Amendments to the Energy Act – what does the UC84 bill propose?
The draft amendment, known as UC84, is a package of changes that implements EU energy directives and addresses the challenges arising from the growing number of micro-installations, the need to develop the grid, and the need to ensure safety for end users. In addition, the proposed provisions allow consumers to choose between a dynamic pricing contract and a fixed-price guarantee contract, and provide for greater transparency when concluding electricity supply contracts.
At present, the draft bill is at the stage of being reviewed by state authorities and institutions.
Strengthening consumer rights
One of the main objectives of the UC84 draft is to strengthen the position of electricity consumers. Suppliers will be required to offer fixed-term contracts with a fixed price guarantee. This is particularly significant in the context of energy price volatility on wholesale markets – by signing such a contract, consumers can expect greater predictability in their bills and a reduction in the risk of sudden price rises during the contract period.
New connection rules – flexibility for renewables
The amendment provides for the introduction of so-called flexible, non-guaranteed connection contracts. Until now, limited grid capacity has hindered the development of renewable energy – now investors will be able to obtain a connection more quickly. The new regulations are intended to remove one of the main barriers faced by companies planning to invest in renewable energy installations. The full digitisation of the process for submitting connection applications and the publication by operators of more information on available connection capacity are also key. The new disclosure obligation is also set to cover submitted applications for the determination of grid connection conditions (for voltages above 1 kV), refusals to determine connection conditions, and the criteria used to calculate grid capacity. This will ensure that investors and businesses receive reliable, publicly available information on the potential for developing new energy sources in a given region.
CSIRE – the new reality of the energy market
On 1 July 2025, the Central Energy Market Information System (CSIRE), managed by Polskie Sieci Elektroenergetyczne, was officially launched. This system is intended to enable a faster switch of energy suppliers (even within 24 hours), online access to metering data, and a transition to a new reserve sales model. It is also envisaged that regulations concerning virtual prosumers will be adapted.
The regulations provide for the phased implementation of tasks via the CSIRE by different categories of entities, depending on the size of the entity. Entities with no more than 100,000 PPE connected to their network will be able to choose the implementation date.
Four time windows are to be introduced: 1 July 2025; 1 March 2026; 1 July 2026; and 19 October 2026 – the final deadline for all entities to carry out tasks via CSIRE, regardless of the number of PPEs they hold.
Frozen energy prices – what next?
One of the most interesting issues, particularly for individual consumers, is the future of the so-called ‘energy price freeze’. From 1 January to 30 June 2025, a cap on the maximum energy price for households was in force – PLN 500 per MWh. Under the amendment to the regulations, the freeze has been extended to the third quarter, and information from public opinion suggests that the legislator may maintain this mechanism until the end of 2025.
Importantly, the capacity charge has also returned from 1 July 2025. In practice, this means that despite the energy price cap remaining in place, bills may be higher than in the first half of the year.
From 2026, there are plans to move away from the universal price freeze mechanism in favour of more targeted support measures. The government has announced the introduction of, amongst other things, energy vouchers and income support for the most vulnerable electricity consumers.
Other important developments include the proposed regulations on the deregulation of RES licences.
According to the published draft of the UDER29 Act, the regulations provide for an increase in the installed capacity threshold above which a licence for electricity generation will be required. From 2026, the proposed regulations provide for an obligation to hold a licence for electricity generation for installations with a capacity exceeding 5 MW (to date, the threshold has been 1 MW). This significant change will allow for a substantial reduction in the scope of regulatory obligations for many energy producers. It will also facilitate investment in larger renewable energy installations, the primary purpose of which will be to meet the owner’s own demand, whilst simultaneously creating the possibility of feeding surplus energy into the grid. Until now, due to the requirement to obtain a WEE licence and the need to fulfil numerous associated obligations, many businesses have been deterred from building larger generation sources by the licensing requirement. Furthermore, raising this threshold may, in practice, ease the burden on the Energy Regulatory Office by reducing the number of licensing proceedings.
Summary
Changes to energy law and modern digital solutions, such as CSIRE, are the response to the challenges of the energy transition in Poland. In the coming months and years, consumers, businesses and investors will have to adapt to the new realities.
We recommend that both businesses and consumers keep a close eye on the legislative process and assess what new opportunities and obligations the subsequent stages of implementing these changes will bring. If in doubt, we encourage you to consult our firm – our lawyers continuously analyse the latest regulations and assist in implementing changes in business practice.
She specializes in civil, commercial and business law. In the corporate and energy department, her activities are mainly based on providing corporate services to companies, reviewing and preparing commercial contracts, drafting litigation and non-litigation pleadings and preparing analyses and legal opinions, particularly in the sphere of business law and energy law. She also has professional experience in administrative and civil proceedings, which she gained in Warsaw law firms. She supports the Firm's…
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