emission reduction (with Land Use, Land-Use Change and Forestry (LULUCF)  50,4% compared to 1990 55% 
    Emission reductions in non-Emissions Trading System (ETS) sectors relative to 2005    -18,2%  -17.5%  
    Share of Renewable Energy Sources (RES) in gross final energy consumption  32.6% 42.5% 
    Thermal coal production 22 million tonnes 

    Based on these projections, Poland’s current decarbonisation strategy can only be successful under the best-case scenario which is the WAM scenario, which presents a simple and limited subset of desired and anticipated future. This limited modelling choice has some shortcomings as it does not account for varying levels of clean energy development barriers—such as land availability, social acceptance of siting new infrastructure, supply chain constraints and import dependencies among others. Integrating more challenging scenarios will provide a better understanding of the scale and scope of change that may be required to succeed in the net zero infrastructure challenge ahead. 

    CATF commissioned a technical study which explores scenario-based pathways for Poland to achieve a decarbonised power grid by 2050. By exploring a range of scenarios, from optimistic to conservative, the study presents a nuanced view of potential futures for Poland’s electricity system, highlighting the importance of a diverse technological portfolio. With 19 scenarios considered, it provides a broad spectrum of possibilities, ensuring a well-rounded understanding of the pathways toward decarbonisation, and considers aspects such as energy security, land use, and infrastructure requirements.  

    Recommendation: 

    • Develop modelling scenarios representing a range of possible futures for Poland’s electricity system. 

    3. Hydrogen’s Role in Poland’s NECP  

    The importance of hydrogen for industrial decarbonisation

    Energy-intensive industries and segments of the heavy-transport sector in Poland will require clean hydrogen to decarbonise their operations. These are sectors of the economy where no, or very limited, other energy-efficient or cost-effective decarbonisation options are available. Despite this, Poland’s NECP adopts a broad-based approach, allocating hydrogen across a multitude of sectors, including power generation and light-duty transport, such as buses. This strategy risks suboptimal utilisation of this scarce and critical resource during a crucial period when the clean hydrogen industry is still in the early stages of development and scaling. Rather than dispersing clean hydrogen indiscriminately across multiple areas, efforts should concentrate on those hard-to-abate industrial segments where unabated hydrogen is already used or where hydrogen will be necessary for decarbonisation, including in refining, chemicals and fertiliser production, and primary steel manufacturing. By directing scarce clean hydrogen supplies first to these ‘no regrets’ sectors, the country can ensure that the most emissions-intensive industries take meaningful steps toward decarbonisation as soon as possible. 

    In parallel, concerns remain about the costs differentials of producing electrolytic hydrogen compared to the fossil-based alternatives, as well as the opportunity costs associated with diverting clean electricity from other critical uses. CATF analysis finds that the lowest achievable cost of electrolytic hydrogen production is likely to be USD $3/kg hydrogen in foreseeable future. Meanwhile the average clean hydrogen production price in Europe is currently around €7/kg hydrogen. Even if European hydrogen developers were able to procure all their equipment and build the project for free, the cost of hydrogen production from just electricity (€110/MWh in the EU) would average €6/kg hydrogen.  

    In the light of these cost constraints, it becomes even more crucial for Poland to channel its clean hydrogen resources into applications that deliver the highest impact—notably by replacing the carbon-intensive hydrogen currently used in its industrial sectors. Poland’s significant industrial sector must take priority over other applications, such as hydrogen for power generation or light-duty vehicles, given that the country already consumes significant volumes of unabated hydrogen in many industrial processes, creating a no-regrets opportunity for clean hydrogen deployment. By taking this strategic approach, Poland can ensure that each investment in clean hydrogen yields meaningful emissions reductions and bolsters long-term competitiveness of its economy.  

    The exclusive use of renewable energy for electrolytic hydrogen production poses additional challenges for some industries, which require a constant and uninterrupted supply of the molecule. While Poland has the technical know-how to produce hydrogen, it needs to generate enough clean energy for large-scale hydrogen production and other important needs, such as grid decarbonisation. In recent years, it has made good progress in deploying more renewables but still lags behind other EU countries. Further, demand for renewable energy sources only continues to increase, as the country’s looks to shift its energy dependence away from coal towards cleaner sources. Therefore, investment in other low-carbon hydrogen production methods is essential to ensure security of supply. A comprehensive framework and market tools must also be in place to guarantee reliable and constant clean hydrogen supply to these priority industries. 

    Issue with hydrogen in the polish NECP

    Hydrogen’s role in decarbonisation across various sectors in the Polish economy is briefly outlined in the NECP, but it lacks a strategic regulatory framework in supporting sufficient supply its deployment to priority sectors. The NECP draft, for example, envisions the deployment of 800 hydrogen buses, which indicates an interest in hydrogen-powered road transportation. However, focusing on light-duty vehicles may not be the most strategic use of limited hydrogen resources as electrification is more advanced in this sector, offering immediate deployment potential with existing infrastructure. 

    Similarly, the current version of the NECP suggests blending hydrogen into the natural gas grid for residential and district heating. However, this strategy offers minimal emissions reductions due to infrastructure limitations. As a recent CATF publication shows, blending hydrogen into the grid is an inefficient use of a valuable resource better suited to directly decarbonise sectors that lack decarbonisation alternatives, such as industrial sectors. The pursuit of large-scale hydrogen blending can potentially disrupt the clean hydrogen market, diverting investment away from more critical end-uses, leading to long-term lock-in effects that slow the transition to genuinely low-carbon solutions. In addition, changing gas-hydrogen blends leads to significant uncertainties in terms of pipeline integrity, corrosion and safety risks, that can only be fully understood after further studies. 

    To support this work, Poland can work to quantify more precisely how much clean hydrogen its needs for its priority industries and ascertain whether it can meet this entire demand profile domestically or will need to turn to imports from neighbouring countries. Should any large-scale imports prove necessary, a clear and sound strategy needs to be developed, identifying the most technoeconomic import pathways, identifying reliable supply partners, and build priority infrastructure capable of handling international hydrogen flows. 

    Poland is unlikely to be able to fully cover the demand for hydrogen with renewables-based electrolytic production capacities alone, due to the high production costs and the increasing demand of these resources for decarbonising electricity. Creating a level playing field for all clean hydrogen production pathways that meet the EU’s emissions reduction threshold ensures that foundational emissions reductions are achieved, enabling a cleaner and more sustainable energy system, which will ultimately support the large-scale deployment of hydrogen in the future.  

    What should be improved

    • Focus hydrogen deployment in priority sectors, accurately assessing home much clean hydrogen each sector will need and map how much of the demand can be met through domestic capacity versus imports. Policymakers should prioritise hard –to-abate sectors to maximize decarbonisation impact where electrification is less advanced. In industry, particularly existing users of unabated hydrogen like the refining and chemicals sectors, and industries where electrification is costly or impossible to implement. One of the key missing elements in the draft NECP is a solid, data-driven assessment of how much clean hydrogen is needed by these key industries. Rather than setting production targets and leaving production allocation to market forces, policymakers should carefully analyse where clean hydrogen will add the most value and how much is needed and can cost-effectively deliver significant emissions reductions. As such, domestic production capacity may need to be supplemented with some level of international imports. If proved necessary, a systematic plan to secure and integrate imported hydrogen into Poland’s capacity would need to be developed. Further, policymakers should discourage using hydrogen in sectors where more suitable and less resource-intensive low-emission solutions are already available, such as blending hydrogen into the gas grid, or using it for home heating or light-duty vehicles. Based on these evidence-driven assessments, a hierarchical allocation of hydrogen can help achieve sustainable market growth, avoid unnecessary waste of resources, and ensure that clean hydrogen meets its fullest potential as one pillar of Poland’s decarbonisation strategy. 
    • Support a diversity of clean hydrogen pathways, not just renewables-based, to ensure security of Poland’s clean hydrogen supply.  Applying a narrow, and often colours-based, focus on clean hydrogen production hydrogen, prioritising renewables-based hydrogen over other forms without quantitative assessments of its production possibility will limit Poland’s true clean hydrogen potential. Further, it may (unintentionally) divert important renewable power away from more pressing needs, such as replacing coal power and decarbonising the electricity grid. By extending opportunity to other low-carbon hydrogen production pathways – provided they meet the EU’s strict emission reduction criteria – Poland can diversify its sources of clean hydrogen and increase its supply faster, providing security to offtakers.  

      Recommendations: 

      Hydrogen demand: 

      • Accurately quantify the country’s clean hydrogen needs for priority sectors, determine how much of this can be met through domestic production. 
      • Strategic prioritisation for end-use sector deployment, focused on sectors that need the clean hydrogen the most for their decarbonisation (refineries, chemicals and fertilisers sector, etc.) 
      • Avoid blending hydrogen into the natural gas grid for residential and district heating.  
      • Limit hydrogen for power to as-needed cases by taking a full systems analysis with alternative clean firm power production that requires limited or no LDES. 
      • Limit the deployment of clean hydrogen in light duty vehicles (such as buses) unless no alternatives are available. 

      Hydrogen production: 

      • Ensure sufficient volumes of clean hydrogen are available, produced through all available clean hydrogen pathways.  
      • Open hydrogen production support schemes to multiple low-carbon pathways rather than focusing solely on renewables-based hydrogen. 
      • Ensure any renewables-produced hydrogen does not cannablise clean energy for Poland’s grid decarbonisation. 
      • Ensuring that all suitable, demonstrably low-GHG options contribute to Poland’s clean hydrogen supply and help avoid diverting critical green energy resources away from more urgent decarbonisation efforts. 

      Hydrogen imports: 

      • If required, develop a coherent, techno-economically sound import strategy alongside well-planned infrastructure investments.  
      • Collaborate closely with neighbouring Member States to develop priority, interconnected infrastructure. 

      Hydrogen sector governance: 

      • Establish a dedicated national and local contact point for hydrogen projects to boost investor confidence. Such “one-stop shop” advisory points would provide comprehensive guidance on administrative procedures and facilitate efficient project implementation. 

      4. Poland’s Nuclear Energy Future  

      The importance of nuclear energy

      The ambitious scenario outlined in the NECP projects that by 2040, nuclear energy will generate 58.1 TWh of gross electricity, while total electricity production in Poland is expected to reach 308 TWh. As recently stressed by Wojciech Wrochna, Government Plenipotentiary for Nuclear Energy, the Polish Nuclear Power Program (PNPP) is currently being updated, with the final version to be presented in January 2025. The update reflects a more phased and diversified approach to nuclear power development than the ambitious projections of the PNPP. A significant change in the PNPP update is removing the requirement for a single technology for all nuclear projects, paving the way for a competitive choice of technology for a second nuclear power plant. This change also aligns with Poland’s strategy to engage various suppliers worldwide, including potential partners from France, Korea and the United States. 

      According to Wrochna, the commissioning of the first nuclear power plant in Choczewo will be postponed until 2036 (previously 2033). The market dialogue for the second nuclear power plant is expected to begin in 2025, and the selection of technology and contractors is expected to take place by 2026. In addition, the updated PNPP is to emphasise repurposing existing coal-fired power plants for future nuclear power plants, which is in line with Poland’s transformation goals and is likely to be supported by both the public and stakeholders.  

      By the end of this forecast, the total capacity of all nuclear units is projected to be approximately 7.4 GW in 2040, which aligns with Poland’s current energy policy. The policy anticipates a significant growth in nuclear energy capacity from 6–9 GW by 2043. The NECP also introduces new developments, such as the inclusion of a third large-scale nuclear power plant, indicating a promising future for the sector.   

      Currently the NECP envisions a net small modular reactor (SMR) capacity of 600 MW by 2035 and 1,200 MW by 2040. It also sets out the government’s commitment to create the conditions for private actors to realise SMRs. This includes supporting the development of human resources and skills, raising public awareness and strengthening the capacity of the Polish industrial sector. The success of SMR technology development will depend on several factors, including the ability of technology suppliers to secure a sufficient order book while ensuring the production of reactor modules at a competitively low cost while maintaining quality. In addition, access to finance, the ability to build the design infrastructure and supply chains, the experience of both the technology supplier and the developer, and political support will be critical. Companies with years of experience in reactor design, a proven track record of deployment and the trust of governments and financial institutions will have a competitive advantage. 

      Issue with nuclear in the Polish NECP

      Unfortunately, the draft NECP overlooks the potential role of nuclear energy in district heating, only briefly mentioning the application of SMRs in waste heat utilisation. Although the NECP envisaged SMRs development goals, the plan still lacks a clear roadmap with milestones and timelines to achieve these targets. For SMRs to become a reality in the next decades, Polish policymakers must actively plan for SMR development today, as they could play a vital role in enhancing Poland’s energy security and achieving its climate goals. The Polish legislator should react to market changes related to the development of nuclear power plants and, if necessary, adapt the legislation to facilitate implementation. Legislation should support investors while harmonising their interests with social and economic needs, safety requirements and international standards. A flexible regulatory approach is promoted through an active and equal dialogue between the developers of nuclear projects and their stakeholders. 

      What should be improved: 

      • Improve Poland’s nuclear regulatory framework by tailoring requirements to specific reactor types, technologies, and capacities, streamlining and shortening licensing and permitting procedures for SMRs. An explicit development pathway should include a phased approach with operational milestones for SMR projects, starting from the creation of fit-for-purpose policies to the construction of a first Polish SMR plant. This could involve development of a clear roadmap or industrial strategy for deployment of this technology. Implementing such a framework would reduce redundancies, lower costs, and accelerate the commercialisation of the regional SMR projects. This is essential to support the commercialisation of SMRs in the region, diversification strategies, and the establishment of secure, long-term supply chain for nuclear components and fuel.  Polish nuclear law currently needs to differentiate regulatory requirements based on reactor type, technology, or capacity, which means that SMRs must undergo the same licensing and permitting procedures as large-scale nuclear units4. In Poland, the National Atomic Energy Agency president oversees this process. Although “licensing” is not legally defined in Polish legislation, the relevant regulations describe its elements, aiming to secure the necessary approvals for operating a given facility within the country. For SMRs, this may prove even more time-consuming than for large reactors, primarily due to limited domestic experience, relatively nascent global implementation, and the constrained capacities of the regulatory authority. At the same time, the smaller scale, more straightforward construction, and reduced fissile material of SMRs should make the safety assessment more straightforward. This, in turn, suggests an opportunity for streamlining and shortening regulatory procedures specifically for licensing and permitting. 
      • Establish transparent, well-structured financing models to ensure the economic competitiveness of SMRs. In Poland, SMR projects will be next-of-a-kind units that still need to progress down the cost curve. Uncertain cost trajectories and wide-ranging current estimates—provided mainly by project developers—warrant caution. These estimates tend to be in the $45-110/MWh for projects in some advanced economies, depending on the degree of technology maturity and assumed discount rate, while some developers aim for a range of $50-60/MWh for Nth-of-a-kind units. Although these estimates carry a high dose of uncertainty, achieving cost reduction requires a combination of appropriate government guarantees, well-structured financing models to ensure acceptable risk levels for banks, and the economies of numbers generated by a fleet-based, regionally integrated investment campaign. Such an approach can help reduce unit costs and foster the development of local competencies, services, and infrastructure essential for building a robust, sustainable SMR sector which could become a major stimulus for Polish economy. 
      • Promote cross-border cooperation and coordinate efforts within the European Nuclear Alliance, engaging with key regional partners to foster SMR development, harmonise regulations, and attract international investment. Another missed opportunity is the absence of plans for cross-border collaboration on SMRs. Poland could deepen cooperation within neighbouring countries in the CEE region and wider across Europe to jointly advance SMR initiatives. In the light of Polish industry’s plans to invest in SMR, pursuing technological diversification, promoting regulatory cooperation, and developing a comprehensive national implementation strategy are well-founded approaches. Cooperation within the European Nuclear Alliance, particularly with regional partners such as the Czech Republic and Romania, which are also committed to developing nuclear energy facilities, could play a central role. Such cooperation could facilitate the development of an EU-wide strategy for nuclear energy facilities and attract investment from key international partners.  
      • Develop and implement a transparent regulatory framework for the final disposal of nuclear waste, ensuring long-term public support and sustainability of Poland’s nuclear energy. Due to Poland’s ambitious action towards deployment on nuclear technologies it is imperative that Polish Government outlines a pathway for final disposal of nuclear waste. Although, the issue of nuclear waste is not imminently pressing, it should be addressed in a transparent and inclusive manner to ensure continued support of the Polish public for nuclear energy.  

      Recommendations: 

      • Improve Poland’s nuclear regulatory framework. 
      • Establish transparent, well-structured financing models to ensure the economic competitiveness of SMRs. 
      • Promote cross-border cooperation and coordinate efforts within the European Nuclear Alliance. 
      • Develop and implement a transparent regulatory framework for the final disposal of nuclear waste. 

      5. Carbon Capture, Utilization, and Storage (CCUS) in industry

      The Importance of CCS

      Scientific evidence shows that carbon capture and storage (CCS) technologies will need to be deployed at a large scale if Europe is to achieve climate neutrality by 2050. CCS will be needed to both rapidly reduce CO2 emissions as well as permanently remove CO2 from the atmosphere. In all scenarios highlighted by the European Scientific Advisory Board on Climate Change5, carbon capture and storage plays a significant role in reducing emissions from industrial processes and fossil fuels and provides a large amount of CCS-enabled carbon removals.  

      Referencing Poland’s point source emissions data, CCS is crucial for decarbonising the 40.6 MtCO₂ emitted annually from sectors such as cement, steel, chemicals, and refineries, which collectively contribute 15% of Poland’s total CO₂ emissions. Employing CCS in these sectors, alongside electrification and energy efficiency improvements, can support the production of net-zero products, thereby preserving the competitiveness of Poland’s industries as other countries transition to climate-neutral production. Furthermore, Poland’s energy-intensive industries employ over 400,000 workers and contribute a disproportionately high industrial gross-value add (GVA) compared to the EU average. CCS deployment at scale is, therefore, not only environmentally beneficial but economically strategic considering the rising carbon price of the EU ETS, securing jobs and strengthening industrial resilience in the transition to net-zero. Efforts to accelerate CCS deployment have increased in Poland over the past years, both in terms of projects and policy, however the environment to bring about deployment at the scales necessary is lacking. 

      Issues with CCUS in the polish NECP

      According to CATF’s analysis, Poland has one of the largest potentials for CO2 storage in Europe. However, this great potential is not adequately reflected in the current draft NECP, where CCS6 are merely acknowledged as a technology that can play a role in Poland’s decarbonisation strategy. The role of CCS should be further elevated in the plan, specially as critical technologies to decarbonise its hard-to-abate industrial sectors. Similarly, there is an untapped potential for CCS in the energy sector which should be further encouraged in the final NECP.  As the country phases out coal fired power generation, CCS can be deployed to decarbonise gas-fired power plants able to provide firm power and grid stability during periods of low renewable energy availability. As CATF’s report on decarbonizsng Poland’s power system illustrates, an optionality-based approach which includes CCS equipped gas power results in the lowest average electricity price while ensuring that Poland’s energy grid remains flexible and reliable while advancing towards climate neutrality.  

      Looking at Direct Air Capture with Carbon Storage (DACCS), the plan presents it as a promising avenue for carbon removal in the country. However, its application in Poland is likely to be very limited due to high energy requirements. Given Poland’s current energy mix, which is still carbon-intensive, DACCS would not lead to substantial net-negative emissions in the near term. Optimal deployment of DACCS requires siting near grids with low carbon intensity to ensure net-negativity, which means other EU regions may be more suitable for DACCS. For Poland, focusing on bio-based removals through BECCS and Bio-CCS is likely to be more impactful, while pilot and research DACCS projects in Poland proceed. 

      Overall, the plan should incorporate the European Commission NECP guidance and build on the groundwork laid by the Net Zero Industry Act (NZIA) and the Industrial Carbon Management strategy (ICMS) to get a better picture of the planned CO2 storage sites and estimation of potential CCS demand. The plan still leaves substantial room for improvement, particularly with regards to fully leveraging its significant national CO₂ storage potential, understanding of current and intended measures to support CCS project development, steps to remove barriers to regulatory frameworks, deployment plans and targets, incentives, funding or facilitating cross-border CO2 transport and storage infrastructure for decarbonising industries. 

      What should be improved: 

      • Maximise Poland’s CO₂ Storage Capacity by investing in geological characterisation studies, securing a robust scientific basis for future storage projects. According to CATF’s analysis, Poland has an estimated CO₂ storage potential exceeding 15 Gt, primarily within saline aquifers (14.3 Gt) and hydrocarbon fields (1 Gt). This capacity is sufficient to store 600 years’ worth of emissions at anticipated post-2050 levels, underscoring Poland’s strategic advantage in deploying CCS as a long-term climate solution. To fully harness this potential, Poland should invest in geological characterisation studies to comprehensively assess these storage sites which would move timelines forward for future storage projects. 
      • Remove barriers to facilitate cross-border CO₂ transport and storage: Given the scale of Poland’s storage capacity, cross-border CO₂ transport and storage could offer significant efficiencies and provide an economic opportunity for the country. Poland should prioritise removing regulatory barriers that hinder cross-border CO₂ flows, including MOUs with other European countries and ratify the amendment to the London Protocol as well as work towards potential revisions to the Helsinki Accord to permit offshore CO₂ storage. These regulatory adjustments would enable Poland to leverage its storage capacity to support decarbonisation efforts across the EU while providing more CO2 for national storage projects. 
      • De-risk CCS investments by implementing Contracts for Difference (CCfD) and leverage EU funding to complement national funds: Poland’s implementation of a Contracts for Difference (CCfD) mechanism could play a pivotal role in de-risking CCS investments and accelerating the deployment of low-carbon technologies in hard-to-abate sectors. When designing such schemes, the Government should promote and leverage EU funds like the Innovation Fund and the Just Transition Fund (JTF) to complement national funding, reducing the financial burden on the Polish government while maximising available investment inflows for CCS infrastructure.  Furthermore, the CCfD contracts should be tailored to address the entire CCS value chain—from capture to transport and storage. By doing so, Poland can create a comprehensive, resilient infrastructure that attracts investment, facilitates CO₂ transport and storage, and establishes Poland as a key player in CCS across the region. Structured contracts that ensure stability and predictability over 10-15 years will attract private sector interest and enable projects to reach final investment decisions. 
      • Outline plans for negative emissions capacity such as through deploying Bioenergy with Carbon Capture and Storage (BECCS) in full consideration of the limits and availability of sustainable feed stocks. In the near term, BECCS can offer opportunities for negative emissions in Poland through leveraging existing biogenic point sources, such as the pulp and paper, bioenergy, and waste-to-energy sectors. Sectors with high-purity CO₂ streams, can reduce capture costs and potentially provide negative emissions if implemented sustainably. This approach would align with Poland’s climate objectives but also supports the development of essential CO₂ transport and storage infrastructure. 
      • Identify and analyse the legal barriers. Despite recent amendments to Poland’s regulatory framework governing CCS and CCU, the current legal environment remains too fragmented and rigid to stimulate effective implementation. There is a pressing need to adjust key legislation so that the conditions for carbon capture, transportation, utilization, and storage more closely reflect technological realities and market requirements. On one hand, the Energy Law still fails to clearly define CO₂ transmission, leaving significant uncertainties about whether and how transportation other than pipelines might count towards emission reductions. On the other hand, the Geological and Mining Law and related ordinances of the Ministry of Climate and Environment have been constrained by particular and overly restrictive provisions. For instance, the Ordinance of the Minister of Climate and Environment on the areas in which it is allowed to locate the underground carbon dioxide storage complex identifies only a single offshore Cambrian reservoir in the Polish economic zone in the Baltic Sea as an eligible storage site, severely limiting the development of domestic CCS projects. Other ordinances impose overly demanding financial securities on investors, potentially undermining economic viability and industry willingness to engage. A more comprehensive revision of these acts, enabling the development of critical infrastructure, would help diversify authorized storage locations, allow for more flexible transport options beyond fixed pipelines, and define technical standards and operational parameters attuned to current technological capabilities.  Introducing an explicit public-entity operator for CO₂ transport services and stable, long-term public policies would encourage private-sector participation and investment. Private actors may hesitate to engage in full-scale CCS ventures without these changes. By confronting these regulatory shortcomings, Poland can create a legal environment conducive to the cost-effective, secure, and technologically up-to-date deployment of CCS and CCU projects. 

      Recommendations: 

      • Maximise Poland’s CO₂ Storage Capacity by investing in geological characterisation studies, securing a robust basis for future storage projects.  
      • Remove barriers to facilitate cross-border Co2 transport and storage and create a supportive regulatory framework. 
      • De-risk CCS investments by implementing Contracts for Difference (CCfD) and leverage EU funding to complement national funds. 
      • Outline plans for negative emissions capacity which are efficient, such as through deploying Bioenergy with Carbon Capture and Storage (BECCS) in full consideration of the limits and availability of sustainable feed stocks. 

      6. Addressing Methane Emissions 

      The importance of methane 

      Methane is a potent greenhouse gas, with over 80 times the warming potential of carbon dioxide over a 20-year period and reducing its leaks can be achieved with cost-effective technologies. According to the IEA 2024 Methane Tracker, Poland emitted an estimated 58 kt of methane in the oil and gas sector in 2023. Addressing these leaked emissions is not only a climate necessity but an economic opportunity for the country. However, methane emissions from the oil and gas sector are only part of the challenge. Coal mine methane accounted for a almost 42% of Poland’s methane emissions in 2023, equivalent to 698 kt, according to the same IEA report.  This figure highlights the significant importance of the coal sector to Poland’s energy mix, even as the country begins its transition to a cleaner energy mix.  

      As a signatory to the Global Methane Pledge, which aims to cut global methane emissions by 30% by 2030, Poland has taken a commendable step towards taking methane emissions seriously, and it is essential that its final NECP reflects this ambition with specific actions. 

      Issue with methane in the Polish NECP

      Despite being a critical issue, methane mitigation remains largely overlooked in the draft plan and the measures covered (i.e. Action 139) are limited in scope and insufficient. The draft NECP provides neither specific nor measurable objectives to reduce methane emissions, the largest source of non-CO2 emissions. By only relying on overall greenhouse gas emissions targets – and failing to include methane specific targets – the near-term impact of this potent dangerous greenhouse gas risks being overlooked.  

      On 4 August 2024, the landmark and first-ever EU Methane Regulation entered into force, and with it, new benchmarks and rules to reduce methane emissions in the energy sector were introduced. The Polish NECP does not include any plans to implement this regulation across the domestic energy sector or allocate the necessary capacity for the designated national competent authorities to enforce it. 

      What should be improved: 

      • Set clear milestones for reducing methane emissions in the energy sector by ensuring a consistent application of the EU Methane Regulation. According to the IEA 2024 Methane Tracker, Poland emitted an estimated 58 kt of methane in the oil and gas sector in 2023. With the recent adoption of the EU Methane Regulation, the NECP should delineate priority actions and planning concerning its implementation in Poland. This should extend beyond the limited scope of Action 139, which only considers emissions resulting from the loss of petroleum products in the storage, filling and emptying processes. For example, in target 3.3.2, which seeks to maintain the national level of natural gas production, there is no mention of efforts to reduce the methane emissions intensity of this gas or guarantee that production meets the new standards set forth the EU Methane Regulation.  
      • Maintain an optimal condition of the natural gas infrastructure and include plans to reduce, detect and repair methane leaks across the entire value chain. The Polish draft NECP refers to ensuring the proper state of natural gas infrastructure (target 4.2.). However, it does not look into downstream methane emissions and thus this maintenance should be expanded across the value chain. The final NECP should include plans to reduce, detect and repair methane leaks across Poland’s entire natural gas transmission system, which is one of the quickest and cost-effective strategies for reducing methane emissions, and outline plans consistent with the EU Methane Regulation. Among others, the plan should include improved measurement, reporting and verification measures of energy sector methane emissions and delineate clear, actionable steps to ban routine emissions from venting, flaring and fugitive emissions across both, upstream production and midstream assets.  
      • Tackle just transition challenges arising from coal mining and subsequent methane emissions. In regard to mining, the draft NECP recognises that emissions reductions in mining will pose additional challenges, but it fails to offer concrete solutions or timelines to address these critical just transition issues. 
      • Develop a Methane Action Plan within the framework of the Global Methane Pledge. In the final NECP, Poland should outline existing policies and future activities and targeted measures planned to reduce methane across various sectors by 2030 and afterwards. This Methane Action Plan, within the NECP, will be crucial to allow for increased accountability and tracking to measure whether Poland is meeting its domestic and international commitments effectively by 2030. Such roadmap should include relevant opportunities, targets, and feasible actions within each priority sector – including energy, waste, and agriculture – and include detailed timelines and benchmarks for execution.  

      Encouragingly, public support for such measures in Poland is high, according to a survey conducted by CATF in 2022, which adds a favourable context for bold action.  

      Recommendations:  

      • Set clear milestones for reducing methane emissions in the energy sector by ensuring a consistent application of the Methane Regulation.  
      • Maintain an optimal condition of the natural gas infrastructure and include plans to reduce, detect and repair methane leaks across the entire value chain. 
      • Tackle just transition challenges arising from coal mining and subsequent methane emissions. 
      • Develop a Methane Action Plan within the framework of the Global Methane Pledge. 

      7. Challenges and Opportunities in Financing and R&D&I

      The importance of financing and supporting R&D&I

      The credibility and effectiveness of Poland’s final NECP will depend largely on its strategy to finance and mobilise public-private resources for scaling, developing, and deploying the clean energy technologies—and supporting policies—required to meet 2030, 2040 and 2050 targets. Similarly, its ability to decarbonise on time will largely depend on the availability of sufficient funding – at EU and national level- and its efficient use. This relates both to the amount available and how it is used, leveraged and coordinated.  

      To ensure the availability of capital, investors need certainty and clear investment signals that foster long-term confidence. A robust NECP that identifies both public and private investment gaps, as well as opportunities to attract the necessary funding for net-zero ambitions, can serve as a vital tool for strategic investment planning. Beyond this, R&D&I funding is also critical especially for promising emerging technologies with low technology readiness level like superhot rock geothermal or fusion energy7 supportive of a net-zero energy landscape. For these cases, focused funding is a first critical step toward broader pilot projects, feasibility studies, and full-scale deployment in time to support 2050 goals. 

      Issues with financing and R&D&I in the polish NECP

      Annex 5 of the NECP draft outlines the financing of actions proposed in the strategy. However, it lacks a detailed financial plan and clear milestones on how to finance the transition. Without precise financial planning, the deployment of key technologies such as SMRs could be delayed, hindering Poland’s decarbonisation objectives. 

      Dimension 5 of the draft NECP highlights the crucial role of research and development in achieving climate neutrality. While this is a positive acknowledgment, the approach to research and innovation remains limited. The draft updated NECP plans to increase R&D investment to 2.5% of GDP by 2030, up from 1.46% in 2022, as shown in Figure 3. Although this represents progress, it falls significantly short of the 3% annual GDP target set by EU leaders over two decades ago and is insufficient to scale up the needed net-zero technologies. As Mario Draghi points out this persistent gap is a key factor behind the EU’s lag in innovation and competitiveness compared to the United States and China.



      In the updated NECP, the plan refers to different actions (i.e. 135 to 137) to drive transformative R&D progress. While all these actions are well intended, they still lack detail to ensure effective implementation.  

      • Action 135 proposes a gradual increase in financing R&D from state budget, targeting areas aligned with the European Green Deal, such as clean energy technologies, next generation nuclear energy, and hydrogen among others. However, it does not specify timelines, funding levels, or mechanisms to ensure impactful outcomes.  
      • Action 136 aims to implement strategic R&D programs in energy, climate, and environmental protection. However, it lacks clarity on the scope, expected deliverables, or how government agencies will prioritise and coordinate these initiatives.  
      • Action 137 plans to update the State’s Scientific Policy8 to align with evolving national and European climate goals. Yet, it remains vague on how these updates will translate into actionable R&D priorities or measurable progress. 

      What should be improved:  

      • Provide detailed national objectives and targets on funding for clean technologies and consider supporting long-term contracts like CCfD. For concrete technologies, the polish government should start by identifying the public funding support available for example for investment in CO2 capture, transport and storage. While the NECP identifies the Innovation Fund as a support source, relying solely on it is insufficient to cover the total costs of initial projects or the scale of initiatives needed for industrial decarbonisation. These projects require substantial direct government support for initial development costs and essential transport and storage infrastructure due to upfront high CAPEX and OPEX. Current carbon prices under the EU ETS remain too low to make CCS economically viable without additional assistance. Implementing Carbon Contracts for Difference (CCfD) tailored to CCS could accelerate deployment by providing financial stability. CCfDs offer price certainty by covering the gap between market carbon prices and a predetermined strike price, thereby de-risking investments. The European Commission also recognises it as a viable financing mechanism. A recent CATF’s report explains how CCfDs can bridge the gap between the costs of CCS projects and market carbon prices. The approach outlined could provide a framework for incentivising CCS deployment in Poland. 
      • Leverage synergies between national and European funds and programs. The final NECP should closely align with the Polich Science Policy to ensure a unified approach to energy transition and technological progress. Enhancing collaboration among academic institutions, research organizations, and the business sector is essential to establish a shared vision for research, development, and innovation. Facilitating the exchange of knowledge and information about ongoing projects will foster synergies, accelerating the development and deployment of innovative solutions. Establishing a well-funded research center could serve as a central hub to coordinate these efforts, optimize resource allocation, and focus on transformative outcomes. To maximize funding opportunities, the Polish NECP should actively identify and leverage synergies across diverse funding mechanisms, including EU programs, to support projects through all stages of their lifecycle and implementation. 
      • Allocate a greater share of the national R&D budget to clean technologies and articulate funding needs, objectives and targets to drive innovation and support the energy transition. The final NECP should plan to increase R&D investment to 3% of GDP by 2030 and clearly articulate clean energy R&I needs to achieve energy and climate objectives. It should also set and describe national R&I objectives and funding targets that outline concrete, quantitative and qualitative pathways for achieving 2030 and 2050 goals, focusing on key clean energy technologies. All of which with a focus on incorporating just transition considerations.  

      Recommendations:  

      • Provide detailed national objectives and targets on funding for clean technologies and consider supporting long-term contracts like CCfD.  
      • Leverage synergies between national and European funds and programs. 
      • Allocate a greater share of the national R&D budget to clean technologies and articulate funding needs, objectives and targets to drive innovation and support the energy transition.  

      Conclusion  

      The updated NECP, submitted for consultation, represents a significant step forward for Poland’s energy transition but still requires substantial refinement to confront the dilemmas inherent in its transformative journey. A more comprehensive, integrated set of measures will be needed to match the scale of identified challenges, particularly those related to industrial competitiveness, energy security and affordable prices — all while balancing environmental protection and the integration of a diverse portfolio of solutions like CCS technologies, zero carbon fuels and nuclear energy, among others. Addressing the gaps identified in this briefing is crucial to ensuring that the final updated NECP goes beyond intentions and becomes a credible investment roadmap, setting the pace for necessary reforms.   

      Poland’s Presidency of the Council of the EU in January 2025 offers a unique opportunity to lead by example and steer crucial discussions on Europe’s energy future. One thing is certain: the EU will not achieve the net zero transformation without efficient and harmonised planning among its Member States. The Final NECPs for 2030 represent the first reality-check to determine whether the EU will meet its agreed targets. A forward-looking and robust NECP is not just an obligation for Poland to achieve these goals but also a transformative opportunity towards job creation, attract investment, and ensure its industry remains competitive as it transitions to net zero. 


      Fußnoten

      1. Mandated under article 14 of the Governance of the Energy Union and Climate Action. 
      2. Belgium, Croatia, Estonia, Poland and Slovakia. 
      3. Including the Fit for 55 package and initiatives raising from the Green Deal Industrial Plan (e.g. Net-Zero Industry Act, Critical Raw Materials Act, Reform of electricity market design), among others.  
      4. Brodacki, B., & Cydejko, J. (2024). Mały atom: Nadzieje kontra rzeczywistość. Polityka Insight. Retrieved December 15, 2024, from https://www.politykainsight.pl/_resource/multimedium/20362816
      5. European Scientific Advisory Board on Climate Change. (2023). Scientific Advice for the Determination of an EU-Wide 2040 Climate Target and a Greenhouse Gas Budget for 2030–2050. https://data.europa.eu/doi/10.2800/609405
      6. The Polish NECP submitted for consultation uses the terms CCS and CCUS interchangeably, despite the significant differences between them. https://carbongap.org/wp-content/uploads/2022/11/The-difference-between-CCS-CCU-and-CDR-and-why-it-matters.pdf
      7. Fusion is an advanced energy source with the potential to produce abundant, zero-emissions power around the world. Paving the way for fusion commercialisation could allow to integrate this carbon-free, firm source into the energy mix, and potentially revolutionise how the global economy is powered.
      8. Ministry of Science and Higher Education. (2022). Polish National Science Policy adopted by the Council of Ministers. Retrieved from https://www.gov.pl/web/nauka/polityka-naukowa-panstwa-przyjeta-przez-rade-ministrow

      Kredite

      Autoren

      Alejandra Muñoz Castañer, Government Affairs Manager

      Bartlomiej Kupiec, CEE Policy Advisor

      Hauptbeitragsleistende

      Alex Carr, Europe Policy Manager, Hydrogen

      Codie Rossi, Europe Policy Manager, Carbon Capture

      Brandon Locke, Europe Policy Manager, Methane Pollution Prevention

      Malwina Qvist, Director, Nuclear Energy Program