In our comments, we repeatedly emphasized that we are at a critical juncture in the transformation of the heating sector, which is largely driven by political decisions made at the European level. It should be emphasized, however, that at the national level, we have the ability to achieve these goals according to our own scenario, taking into account primarily costs and the security of heat supply. Therefore, the sector can gradually implement a transition away from coal, using gas as a bridge, developing the use of biomass and biogas, and investing in heat pumps and waste heat. We urged that this previously chosen transformation direction take into account both the country's energy security and the financial dimension, ensuring that consumers are able to bear the cost of this transformation.
The current National Energy Policy and the National Energy and Climate Plan have defined the directions of the transformation, unfortunately only partially taking into account industry-specific demands and our own proposals to maintain the role of cogeneration and limit the pace of electrification. Critics even claim that the position of heating within the government administration has changed, but the policy itself, unfortunately, has not. The cost of the energy transformation is, of course, a very important, complex, and multifaceted topic. Heating companies require funds for both current needs (renovations, modernizations) and investments. Many estimates demonstrate the magnitude of these challenges. For example, it's worth citing the PTEC (formerly PTEZ) report, which estimates the cost of transformation to meet the requirements of the Fit for 55 Package at PLN 466 billion by 2050. The transformation challenges are enormous, not only technologically but also financially.
It is obvious that, given the scale of the investment, it is impossible to finance it solely through tariffs. Heating tariffs are already high, as evidenced by successive government aid laws, under which heat consumers have received compensation and offsets in the past, and currently support in the form of a so-called heating voucher. Unfortunately, the current solution is ad hoc and limited to the end of 2026. The support mechanism for heat consumers has also been significantly limited in both financial and personal terms. This means that only a narrow group of consumers (the income criterion is PLN 3,272 net per month for a single-person household and PLN 2,454 per person in a multi-person household) will be eligible for support. Furthermore, the single-component price of heat supply, the starting point for support, has been set quite high – PLN 170 per GJ, further narrowing the potential group of heat consumers benefiting from support. It's impossible not to mention the important element of consumer economic vulnerability here. This is the economic threshold above which consumers will not connect to the heating network, and those already connected can make decisions about alternative solutions. Simply put, raising tariffs for end users has its limits.
According to a report by the Energy Regulatory Office (URE), the total revenues of licensed energy companies in 2024 amounted to PLN 41 billion, of which PLN 30 billion came from heat generation, transmission, and distribution. At the same time, the total capital expenditures of these companies reached only
PLN 4.7 billion. As a reminder, PTEC estimates the implementation of the Fit for 55 Package at PLN 466 billion by 2050. Simply put, implementing the transition based on tariff funds would extend the transition to 100 years!
Without external financial support, many companies will undoubtedly be unable to sustain these expenditures, especially given their current financial situation. We know the scale of the needs. Therefore, large-scale public assistance measures are necessary. The announced support mechanisms should be implemented immediately: for example, subsidies, along with an appropriate change in tariff regulations enabling the inclusion of this cost in the heating tariff. Financing cannot be incidental, as this is not the nature of the transformation. Therefore, it must be predictable, spread over many years, and financially sufficient.
The aforementioned PEP and NECP defined the transformation directions only partially taking into account the industry's demands, and yet the investment plans of companies corresponding to these documents lack appropriate support programs. For example, there is no dedicated program for heat storage facilities as separate installations. Furthermore, funding already granted or currently under review may require repayment in several years with interest due to the so-called risk of non-compliance with the taxonomy requirements. The National Fund for Environmental Protection
and Water Management (NFOŚiGW) demands from companies a clear and binding declaration of transitioning supported sources to exclusively renewable fuels after 2035. This requirement is unrealistic to meet, and without a change in the approach of the National Fund for Environmental Protection and Water Management (NFOŚiGW) or a change in regulations in this area, it creates significant financial risks for the industry. We appeal to the Ministry of Development and Technology, which oversees the taxonomy implementation process in Poland, to develop an appropriate and flexible approach, tailored to the specific Polish circumstances. This is especially difficult to make a clear commitment at this time, and the need to repay public aid would undoubtedly be a disaster for the Polish heating sector! We encourage the government to improve dialogue, exercise common sense, and listen to the industry's arguments. The strategy for the heating sector, including securing funding for the transformation, still requires significant changes. And this is truly the final moment.
