Poland’s Ministry of Energy has drafted amendments to the Energy Law designed to strengthen the security of the National Power System and protect the market in the event of disruptions affecting the Central Energy Market Information System (CSIRE). The bill introduces strict deadlines for reporting and resolving IT system outages, new obligations for electricity generators and energy storage facilities, and fines of up to PLN 500,000. In cases of serious violations, grid operators could even temporarily disconnect an installation from the network without compensation.
The draft amendment to the Energy Law, prepared by the Ministry of Energy, is currently undergoing public consultation. The consultation process began on August 6, with comments accepted until August 13, 2026. The bill is listed in the Government Legislative Process under reference number UD446.
The proposed changes cover several areas of the electricity market at the same time. They concern the Central Energy Market Information System, data exchange between market participants and grid operators, energy storage facilities, electricity generators, smart meters and settlements related to paid electricity supply restriction schemes.
One of the main reasons for the reform is the growing importance of distributed energy resources. As more electricity comes from generation facilities connected to distribution networks and from energy storage systems, accurate and up-to-date information about their operation becomes increasingly important to the stability of the entire power system.
Nearly 2,000 installations failed to provide required data
The explanatory memorandum to the bill reveals the scale of a problem that is not immediately apparent from the Ministry of Energy’s general announcement.
According to data cited by the ministry, as of the end of May 2026, the required scheduling data was not being submitted for almost 20% of electricity generation modules, representing around 2,000 installations. In some other cases, the information submitted contained incorrect values.
There were situations in which an installation was scheduled to generate electricity but was not actually producing power, as well as cases in which production took place despite the submitted schedule indicating otherwise.
According to the authors of the legislation, incomplete or incorrect information reduces the accuracy of planning and balancing within the Polish National Power System. The explanatory memorandum explicitly warns that if these risks materialise, they could contribute to failures affecting not only Poland but potentially other parts of Europe.
This is one of the main reasons behind plans to tighten the rules governing data exchange between generators, energy storage operators and grid operators.
New obligations for generators and energy storage facilities
The draft specifies which entities will be required to provide information to electricity system operators and what type of data they must submit.
The obligation to cooperate with the relevant operator will apply, among others, to energy companies operating generating facilities classified as type B, C or D power-generating modules, as well as to owners of such facilities who are not themselves licensed energy companies.
The rules will also apply to businesses operating energy storage facilities with a total installed capacity of more than 50 kW, as well as to owners of such storage facilities who are not energy companies. Certain exemptions are planned for storage units forming part of prosumer micro-installations.
These entities will be required to provide structural data and real-time information, submit and comply with generation schedules, and follow instructions issued by the relevant system operator.
The proposal also covers smaller energy resources managed on an aggregated basis. Scheduling obligations are expected to apply, among others, to aggregators or certain electricity suppliers managing type A generating units, as well as aggregators managing storage facilities of up to 50 kW and storage systems operating within prosumer installations.
Where such companies have access to real-time operating data for the resources they manage, they will be required to provide that information to the grid operator on an ongoing basis.
Fines for missing data could reach PLN 500,000
The proposal does more than introduce new obligations. It also establishes mechanisms to enforce them.
Failure to comply with certain requirements relating to structural data, scheduling information and real-time data could result in fines ranging from PLN 1,000 to PLN 500,000. The penalty would be imposed collectively for violations occurring during a given calendar quarter.
A separate sanctions regime is proposed for obligations relating to the operation of CSIRE, including reporting system outages, resolving them within the required deadlines, supplementing and correcting information, adjusting settlements and preparing business continuity and contingency plans.
According to the explanatory memorandum, penalties for these violations are expected to range from PLN 10,000 to PLN 500,000.
At the same time, companies would be protected from liability where a violation resulted exclusively from a failure or outage of a system outside their actual control.
Grid operators could disconnect installations for up to 24 hours
A temporary restriction on the operation of an installation could prove considerably more severe than a financial penalty.
In the event of a serious breach of requirements concerning the submission or implementation of schedules, the provision of real-time data or compliance with grid operator instructions, the electricity system operator would be permitted to restrict or suspend transmission or distribution services.
This could involve limiting electricity fed into the grid, restricting electricity consumption or physically disconnecting a generating module or energy storage facility. Such measures could remain in force for up to 24 hours.
Importantly, the owner of the installation would not be entitled to compensation or damages as a result of such action.
Grid operators would not, however, have complete discretion. The criteria used to determine whether an infringement is sufficiently serious would have to be set out in grid operation and maintenance instructions, amendments to which require approval from the President of Poland’s Energy Regulatory Office, URE.
CSIRE to receive formal contingency procedures
The second major pillar of the amendment concerns the Central Energy Market Information System.
CSIRE is intended to serve as the central source of information used, among other things, for electricity market settlements. Existing legislation allows market participants to operate without the system in the event of a CSIRE outage. However, according to the Ministry of Energy, the current rules do not adequately address situations where CSIRE itself remains available but one of the IT systems connected to it becomes unavailable.
The amendment therefore expands the circumstances in which data stored outside CSIRE may be used.
Alternative data would only be used to the extent and for the period during which the outage genuinely prevents the use of information from CSIRE. Once normal operation is restored, missing or incorrect information would have to be supplemented or corrected. Any discrepancies would also have to be reflected in corrected settlements.
One hour to report an IT problem
The proposed rules set out detailed deadlines for responding to IT incidents.
An entity operating a system connected to CSIRE, as well as the transmission system operator, would be required to notify the Energy Market Information Operator, or OIRE, of an outage within one hour of becoming aware of it.
Information about the scope of the outage and the expected time required to resolve it would have to be provided within the deadline specified in the relevant contingency plan, but no later than three hours after the problem is identified.
Once normal operation is restored, confirmation that the outage has been resolved would have to be sent to OIRE within a maximum of two hours.
Different deadlines would apply to failures affecting CSIRE itself. The Energy Market Information Operator would have to notify market participants of the outage, its scope and the expected restoration time within two hours, while information confirming that normal operation had been restored would have to be provided within one hour.
Information about such incidents would also have to be published on the websites of the relevant entities.
Outages generally must be resolved within 24 hours
The draft legislation also introduces an overall deadline for resolving system failures.
An outage affecting CSIRE or an IT system connected to it would have to be resolved within the period specified in the relevant contingency plan, but generally no later than 24 hours after it is identified.
Exceeding this deadline would only be permitted where compliance was impossible for reasons beyond the control of the entity responsible for the system.
In practice, the digitalisation of Poland’s energy market will therefore be accompanied by formal requirements covering IT system continuity, contingency procedures and the speed with which companies respond to incidents.
Companies will need business continuity plans
The Energy Market Information Operator, the transmission system operator and market participants operating systems connected to CSIRE would all be required to prepare and implement contingency and business continuity plans.
These plans would cover not only failures of IT systems but also problems affecting the telecommunications infrastructure required to communicate with CSIRE.
The documentation would have to specify, among other things, which processes are covered by emergency procedures, how the impact of disruptions is to be limited, how business continuity is to be restored, the deadlines for reporting problems, procedures for correcting data and the rules governing communication between market participants.
In practice, preparing for CSIRE will therefore involve much more than integrating a company’s IT systems with the central platform. Market participants will also need to be prepared for periods when the system is unavailable.
October 19 remains the key CSIRE deadline
CSIRE was launched on July 1, 2025, when the first optional integration window opened. Further voluntary onboarding dates were scheduled for March 1 and July 1, 2026.
October 19, 2026 is intended to be the final deadline for all market participants subject to the mandatory CSIRE integration requirement.
The draft legislation nevertheless introduces a contingency mechanism for distribution system operators that fail to begin carrying out the required CSIRE-related tasks by that date.
Here, the bill is more precise than the Ministry of Energy’s general announcement.
The President of URE would be able to refrain from imposing certain penalties on a distribution system operator only if two conditions are met simultaneously: the operator must have concluded the required agreement with OIRE before the relevant deadline and must begin performing its CSIRE-related tasks on April 19, 2027.
The proposal also protects other market participants from penalties where their failure to meet regulatory obligations is caused solely by delays on the part of the relevant distribution system operator.
Settlements could continue outside CSIRE
The legislation also provides for a scenario in which, after October 19, 2026, a particular distribution system operator is still unable to perform its required tasks within CSIRE.
In such a case, system users, including electricity suppliers and operators, would be allowed to conduct settlements using information that has not been registered in CSIRE.
This mechanism would apply from October 19, 2026 until the relevant distribution system operator begins performing its required CSIRE tasks.
The purpose is to prevent integration problems at one operator from disrupting settlements across the wider electricity market.
February 1, 2027 will matter for some of the new obligations
The draft also includes an additional transition date relevant primarily to aggregators and entities managing smaller generating units and storage facilities.
Requirements concerning the submission and implementation of scheduling data for certain type A resources and smaller storage facilities, together with related obligations to provide available real-time data, would apply from February 1, 2027.
The transmission system operator would have three months from the legislation’s entry into force to prepare and submit amendments to its transmission grid operation and maintenance instructions to the President of URE.
Distribution system operators would then have three months from the publication of the approved changes to the transmission system instructions to prepare corresponding amendments to their own documentation.
Smart meters: an exemption from the installation requirement
The amendment would also relax one of the obligations imposed on distribution system operators.
Current regulations require smart meters to be installed at all electricity substations transforming medium voltage into low voltage where those substations form part of an operator’s network. Until now, the legislation has not provided for exemptions based on cost or technical constraints.
Under the proposed changes, a distribution system operator could refrain from installing a meter at a particular substation if installation is impossible for technical or legal reasons, or is economically unjustified.
This would not amount to a general exemption. The operator would be required to document the circumstances justifying its decision, and the President of URE would be able to verify whether the exemption had been properly applied.
Simpler settlements for paid electricity supply restrictions
The amendment also changes the settlement mechanism for so-called paid electricity supply restriction levels.
This mechanism applies when the transmission system operator imposes restrictions on electricity consumption because of a threat to security of supply. It generally applies to large consumers with contracted capacity exceeding 300 kW, subject to exemptions specified in law.
Following the amendment, the distribution system operator would act towards the customer in its own name but on behalf of the transmission system operator.
As a result, the customer would settle the service directly with the distribution operator, while the transmission and distribution operators would carry out aggregate settlements between themselves.
According to the authors of the bill, the change should reduce paperwork, accelerate payments and avoid situations in which a distribution operator effectively has to finance customer compensation before receiving the corresponding funds from the transmission system operator.
Greater responsibility for data and IT systems
The draft legislation illustrates how quickly the nature of responsibilities in the energy market is changing. Power system security increasingly depends not only on power stations, networks and available generation capacity, but also on the quality of information and the reliability of IT and telecommunications systems.
Only a few years ago, distribution networks were viewed by the transmission system primarily as points of electricity consumption. Today, they host thousands of distributed generation installations, and periods of surplus production increasingly cause electricity to flow in the opposite direction — from distribution networks into the transmission grid.
As a result, information about the actual and planned operation of electricity generators and storage facilities is becoming directly relevant to the security of Poland’s National Power System.
If the legislation is adopted in its proposed form, some energy companies will have to do more than adapt their IT systems. They will also need to introduce contingency procedures, ensure adequate data quality and prepare their organisations to comply with extremely short incident-reporting deadlines.
The bill also provides for a rapid entry into force. Most provisions would apply on the day after the legislation is officially published, while certain requirements concerning data transmission would be subject to a 14-day vacatio legis. Specific obligations relating to smaller energy resources would apply from February 1, 2027.
For now, however, these remain proposed measures. Public consultation will continue until August 13, and the final shape of the legislation may still change during the subsequent legislative process.
