White Certificates in Poland – how the energy efficiency certificate system works and when it can be used

White certificates, formally energy efficiency certificates under Polish law, are a mechanism that links a planned modernisation project with additional value arising from the energy savings achieved. They are not an ordinary grant or a guaranteed percentage return on investment. The President of Poland’s Energy Regulatory Office (URE) issues a certificate with a value expressed in toe, and once the procedure has been completed correctly, transferable property rights arise from that certificate.

For a business, the sequence of actions is the most important point. An application for an energy efficiency certificate should be submitted before the “start of works” within the meaning of the Polish Energy Efficiency Act. The start may be not only the contractor beginning construction work, but also the first legally binding commitment to order equipment or another commitment that makes the project irreversible.

The most important practical rule: before a binding equipment order or a contract committing the company to carry out the modernisation is signed, it is worth checking the project’s eligibility, estimating the energy savings, preparing an energy efficiency audit and submitting the application to URE.

The white certificate system in Poland at a glance

From a company’s perspective, the entire mechanism can be reduced to seven stages:

1. Initial project eligibility assessment – checking the type of project, the savings threshold, the start-of-works date and any public aid.
2. Pre-investment energy efficiency audit – defining the baseline, the modernisation option and the planned energy savings.
3. Application to the President of the Polish Energy Regulatory Office (URE) – submitted before the statutory start of works.
4. Implementation of the project – while maintaining the scope and parameters on which the audit and application were based.
5. Completion and settlement of the project – notification to URE, documents confirming commencement and completion, and, where required, an audit confirming the achieved effect.
6. Transfer of information to the register – once the statutory conditions are met, URE sends the information to the entity operating the certificate register.
7. Creation and sale of property rights – the rights arising from the certificate are created when the certificate is first entered in the register and may be traded.

This distinction between the issue of the certificate and the creation of property rights is important. The document issued by URE alone does not yet mean that the company has received proceeds from the sale of the rights.

What are white certificates in Poland?

The formal name of a white certificate under Polish law is an energy efficiency certificate. Under the Act, the certificate confirms the amount of final energy planned to be saved as a result of a project, or projects of the same type, aimed at improving energy efficiency.

The value of the certificate is expressed in tonnes of oil equivalent (toe). It is not derived directly from the investment cost, the price of the equipment or the amount of the energy bills. The basis is the energy effect determined in the audit.

A white certificate should also not be confused with an Energy Performance Certificate for a building. These are two different documents, issued for different purposes and under different regulations.

Certificate and property rights – they are not the same thing

The energy efficiency certificate is issued by the President of URE. The property rights arising from the certificate are created only when the certificate is first entered in an account in the register, on the basis of information provided after completion of the project. These rights are transferable and may be traded.

The economic mechanism therefore works as follows:

energy savings → certificate value in toe → entry in the register → property rights → sale of the rights.

Which projects can qualify for an energy efficiency certificate in Poland?

The Polish Energy Efficiency Act lists broad groups of projects aimed at improving energy efficiency. A detailed list is set out in the notice of the Minister of Climate and Environment of 30 November 2021.

This does not mean that every equipment replacement automatically qualifies for the Polish system. A measurable energy saving must be demonstrated and the other statutory conditions must be met. For energy processes carried out in fuel-combustion installations covered by the emissions trading system, an additional statutory restriction applies, except for equipment serving the installation’s own needs. Such a project therefore requires a separate eligibility assessment.

How can you check before the investment whether a project may qualify for the system?

It is worth carrying out an initial assessment before commissioning the full audit. Seven questions are particularly important:

If the project does not reach 10 toe at this stage, it may still be worthwhile from an energy perspective. It simply does not meet the minimum threshold of the Polish white certificate system for the option being analysed.

The 10 toe threshold – how much energy must be saved?

The statutory definition of one tonne of oil equivalent corresponds to a calorific value of 41.868 GJ. Since 1 MWh equals 3.6 GJ:

• 1 toe = 41.868 GJ = approximately 11.63 MWh,
• 10 toe = approximately 116.3 MWh,
• 100 toe = approximately 1 163 MWh.

The 10 toe threshold concerns energy savings averaged over one year, not the value of the investment. The Polish Act allows the threshold to be assessed for one project or for projects of the same type.

If a project demonstrates savings in primary energy, the certificate value should not be determined simply by dividing that energy by 11.63 MWh/toe. In such a case, Article 21 of the Polish Act requires the conversion efficiencies for transforming primary energy into final energy, as specified in the implementing regulations, to be taken into account. This conversion should be performed in the audit.

Example: a modernisation saves 200 MWh per year

If the correctly determined final energy saving is 200 MWh per year:

200 MWh / 11.63 MWh/toe ≈ 17.20 toe.

The project therefore exceeds the minimum threshold of 10 toe. This result does not yet indicate how much the company will earn from the property rights. Their financial value depends on the number of rights registered, the sale price and transaction service costs.

Why is the sequence “first analysis and application, then implementation” so important?

The Polish Act defines the “start of works” very specifically. It may be:

• the start of construction works related to the project,
• the first legally binding commitment to order equipment,
• another commitment that makes the project irreversible,

whichever of these events occurs first.

The definition excludes, among other things, the purchase of land, obtaining permits, carrying out preliminary feasibility studies and certain preparatory works within the meaning of the Polish Construction Law.

Do you have to wait for the certificate to be issued after submitting the application?

Within the Polish white certificate system itself, the critical point is the application date in relation to the start of works. Article 24 provides for refusal to transfer information to the register if the works began before the date on which the application was submitted. The Act does not establish a general rule requiring the investor to wait until the certificate is issued before implementation begins.

In practice, before launching the investment, the conditions of other sources of financing or public aid must still be checked separately. A grant agreement, aid programme or external financing may have its own rules concerning the start of the project.

What technical data are needed for an initial estimate of the savings?

There is no single list of data suitable for every modernisation. A sound eligibility assessment should reconstruct the pre-investment state and reliably describe the post-investment state.

Energy bills alone are often not enough. In many projects, changes in production, operating hours, outdoor temperature, system load or process parameters must be taken into account. Without normalisation, it is easy to mistake a genuine improvement in efficiency for a change in operating conditions.

What is the role of an energy efficiency audit?

An energy efficiency audit is the principal technical document attached to an application for an energy efficiency certificate in Poland, except in specific cases provided for by the Act. The Polish Act defines it as a study covering energy consumption analysis, an assessment of technical condition, possible measures, their economic viability and the achievable energy savings.

For white certificates, the pre-investment audit should primarily:

• define the boundaries of the project being analysed,
• document the baseline,
• describe the modernisation option,
• identify the data, measurements and assumptions used in the calculations,
• calculate the energy savings using the appropriate method,
• convert the result into toe,
• enable a later comparison between the scope actually implemented and the scope assumed in the application.

The detailed scope and methods for preparing the audit are laid down in Polish implementing regulations. URE currently lists the consolidated text of the 2023 regulation and the amendment of 24 November 2025 as the current legal acts governing this audit.

Who may prepare an audit for white certificates in Poland?

The Polish Act specifies requirements for the person preparing an energy efficiency audit. This may be a person with at least two years of professional experience in servicing, operating or installing the relevant equipment, installations or facilities, or a person who has completed higher education leading to a master’s degree, Master of Engineering degree or an equivalent qualification, or appropriate postgraduate studies. Under the education route, the curriculum must cover the subjects listed in Article 25(5) of the Act, including energy engineering, electrical engineering, energy efficiency, building energy audits, energy-efficient construction or renewable energy sources.

For the same project, the audit attached to the application and the audit confirming the achieved effect after implementation may not be prepared by the same person.

Energy savings versus cost savings – why are they not the same?

Under the Polish system, what matters is energy savings, not merely a lower bill. The Act defines energy savings as the difference between the energy that could have been consumed before the project and the energy consumed after implementation over the same period, taking normalised external conditions into account.

A company may therefore reduce its costs without achieving a corresponding energy saving, for example by changing its tariff, renegotiating the energy price or changing the billing method. Conversely, a genuine energy saving may occur even if the cost in PLN does not fall because the energy price rises at the same time.

For example, if normalised consumption falls from 1000 to 800 MWh per year, the saving is 200 MWh per year regardless of whether energy costs 400, 600 or 800 zł/MWh. The price is important for the economics of the investment, but it does not replace calculation of the energy effect.

What does the application to URE contain and what happens after it is submitted?

The application for a certificate is submitted by the entity planning to start the project or by an entity authorised by it. The Polish Act requires, among other things, the following information:

• the applicant,
• the type and location of the project,
• the planned final energy savings in toe averaged over one year,
• the period over which the savings will be achieved,
• the planned start and completion dates of the works,
• information on other applications concerning the same project.

As a rule, the application must be accompanied by an energy efficiency audit and the required declaration. URE publishes the current application, authorisation and project-completion notification forms on its website.

Key procedural deadlines

• If required data or documents are missing from the application, the President of URE requests supplementation within 7 days of service of the request. Failure to supplement the application results in it being left without consideration.
• If the audit was not prepared by a person meeting the statutory requirements, URE requests a compliant audit within 30 days of service of the request.
• The Polish Act specifies 45 days from the date of submission of the application as the period for the President of URE to issue the certificate.
• URE publishes information on the issued certificate together with the audit card in the Polish Public Information Bulletin (BIP) within 7 days of issuance.

The 45-day period is a statutory deadline. When planning an investment, however, it should not be treated as a commercial guarantee that the entire procedure will be completed within that time – the need to supplement or verify documentation may affect the actual timetable of the case.

What can happen if the scope of the investment changes during implementation?

The application and audit are prepared for a specific technical option. If implementation differs materially from that option, the energy savings may also change.

Particular attention should be paid to changes in:

• the number or power of equipment,
• equipment efficiency and operating parameters,
• system operating time,
• production volume or load,
• location or the boundary of the system being analysed,
• pressure, temperature, flow or other process parameters,
• the control and automation strategy,
• the energy carrier,
• the way recovered energy is used.

If it is already known during implementation that the project will differ materially, it is best to recalculate the impact of the change before approving it, rather than waiting until final settlement.

After completion, if the final energy saving achieved differs from the value specified in the issued certificate, Article 23a of the Polish Act provides for an application to change the certificate value together with an audit confirming the achieved effect. Failure to submit the required amendment application may result in refusal to transfer the information to the register.

What must be done after the investment is completed?

After completion of the project, the entity notifies the President of URE. The notification is accompanied by:

• an energy efficiency audit confirming the achieved effect – if required,
• the required declaration confirming completion of the project and achievement of the savings,
• a document confirming the start of works, in particular a contract with the contractor or a document confirming the equipment order,
• a document confirming completion of the project.

When is a post-completion audit required?

The Polish Act does not require an audit confirming the effect after implementation if the project’s planned savings are no more than 100 toe averaged over one year. Above 100 toe, a confirming audit is required.

In addition, the pre-investment audit and the post-investment confirming audit may not be prepared by the same person for the same project.

If the savings actually achieved differ from the value specified in the certificate, the need to apply Article 23a may also require a confirming audit in order to formally change the certificate value.

Does the investor have 45 days to report completion?

No. The Polish Act currently in force does not establish a general 45-day deadline for a company to submit a project-completion notification. The 45-day period concerns issuance of the certificate by URE after the application is submitted.

After receiving a correct project-completion notification, the President of URE has 30 days to transfer the relevant information to the entity operating the register.

When are property rights created and how are they sold?

The property rights arising from the certificate are transferable. They are created when the certificate is first entered in an account in the register on the basis of information sent by URE after completion of the project. Rights are transferred by making the appropriate entry in the register.

In practice, rights arising from energy efficiency certificates with no expiry date are associated on the market with the PMEF_F instrument. Trading in these rights enables them to be sold to entities that use them, among other things, to fulfil the statutory energy-efficiency obligation in Poland.

White certificate price versus substitute fee

These are two different concepts:

• the price of property rights is a market price and depends on the terms of the transaction,
• the unit substitute fee is a parameter set by statute.

The Polish Act set the unit substitute fee for 2017 at 1500 zł/toe and, from 2018, provides for a 5% increase over the previous year’s value. Under that formula, the figure for 2026 is approximately 2326.99 zł/toe.

This does not mean that 1 toe of a white certificate “costs” 2326.99 zł. The substitute fee is not a guaranteed sale price for property rights, and the market price of PMEF_F should not be calculated by automatically adding 5% each year.

This fee should also be distinguished from the amount of 1500 zł/toe which Article 20 of the Polish Act requires to be used in a specific test concerning the permissible level of public aid. This is a separate statutory parameter, not a current market valuation.

Can white certificates be combined with a grant or other support?

There is no single answer that applies to every support programme. The Polish Act sets out specific restrictions.

No certificate is available for a project that has received a thermomodernisation bonus, except for certain low-emission projects specified in the Polish Act. In the case of investment aid, it is necessary to check whether granting the certificate would cause the permissible level of public aid to be exceeded.

Therefore, before combining white certificates with a grant, a loan containing a write-off element or another aid instrument, both the Polish Energy Efficiency Act and the documentation of the specific programme must be checked.

The most common mistakes that may result in losing the opportunity to obtain property rights

1. Starting the investment too early

Signing a binding equipment order before submitting the application may be treated as the start of works. This is one of the most serious errors because Article 24 of the Polish Act links it to refusal to transfer the information to the register.

2. Calculating cost savings instead of energy savings

A lower bill is not automatically an energy saving. The audit must demonstrate the energy effect under comparable, normalised conditions.

3. No reliable baseline

Incomplete measurement data, incorrect operating hours or failure to account for production and external conditions may materially distort the result.

4. Assuming that every modernisation exceeds 10 toe

The threshold concerns energy savings, not capital expenditure. An expensive investment may deliver less than 10 toe, while a relatively simple modernisation may exceed that threshold.

5. Arbitrarily combining different projects

The Polish Act allows the threshold to be applied to projects of the same type. Grouping should have a substantive and statutory basis.

6. Changing the scope without recalculating the effect

A change in power, equipment, operating time or control strategy may mean that the actual saving differs from the certificate value. In such a case, an application to change the value may be required.

7. Gaps in completion documentation

After implementation, documents are needed to confirm both the start date and completion of the project. Larger projects also require a confirming audit.

8. Ignoring public-aid rules

The fact that an investment is technically eligible for the system does not mean that every form of financing can automatically be combined with it.

9. False information in the settlement

The five-year restriction on applying for a new certificate is not the consequence of an ordinary rejection of an application. Article 28 of the Polish Act links it to providing false or misleading information about completion or the savings achieved, and to a negative verification of the savings.

Checklist before signing a modernisation order

Before the first binding commitment, it is worth confirming:

• the exact technical option to be implemented,
• whether the project is covered by the Polish system,
• whether the estimated saving exceeds 10 toe on average per year,
• which data and measurements substantiate the baseline,
• whether several locations or tasks can be treated as projects of the same type,
• whether the statutory start of works has already occurred,
• whether the project receives public aid or a thermomodernisation bonus,
• whether the audit and application documentation are ready for submission,
• which investment parameters should not later be changed without recalculation.

If some of these answers are not yet known, the safest approach is to treat the procurement stage as the point for analysis, not as the start of implementation “on a trial basis”.

Where can issued certificates and the status of a case be checked?

The President of URE publishes information in the Polish Public Information Bulletin (BIP) on issued certificates together with audit cards. The Polish Act provides for publication of this information within 7 days of the certificate being issued.

However, the public database of issued certificates should not be treated as a complete tracker of every application awaiting consideration. The status of a specific ongoing case is established through the appropriate communication with URE.

FAQ – frequently asked questions about white certificates in Poland

What are white certificates?

This is the common name for energy efficiency certificates issued by the President of URE under Polish law. They confirm the planned energy savings resulting from an eligible project.

How much is 1 toe?

1 toe corresponds to 41.868 GJ, or approximately 11.63 MWh of energy.

What is the minimum threshold?

As a rule, one project or projects of the same type must deliver at least 10 toe of energy savings averaged over one year, i.e. approximately 116.3 MWh.

When must the application be submitted?

Before the statutory start of works. The first legally binding commitment to order equipment may already be critical, not only the physical start of installation.

Do you have to wait for the certificate to be issued before starting the investment?

The Polish Energy Efficiency Act itself sets the key boundary at the application date. After a correct application has been submitted, there is no general statutory requirement to wait for the certificate to be issued, but any conditions of other support programmes must be checked.

Can any company obtain a white certificate?

The Polish Act does not restrict the system to large enterprises. The decisive factors are primarily the characteristics of the project, the energy effect, the start-of-works date and the other statutory conditions.

When is a post-completion audit required?

It is required when the planned saving exceeds 100 toe averaged over one year. It may also be needed in connection with a change in the certificate value if the actual saving differs from the value previously specified.

Is 45 days the deadline for reporting completion of the investment?

No. 45 days is the statutory period for the President of URE to issue the certificate from the date the application is submitted. After notification of completion, URE has 30 days to transfer the information to the entity operating the register.

How much does a white certificate cost?

There is no single statutory sale price for the property right. The price is market-based. It should not be equated with the unit substitute fee or with the amount of 1500 zł/toe used in the statutory public-aid test.

Who buys white certificates?

What is traded are the property rights arising from the certificates. Demand is linked, among other things, to fulfilment of the statutory obligation by obligated entities in Poland. The transaction itself is carried out in accordance with the rules of the market and the property-rights register.

Does an ordinary rejection of an application mean a five-year ban?

No. The five-year restriction under Article 28 of the Polish Act concerns specified cases of false or misleading information after implementation and a negative verification of the savings, not every procedural failure.

How should white certificates be accounted for?

They should not automatically be classified as a “grant” merely because they have economic value. Their accounting and tax treatment depends on the specific facts and the entity’s accounting policy; where the value is material, it is worth agreeing the treatment with the accounting team or a tax adviser.

When is it worth starting the procedure?

The best time is when the company already knows enough about the planned modernisation to calculate the energy effect, but has not yet entered into a binding commitment that constitutes the start of works within the meaning of the Polish Act.

If the project is still at the stage of comparing offers, selecting equipment or preparing the budget, a quick eligibility assessment can be carried out to decide whether a full audit and application are worthwhile. The later white certificates are considered, the greater the risk that procurement decisions have already been made in a way that closes access to the system.

If you are planning an investment in Poland and want to check its eligibility, the audit scope and the planned certificate value in toe, contact Energy Trend. For a project assessed before equipment is purchased, the most important step is to verify the timeline and technical data first – only then should irreversible procurement decisions be made.

Sources and legal status

This article was verified against information available as of 20 August 2026. The principal sources were:

• the Polish Energy Efficiency Act – consolidated text, Journal of Laws 2025, item 711,
• the detailed list of energy-efficiency improvement measures – Monitor Polski 2021, item 1188,
• current URE forms and information concerning energy efficiency certificates,
• URE’s list of current legal acts concerning energy efficiency.