Deadlines in question
Currently, businesses subject to the requirements of the amended act are in limbo, awaiting final legislative decisions. New entities already covered by these obligations, along with the vast number of those about to fall under the new legal regime, could theoretically push for deadline extensions. But what will happen if the schedule is not postponed? Polish businesses can expect to face immense challenges and pressure.
Particular attention should be paid to the date of October 11, 2027. Will companies manage to meet the requirements and prepare the necessary documentation in time? Regardless of whether the effective dates for these obligations are postponed or remain unchanged, preparing an energy consumption reduction plan will be absolutely mandatory. Putting off the work on this document until the last minute carries significant risks that not everyone can afford to take.
Key pillars of the proposed changes
1. Changes regarding EEO obligations and energy management systems (ISO)
The draft amendment clarifies new qualification thresholds. The new approach is based on the average annual energy consumption over the last three years (covering all energy carriers) – if it exceeds 2.78 GWh (i.e., 10 TJ), the organization is required to implement a certified ISO 50001 energy management system or conduct an energy efficiency audit. In the case of an audit (EEO), the bar is set very high – the business will have only 45 days from the completion of the audit to create a comprehensive action plan. This document must include:
- calculations of planned energy savings resulting from the audit,
- a precise indication of measures to implement the recommendations (provided they are technically and economically feasible),
- a detailed schedule for implementing these actions,
- a dedicated indicator to monitor progress in implementing audit recommendations.
Regarding the timeline, the corporate energy efficiency audit must be completed within 12 months of the regulations coming into force. Meanwhile, the deadline for implementing a certified energy management system compliant with ISO 50001 is set for the aforementionedOctober 1, 2027., although this date remains the subject of much uncertainty.
Our ISO 50001 services
ISO 50001 allows you to strategically manage the energy consumption of an enterprise. We help businesses implement effective solutions in this area in accordance with the latest EU regulations.
2. Digitalization and the revolution in White Certificates and audits
The amendment introduces fundamental changes to administrative procedures:
- New digital platform: A dedicated Energy Efficiency Platform will be created to digitize the White Certificate application process and reduce bureaucratic application verification to 10%.
- Auditor as a regulated profession: This is one of the most significant qualitative changes – the burden of audit verification is set to shift from the Energy Regulatory Office (URE) directly to independent, certified auditors. This involves the introduction of official training and a state examination (supervised by a committee appointed by the President of the Office of Technical Inspection), covering both corporate energy audits and energy efficiency audits. Qualifications are formally obtained upon entry into a special register.
- Expanded scope: The list of projects qualifying as energy efficiency improvement measures is also set to be expanded.
3. What about the public sector?
There will be an increased focus on budgetary units and public institutions. They will face an absolute, annual obligation to reduce final energy consumption by 1.9% relative to the 2021 base year.
How should this be approached in practice?
As experts specializing daily in ISO system implementations and comprehensive reduction plan development, we are monitoring these developments closely. Waiting for official announcements and putting off action until the last minute may prove to be a strategy carrying too much risk. The complexity of reduction documentation and formal requirements means that auditing processes and building an energy strategy well in advance is currently the only path to full business security. We invite you to a free consultation to determine the best path forward for your business.
