On August 19, 2025, Poland’s Council of Ministers proposed an amendment to the Energy Law, set to reinstate the exchange obligation for electricity trading and extend it to the natural gas market. The amendment, documented as UD284, aims to improve market transparency and liquidity while minimizing price speculation.
The Energy Ministry plans to require that 55% of electricity generated in Poland is sold through the Polish Power Exchange (Towarowa Giełda Energii, TGE) and nominated electricity market operators (NEMOs). This reinstatement comes after the exchange obligation was fully repealed in 2022, which led to a decline in market transparency and an increase in speculative trading activity. The Ministry aims to use this requirement to facilitate better price assessments by the Energy Regulatory Office (ERO) and enhance trading conditions.
The amendment also proposes raising the gas market’s exchange obligation from 55% to 85%. This change seeks to increase the number of offers available on the TGE, improve supply levels, and subsequently reduce wholesale prices for consumers. By implementing these new rules, the government hopes to foster competitiveness within the energy market and support smaller market participants.
The proposed amendment outlines specific exemptions from the exchange obligation for certain electricity sales scenarios. Notably, electricity delivered directly to end users, renewable energy generated from smaller units (under 10 MW), and cogeneration units with high efficiency may be exempt. This consideration is aimed at balancing the needs of various stakeholders while promoting market growth.
Historically, the exchange obligation for electricity existed in Poland from 2010 and was fully implemented by 2018. However, deregulation efforts led to its repeal in 2022, as more than half of electricity transactions were occurring outside the exchange. The absence of this obligation resulted in challenges for consumers in securing energy agreements, a decline in market competition, and increased vulnerability to price manipulation. In the gas sector, the low exchange obligation hindered competitiveness and made it difficult to establish reference prices, negatively impacting industrial consumers.
With the proposed changes, the Energy Ministry anticipates positive impacts on market dynamics. The reinstatement of the exchange obligation for electricity is expected to improve the transparency of quarterly price calculations by the ERO and increase trading liquidity. Similarly, the higher exchange obligation for natural gas is projected to attract more offers on the TGE, ultimately leading to lower prices and enhanced market competitiveness.
The Council of Ministers plans to finalize and adopt the amendment in the third quarter of 2025, marking a significant shift in Poland’s approach to energy market regulation and transparency.
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