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

Poland is poised to undergo an economy-wide transformation, shifting from more than 70% reliance on fossil fuels in electricity generation to almost the same percentage of zero-carbon sources by midcentury. Reaching climate neutrality 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).  

As the nation stands at a critical juncture in its transition away from coal, it is essential that the final updated NECP is ambitious, coherent, and informed by both industrial and societal needs, reflecting the complexities of the transition. A well-crafted plan will guide investments in the right direction and outline a pathway for deploying and demonstrating a diverse portfolio of technologies, systems and infrastructure options. 

This element, together with the planning of necessary infrastructure should be approached with precision and should strategically reflect newly enacted legislation¹ that will ultimately support Poland’s leadership in industrial decarbonisation. 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.  

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, and proposes the following recommendations to improve the final updated plan:  

Promote risk management through optionality  

• Support the deployment of a diverse portfolio of low- and zero-carbon technologies, with an options-based approach to hedge against the risks of underperformance by a single technology. Optionality serves as a critical risk management strategy that aligns with the priorities of the Polish Presidency of the EU Council in 2025 by strengthening energy security and resilience across the EU. 

• Further detail how Poland will scale up and support additional climate-protecting technologies such as clean hydrogen and ammonia, carbon capture, removal, and storage, small modular reactors (SMRs), and innovations such as superhot rock geothermal. 

Modelling

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

Clean hydrogen

• Accurately quantify the country’s clean hydrogen needs for priority sectors, determining the domestic production capacity versus import requirements, and developing a coherent, techno-economically sound import strategy alongside well-planned infrastructure investments.  

• Deploy any available clean hydrogen in priority hard-to-abate sectors first (e.g., refining, steel, and chemicals), where electrification or alternative decarbonisation pathways may be limited or not viable, ensuring that clean hydrogen achieves its maximum emissions reduction impact. 

• Avoid blending hydrogen into the natural gas grid for residential and district heating due to minimal emissions reductions potential, infrastructure challenges, and safety concerns.  

• Open hydrogen production support schemes to multiple low-carbon pathways rather than focusing solely on renewables-based hydrogen, ensuring that all suitable, demonstrably low-GHG options contribute to Poland’s clean hydrogen supply.  

Nuclear energy

• 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.  
• 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. 

Carbon capture and storage

• 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 Carbon Contracts for Difference (CCfD) and leverage EU funding to complement national funds. 

• Outline plans for efficient negative emissions capacity, such as deploying Bioenergy with Carbon Capture and Storage (BECCS), while fully considering the limits and availability of sustainable feedstocks. 

Methane emissions reductions

• 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. 

Financing, research, development, and innovation

• 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.  

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. 

Poland’s Presidency of the Council of the EU in January 2025 offers a unique opportunity to lead by example by presenting a robust final plan and steer crucial discussions on Europe’s energy future. One thing is certain: the EU will not achieve the net-zero emissions 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 to stimulate job creation, attract investment, and ensure its industry remains competitive as it pursues net-zero emissions. 

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¹ 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.