UC84 Poland’s Proposed Energy Law Amendment: What It Means for BESS and Renewable Energy Projects

Executive Summary

The UC84 amendment to the Polish Energy Law proposes reforms to the regulatory framework governing grid connections to the electricity network, including connections for renewable energy installations and energy storage facilities such as battery energy storage systems (BESS).

The reform responds to increasing pressure on the Polish electricity network. In recent years, the number of applications for grid connection conditions has grown significantly. Government communications indicate that a substantial portion of grid capacity has been reserved by projects that have not progressed to construction, limiting access to connection capacity for new investments.

UC84 introduces measures intended to address this issue by strengthening financial commitments and development milestones associated with grid connections. These changes aim to discourage speculative applications and reduce so-called “zombie projects” - projects that hold grid capacity but do not advance toward implementation. The amendment also proposes mechanisms intended to improve utilisation of existing grid infrastructure, including flexible and configurable grid connections and the expansion of shared connection arrangements (commonly referred to as cable pooling).

Legislative Status

As of March 2026, the Sejm adopted the amendment to the Energy Law on 27 February 2026. The act was subsequently forwarded to the Senate for consideration. On 3 March 2026, the Senate Legislative Bureau published its opinion on the act, which includes legal analysis and proposed amendments as part of the Senate’s review process.

The act has not yet entered into force and remains subject to the remaining stages of the legislative procedure.

1. Updated Grid Connection Fee Structure in Poland Under UC84

One of the central objectives of UC84 is to discourage speculative grid connection applications and prioritise projects with a higher probability of implementation. Therefore, UC84 introduces a three-layer fee structure applicable at different stages of the connection process.

(a) Statutory/Application Processing Fee

The reform introduces a non-refundable administrative fee for connection applications:

• PLN 1 per kW of requested capacity

• Maximum fee: PLN 100,000

This fee applies when submitting an application for grid connection conditions and covers administrative processing by system operators.

(b) Increased Advance Grid Connection Payment

UC84 also increases the advance payment required when applying for grid connection conditions:

• PLN 60/kW, increased from PLN 30/kW

• Maximum amount of PLN 6 million

The advance payment is credited toward the final connection fee if the project proceeds to implementation.

(c) Performance Security for Grid Connection Agreements

The reform introduces additional financial security obligations linked to the grid connection agreement.

• PLN 30/kW for projects up-to 100MW

• PLN 60/kW for projects above 100MW

• Maximum amount: PLN 12 million

Legal commentary indicates that the return or retention of the security is linked to development progress. For example, withdrawing from a connection agreement after 36 months from its conclusion may result in loss of the security.

2. Shortened Development Timelines and Automatic Termination Risk for Energy Projects in Poland

UC84 introduces stricter project development timelines intended to prevent long-term reservation of grid capacity by projects that are not progressing.

• The validity period of GCC shortened from 24 months to 12 months

• Re-verification of technical conditions before GCA signing, ensuring that network parameters remain valid at the time of contract execution.

• Milestone deadlines for obtaining key administrative permits within defined timeframes. These requirements apply to renewable energy and other installations connecting to the grid, including energy storage projects.

• Failure to meet the required milestone deadlines may lead to the expiry of the grid connection agreement.

The legislation also allows a single extension of the milestone deadline, subject to justification and the provision of additional financial security.

3. Mechanisms to Improve Grid Utilisation

In addition to stricter financial and procedural requirements, UC84 introduces structural changes intended to improve utilisation of existing grid infrastructure.

(a) Expansion of Cable Pooling

UC84 expands the cable pooling formula to enable connection-sharing across installations, including energy storage.

Government information and legislative documentation indicate that the revised framework allows the participation of:

• Renewable energy installations

• Energy storage facilities

This may facilitate the development of hybrid projects combining generation and storage technologies.

b) Flexible and Configurable Grid Connections

The reform introduces new connection models referred to as:

• Flexible connections

• Configurable connections

These connection models allow connection parameters to vary depending on the current conditions of the electricity network, enabling projects to connect even in locations where full firm capacity may not yet be immediately available.

(c) Increased Transparency of Available Grid Capacity

UC84 also strengthens transparency obligations for system operators.

Government information about the reform states that operators will be required to publish updated information on:

• Available grid connection capacity

• Status of connection applications

• Other information relevant to grid connection processes

4. Transitional Provisions for Existing Energy Projects

UC84 also includes transitional provisions affecting projects that are already in development.

These provisions apply both to projects that:

• Have already received grid connection conditions, an

• Have already signed grid connection agreements.

(a) Projects with GCC Issued but No GCA Signed

Projects that have received grid connection conditions but have not yet signed a grid connection agreement may be subject to certain updated requirements under the new framework.

In particular:

• System operators may verify technical conditions before concluding the grid connection agreement

• Some projects may be required to adjust financial payments to comply with the updated rules

Practical implication: Developers with existing connection conditions may therefore need to review the implications of the transitional provisions once the final version of the legislation is adopted.

(b) Projects with GCA Already Signed (Low Advancement Projects)

If the connection date is scheduled several years after UC84 enters into force:

• Existing GCAs remain valid

• Projects must comply with new development milestones introduced by UC84

• Failure to demonstrate the milestone within the deadline may result in the expiry of the grid connection agreement.

Practical implication: Developers with signed GCAs should review milestone readiness (permitting, land, financing and procurement timelines).

5. Practical Implications for BESS Developers and Investors

For standalone and hybrid battery energy storage projects in Poland, UC84 results in:

• Higher upfront capital commitments

• Tighter alignment between permitting strategy and grid milestones

• Reduced tolerance for development delays

• Greater importance of technical readiness before GCA execution

• Enhanced opportunity for hybridisation via cable pooling

For investors and lenders, the reform directly impacts:

• Internal rate of return (IRR) sensitivity to early cash outflows

• Security structuring (guarantees vs. cash deposits)

• Permitting risk modelling

• Portfolio prioritisation strategy

Conclusion: A Structural Recalibration of Poland’s Grid Connection Framework

UC84 represents one of the most significant proposed reforms of Poland’s grid connection framework in recent years. Government communications indicate that the objective of the reform is to increase the availability of grid connection capacity and improve the efficiency of connection procedures.Although the legislation has been adopted by the Sejm, the final shape of the reform will depend on the outcome of the ongoing legislative process in the Senate and the subsequent stages of the legislative procedure.

Developers, investors and lenders active in the Polish energy market should monitor the legislative process closely and assess the potential impact of the new rules on project development strategies.

Interested to learn more? Contact us.

Michał Ogiński
Chief Development Officer
michal@storaenergy.pl

+48 507 418 331

Shannon O’Connell
CEO & Co-Founder
shannon@storaenergy.pl

Date of Publication: 6 March, 2026

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