approval for a subsidy in 2024 must normally complete the measures so that the subsidy can be paid out within one year of the approval being given. Husbanken provides loans for improving energy efficiency also to developers and housing associations<fnref n="143" />.

At the local level, some municipalities promote initiatives to support the improvement of the energy efficiency level of existing housing. The municipality of Oslo<fnref n="144" />, for example, has a support scheme for the installation of solar panels in housing cooperatives and condominiums, which covers 20% of the total expenses, and a support for replacing of windows and doors.<fnref n="145" />

Support and Networking Tools

Support and knowledge exchange around housing renovation and energy efficiency in Norway are facilitated through various structures. Husbanken plays a central role, not only through financing tools but also via its advisory function with municipalities and other actors, including participation in the development of new loan criteria (interviews). Knowledge sharing also occurs through inter-organizational cooperation, such as collaboration with the Directorate for Building Quality and meetings with Enova to coordinate support schemes and avoid overlap (interviews). Platforms like *Energi Nettverket* provide additional arenas for dialogue among municipalities, state actors, and energy experts, fostering policy learning and coordination (interviews). NGOs are also part of this ecosystem, contributing perspectives on equity and the implications of energy measures for disadvantaged groups (interviews). Despite these efforts, limitations exist in capacity and clarity about available tools, especially at the municipal level.

<table><thead><tr><td>Name</td><td>Typology</td><td>Actor</td><td>Description</td></tr></thead><tbody><tr><td>Enova Grants</td><td>Financial</td><td>Enova</td><td>Grants for energy-saving measures (e.g., insulation, heating systems); support for pilot projects and new technologies; typically cover about 20% of retrofit costs.</td></tr><tr><td>Husbanken Loans and Grants</td><td>Financial</td><td>Husbanken</td><td>Low-interest loans and grants for energy and accessibility upgrades; up to 90% coverage for high-ambition retrofits.</td></tr><tr><td>Municipal Support (e.g., Oslo)</td><td>Financial</td><td>Local Municipalities (e.g., Oslo Kommune)</td><td>Local schemes for energy improvements, including 20% subsidies for solar panels and</td></tr></tbody></table>

<footnote n="143">¹⁴³ https://www.husbanken.no/bransje/lan-og-tilskudd/boligkvalitet/oppgradering/</footnote>

<footnote n="144">¹⁴⁴ Solar energy subsidy - Klimaetaten</footnote>

<footnote n="145">¹⁴⁵ Oslo kommune støtter energieffektive vinduer og dører - Klimaetaten</footnote>
<table><caption>Table NO3. Policy tools for implementing energetic retrofitting in Norway</caption>
   <tr>
    <td>
    </td>
    <td>
    </td>
    <td>
    </td>
    <td>
     window/door replacement in cooperatives.
    </td>
   </tr>
   <tr>
    <td>
     Husbanken Advisory Services
    </td>
    <td>
     Support
    </td>
    <td>
     Husbanken
    </td>
    <td>
     Provides technical and financial advice to municipalities and housing actors; contributes to defining new loan criteria.
    </td>
   </tr>
   <tr>
    <td>
     Energi Nettverket
    </td>
    <td>
     Networking
    </td>
    <td>
     Municipalities, State Agencies, Energy Experts, NGOs
    </td>
    <td>
     Platform for policy learning and coordination around energy efficiency across governance levels.
    </td>
   </tr>
  </table>

4.3 Size and role of the market

Energy price settings

Norway's energy market is integrated into the Nordic power market, where electricity prices are determined by supply and demand dynamics. The Norwegian Energy Act is based on the principle that electricity production and trading should be market-based. A significant portion of Norway's electricity is generated from renewable hydropower, ensuring competitive and relatively stable energy prices. However, market fluctuations can occur during dry periods or when demand surges in connected European markets. Global events like the COVID-19 pandemic triggered a surge in energy demand, initiating a steep price rise. This trend was further intensified by the European energy crisis and the Russian invasion of Ukraine in 2022, which led to natural gas shortages across Europe. It should be noted that, in order to support households to mitigate high electricity costs, in September 2023 a support model (Strømstøttemodell) was introduced in Norway. The support is calculated hourly based on the spot price of electricity rather than a monthly average. If the spot price exceeds a threshold of 91.25 øre per kilowatt-hour (73 øre/kWh excluding VAT) during any given hour, the government covers 90% of the cost above this threshold. The support is automatically deducted from household electricity bills, reducing the amount payable. It applies to monthly consumption up to 5,000 kWh, with any usage beyond this limit excluded. While the scheme is available to all households, it does not cover holiday homes.

Furthermore, it should be noted that this situation is evolving rapidly in light of the ongoing government crisis. The debate surrounding the energy market and electricity pricing schemes remains highly contentious, with intense discussions on their potential impact. One of the most recent government proposals is the so-called *Norgespris* (Norwegian Price) for electricity, which would offer all consumers a fixed rate of 40 øre per kWh, excluding VAT. This measure
was discussed in the Policy Lab as a potential factor that could further discourage investment in energy retrofitting interventions.

## Energy obligation schemes

While Norway does not have a specific Energy Efficiency Obligation Scheme (EEOS) targeting housing retrofitting, Enova's programs described above serve a similar purpose by encouraging energy-efficient renovations through financial support and guidance. These efforts align with broader national goals to reduce energy consumption and greenhouse gas emissions in the residential sector.

## 4.4 The multilevel governance process

The governance of retrofitting in Norway is highly centralized, with both normative and financial responsibilities primarily managed at the national level.

In terms of the normative framework, the Ministry of Local Government and Regional Development and its subordinate agency, the Directorate for Building Quality (DiBK), are the key actors. They set energy requirements for existing buildings and establish building regulations (TEK). EU directives, particularly the Energy Performance of Buildings Directive (EPBD) and the Energy Efficiency Directive (EED), significantly influence Norway's national retrofitting framework by introducing stricter standards for energy efficiency and building energy labeling. However, Norway has not yet adopted a law mandating energy retrofitting for residential buildings with low energy standards, leaving the long-term effects of these directives uncertain.

Regarding the financial framework, two national entities play central roles in supporting building renovations: Enova, under the Ministry of Climate and Environment, and Husbanken, under the Ministry of Local Government and Regional Development. These organizations provide grants and financial incentives to encourage energy-efficient retrofitting.

At the current stage of research, no specific responsibilities for retrofitting seems to concern the regional level, and municipalities mainly have the role to apply for fundings for renovating municipal rental units (which constitute only the 3% of the overall Norwegian housing stock). For private buildings, the decision to retrofit, secure funding, and apply for national grants remains largely with individual property owners or housing associations.

Overall, Norwegian municipalities rely on national funding for housing retrofitting projects, highlighting their financial dependence. However, they appear to maintain some autonomy in regulatory matters, as there is no regulatory mandate for retrofitting non-public buildings, creating a nuanced balance between national oversight and local implementation.

<table><thead><tr><th>National level</th><th>Local level</th></tr></thead></table>
<table><caption>Table NO4. Governance structure of retrofitting in Norway</caption><tr><td>Responsible political actors</td><td>Ministry of Local Government and regional development: responsible for the Planning and Building Act<br/>Ministry of Climate and Environment: Coordinates Enova work<br/>Directorate for Building Quality (DiBK): responsible for developing and managing the building regulations known as TEK17, provides guidance on achieving energy efficiency in buildings<br/>The Norwegian Water Resource and Energy Directorate (NVE): coordinating role in energy matters including energy labelling of buildings and housing</td><td></td></tr><tr><td>Responsible Financial actors</td><td>Enova: provides grants for retrofitting to individuals and cooperatives<br/>Husbanken: provides loans for retrofitting to private and public housing (social rental stock and student housing)<br/>Banks: provide green loans to support energy-efficient measures, though these are currently more common for new construction than for retrofitting existing buildings.</td><td></td></tr><tr><td>Key regulatory tools</td><td>TEK 17: Regulations on technical requirements for construction works</td><td></td></tr><tr><td>Key Financial tools</td><td>Enova grants and Husbanken loans</td><td>Municipalities are responsible for applying for grants for the renovation of municipal rental housing from Husbanken. Furthermore, municipalities promote local grants for energy efficiency (e.g. installation of solar panels)</td></tr><tr><td>Key policies</td><td>Actions plans for energy reduction in the building sector:<ul><li>Environmental Action Plan 2005–2008</li><li>Build for the future: Environmental action plan for the housing and construction sector 2009–2012</li><li>Action plan for energy efficiency in all parts of the Norwegian economy 2023</li></ul></td><td></td></tr></table>

The synergies between retrofitting and housing affordability policies in Norway appear to be minimal. Firstly, Norway lacks a comprehensive housing affordability policy. National housing strategies focus primarily on homeownership and municipal housing, the latter representing only the 3% of the total stock and being limited to the most disadvantaged populations. While
some housing affordability initiatives have been undertaken by developers or specific
municipalities, no clear connection to retrofitting policies has been observed.

Secondly, financial support for retrofitting is limited. Further research is needed to better understand the gap between the available grants and the actual costs borne by private property owners, which may act as a barrier to widespread retrofitting efforts. Additionally, the absence of a rent control law in Norway means there are no mechanisms in place to regulate rent increases linked to retrofitting interventions, potentially leading to higher rents.

Finally, the primary measure implemented to address household housing costs appears to be national support for electricity bills, rather than measures directly targeting the affordability of housing or the integration of retrofitting into broader affordability strategies.

4.5 Achievements, assessments, and challenges

Literature analysing the relationship between housing retrofitting and housing inequalities in Norway is, to our knowledge, extremely limited. At this stage, only one academic study was identified—Fyhn et al. (2019)—which highlights the challenges homeowners face when accessing Enova grants for retrofitting. Given this knowledge gap, the following analysis draws on informed hypotheses grounded in the institutional characteristics of Norwegian retrofitting and housing policies, complemented by empirical insights gathered through expert interviews and discussions conducted during the Policy Lab.

A central issue emerging from this material is the lack of integration between retrofitting and housing policy. Norway has no comprehensive housing affordability strategy, and existing retrofitting instruments do not account for affordability—for instance, through income-targeted subsidies. Public grants for retrofitting are relatively modest, with households typically required to cover up to 80% of the total cost (interviews). This financial structure poses a substantial barrier to broader uptake and risks deepening inequalities between those who can afford to invest in retrofitting and those who cannot. As one interviewee noted, current schemes are designed primarily to stimulate market activity—encouraging the adoption of new technologies and fostering demand—rather than to ensure accessibility for lower-income groups (interviews).

This dynamic is particularly problematic in the rental sector, where tenants are significantly more exposed to energy poverty and substandard housing conditions than homeowners. In Norway's highly commodified rental market, energy efficiency improvements depend entirely on the initiative of property owners. No direct support is available to tenants, and existing grants do little to incentivise landlords—whether private or public—to invest in upgrading the housing stock (interviews). The core vulnerability for tenants lies not so much in the risk of renoviction, but in the structural imbalance between landlords and tenants, particularly when it comes to negotiating for adequate energy standards. Many tenants are reluctant to report poor housing conditions due to fears of eviction or lease non-renewal (interviews). This problem is compounded by the common practice of separating energy costs from rent, which further weakens landlords' incentives to improve energy performance.
Access to Enova support also presents a number of structural and procedural challenges. Fyhn et al. (2019) describe how homeowners are often deterred by complex application procedures, extensive documentation requirements, and the relatively limited financial support offered. These administrative burdens disproportionately affect less resourceful households, such as those lacking digital literacy, language proficiency, or time to navigate bureaucratic processes. Several interviewees pointed out that this creates a polarisation in both energy costs and housing quality, particularly disadvantaging elderly residents, single parents, or low-income homeowners without the capacity to engage in lengthy application processes.

The cooperative housing sector is another area where affordability concerns and retrofitting efforts intersect in particularly complex ways. When building maintenance or energy upgrades are financed through collective loans, the associated debt burden can place significant financial pressure on individual residents, in some cases forcing them to sell their homes (interviews). Yet these same debt levels may reduce the market value of the property, making resale more difficult and potentially limiting sellers' ability to purchase a comparable home in the same neighbourhood. According to interviewees and Policy Lab participants, tensions within cooperatives are common, though rarely discussed publicly. Decisions around retrofitting are often politically and socially negotiated. In several cases, board members expressed hesitation to proceed with renovations if the costs risk displacing vulnerable residents—even when the majority supports the investment. Without formal mechanisms or mandates to ensure equitable decision-making, action depends on consensus, and disagreement or discomfort can stall necessary upgrades. As such, the cooperative model illustrates how retrofitting decisions are shaped not only by economic constraints, but also by internal social dynamics, timing, and shared norms.

Territorial disparities further reinforce these patterns of uneven retrofitting outcomes. Larger cities such as Oslo and Bergen are better positioned to access national funding, launch pilot projects, and coordinate multi-stakeholder efforts. Smaller municipalities, by contrast, often face resource constraints, limited administrative capacity, and difficulties meeting co-financing requirements. As several interviewees noted, some municipalities lack the institutional capacity to pursue retrofitting efforts, even when there is political support or evident local need (interviews). Without mechanisms for redistribution or inter-municipal support, retrofitting risks reinforcing spatial inequalities, with the greatest progress concentrated in already well-resourced areas.

<table><thead><tr><td></td><td>Potential Impacts</td></tr></thead><tbody><tr><td>Affordability and Access to Grants</td><td>Deepening inequalities between those who can and cannot afford retrofitting; increased polarization of housing quality.</td></tr><tr><td>Rental Sector Vulnerabilities</td><td>Increased energy poverty in rental housing; risk of hidden evictions and deterioration of rental stock.</td></tr><tr><td>Administrative Barriers</td><td>Widening gaps in housing standards and energy efficiency between well-connected and vulnerable households.</td></tr></tbody></table>
<table><caption>Table NO5. Potential impacts of retrofitting policies on housing inequalities.</caption>
   <tr>
    <td>
     Cooperative Housing Sector
    </td>
    <td>
     Reduced housing stability; internal conflicts delaying or blocking retrofitting efforts.
    </td>
   </tr>
   <tr>
    <td>
     Territorial Disparities
    </td>
    <td>
     Fragmented national retrofitting landscape; reinforcement of urban-rural inequality.
    </td>
   </tr>
  </table>

5 Nature-Based Solutions

5.1 The Policy Cycle: Emergence of the Issue and Policy Decisions

Legal Requirements

In Norway, Nature-Based Solutions (NBS) are defined in accordance with the UNEA 5.2 definition (UNEP United Nations Environment Programme, 2022) which states that NBS are 'actions to protect, conserve, restore, sustainably use and manage natural or modified terrestrial, freshwater, coastal and marine ecosystems which address social, economic and environmental challenges effectively and adaptively, while simultaneously providing human well-being, ecosystem services, resilience and biodiversity benefits.'

NBS are increasingly central to Norway's climate adaptation and biodiversity policies, shaped by global agreements like the Paris Agreement (United Nations, 2015) and the UN Global Biodiversity Framework (United Nations, 2022). These have promoted ecosystem-based approaches, reinforcing NBS in areas such as stormwater management and biodiversity conservation through national frameworks and local experimentation (Nordic Council of Ministers, 2019).

Today, there is an explicit legal requirement to consider NBS in spatial planning guidelines in
Norway. A key milestone for reaching this has been the adoption of the **State Planning Guidelines for Climate and Energy Planning and Climate Adaptation (henceforth, SPR Klima)** published in 2018 (Kommunal- og distriktsdepartementet, 2018). The SPR Klima states that the preservation, restoration, or establishment of NBS (such as existing wetlands and natural streams, or new green roofs and walls, artificial streams, and pools) should be considered. SPR Klima requires municipalities and regional authorities to assess the use of NBS in climate adaptation planning. If alternative solutions are chosen, planners must justify why NBS are not selected (Kommunal- og distriktsdepartementet, 2018). While not legally binding for private actors, the guidelines must be incorporated into zoning plans for legal effect. Non-compliance may trigger objections from relevant authorities under the Planning and Building Act (2008). (Di Marino et al., 2025)

These guidelines, built upon earlier 2009 strategies, place a stronger emphasis on climate
adaptation and ecosystem services, and their implications are particularly evident in two
national policy documents shaping spatial planning in Norway: The **National Expectations
regarding Regional and Municipal Planning** published in 2019 and 2023. The most recent
version (Ministry of Local Government & and Regional Development, 2023) is the main
planning instrument for implementing NBS (Di Marino et al., 2025). These guidelines recall the key message of SPR Klima (2018), by highlighting the relevance of NBS as a climate mitigation tool in spatial planning, including water management (Di Marino et al., 2025). The National expectations are updated every four years.

Additionally, in 2022, the Norwegian Ministry of Climate and Environment published a white paper (Meld. St. 26, 2022–2023), stating that NBS should be used to reduce flooding or stormwater, thus stabilising the ground and preventing landslides, while preserving or improving the conditions for biodiversity. The meaning is that “changing climate and natural hazards are better addressed in risk and vulnerability analyses in connection with specific building applications and when land-use plans are updated” (Ministry of Environment and Climate 2020, p.46). An important principle is that the municipalities might be allowed to charge a separate fee to the residents in order to fund NBS measures, such as stormwater measures, and the opportunity to extend this is under consideration by the Government (Ministry of Environment and Climate 2020).

Finally, in **2024**, the Norwegian Government adopted the new **State Planning Guidelines for Climate and Energy** in which there is a small change - compared to the SPR Klima, 2018 - in the purpose regarding climate adaptation (see *objective d*: society and ecosystems are prepared for and adapted to climate change, in which NBS are also included). In addition, the flood and landslide report that was recently adopted in the Storting (Kommunal- og distriktsdepartementet, 2024) also mentions NBS as a crucial asset (chapter 7.2.4)

These updates reflect a broader shift toward embedding NBS more systematically into Norwegian spatial planning and climate adaptation strategies. However, local governments remain responsible for implementation, and approaches vary across municipalities (Furuseth, Ingvild Skumlien et al., 2024).

Influence of World, Nordic and EU Directives

Over the last few years, there has been increasing awareness and implementation of NBS in the Nordic countries. International and Nordic policies on NBS have given relevant impulses to the national policy making, while the EU's policies have contributed to a limited extent to the debate and Norwegian agenda.

The reports/programs from i) the International Union for the Conservation of Nature (IUCN, 2016), ii) the Intergovernmental Science-Policy Platform on Biodiversity and Climate change (Pörtner et al., 2021), and iii) the United Nations Environment Programme (2022) have increased the awareness about the implementation of NBS in Norway. These key policies are fundamental to achieve global targets for both biodiversity, as well as for climate change mitigation and adaptation. In 2022, by joining the Nordic ministerial declaration on NBS in 2022 (Sandin et al., 2023), Norway was committed to “actively promote the full potential of nature-based solutions, while ensuring their social and environmental safeguards and enhancing their multiple benefits”.

Norway's commitment to the EU Water Framework Directive (2000/60/EC) and the UN
Sustainable Development Goals results in the River Basin Management Plans (RBMPs, 2016).
Through the RBMPs, the regional water authorities (vanneregionmundigheter) have
recognised the importance of the NBS in water planning (Di Marino et al., 2025). Consequently, the RBMPs have been implemented in the regional plan and by the municipalities (Di Marino et al., 2025). The objectives of the RBMPs are legally binding. This means that all public authorities should implement measures for protecting all water and groundwater surfaces (Di Marino et al., 2025) referring to (Larsen & Solli, 2022).

<figure><img src="image_77.png" /><figcaption>Figure NO2. Timeline illustrating key policies and regulations in Norway (bottom part), internationally and EU (upper part) affecting NBS (in green)</figcaption></figure>

5.2 The implementation process

The implementation of NBS in Norway reflects a multi-faceted approach combining regulatory measures, financial incentives, and collaborative strategies (Furuseth, Ingvild Skumlien et al., 2024).

Municipalities often incorporate incremental deadlines into their planning cycles, such as five-year reviews of climate adaptation plans (Furuseth, Ingvild Skumlien et al., 2024). The implementation of NBS should be regulated in land use planning. This means that there should be recognized as a legal basis if obligations are to be imposed on **private parties, and thus affecting property rights** (Di Marino et al., 2025). As mentioned in Section 2.1.1, the SPR Klima (2018) is not a legally binding tool that can impose the use of NBS on private parties (Di Marino et al., 2025). Therefore, the instructions of the SPR Klima (2018) should be
implemented into existing legally binding zoning plans (Di Marino et al., 2025). On the contrary, the implementation of NBS on **public properties** is typically a local policy question. The municipalities can decide which criteria to adopt for determining and using NBS – and the result is related to local finances, practical conditions, or other factors (Di Marino et al., 2025, referring to (Junker, 2024). A key challenge in the implementation process concerns territorial disparities, particularly between urban and rural areas. Smaller and rural municipalities appear to be adapting more slowly to the national guidelines, largely due to limited administrative capacity, technical expertise, and human resources. In contrast, larger cities often have more robust institutional frameworks and dedicated staff, which allow them to respond more efficiently and proactively to policy changes (Furuseth, Ingvild Skumlien et al., 2024). This uneven pace of adaptation is further exacerbated by disparities in access to financial and technical support mechanisms. As detailed below, smaller municipalities often face greater obstacles in navigating and benefiting from the available support schemes, which further hinders their ability to implement national directives effectively and equitably. As reported by Di Marino et al. (2025), in 2023, 70% of Norwegian zoning plans were initiated by private developers (Minde, 2023). The financial tools reported below mainly target public properties in municipalities and do not have different implications for different housing tenures. In the same way, regulatory frameworks developed by municipalities concerning green roofs and other NBS for stormwater management in new developments can indirectly affect housing costs in all housing tenures.

Financial Tools

The main aim of the **Government is** to support the implementation of NBS in **spatial planning practices**. Additional national instruments are in force for the NBS implementation, such as **grant schemes offered by the Norwegian Environment Agency** (*Miljødirektoratet*) (Di Marino et al., 2025). This allows municipalities and other local authorities to develop NBS - among the tools for climate change adaptation, as well as networks among different actors involved in climate adaptation strategies (Di Marino et al., 2025). The Norwegian Environment Agency provides guidance to the municipalities for implementing NBS for climate adaptation in spatial planning (such as a web-based guide, guidelines on how to work with NBS, referencing several reports, examples and webinars) (Di Marino et al., 2025)

The municipal practitioners interviewed by Furuseth et al. (2024) stated that having the option to apply for government grants is important for supporting the implementation of NBS. All Norwegian municipalities can apply to the above-mentioned grant schemes. The national guidelines, fees and tools can be implemented in both urban and rural contexts.

In addition to the public grants for NBS mentioned above, there are direct funds for restoration and nature protection projects, urban climate change adaptation, stormwater treatment and water quality improvement (Nordic Council of Ministers, 2022). However, most of these funding opportunities have not been tagged with NBS, but used other terms such as storm water management, green structure, etc.

In addition to these grants, which directly target the implementation of NBS, there are also complementary support schemes provided by various government bodies and agencies. While not specifically designed for NBS, these schemes can indirectly facilitate their implementation
by offering funding, technical assistance, or capacity-building opportunities that align with
broader environmental or planning goals. In the agricultural sector, the **Nasjonalt miljøprogram** (National Environmental Program), introduced in 2004, offers financial
incentives to farmers and landowners to implement practices that preserve biodiversity and
enhance ecosystem services. Grants are available for maintaining and restoring agricultural
landscapes, promoting sustainable farming practices, and establishing buffer zones along
waterways to reduce nutrient runoff. Additionally, the Norwegian Water Resources and Energy
Directorate (NVE) provides funding for projects related to flood and landslide risk management
and supports initiatives that incorporate solutions like floodplain restoration and the
enhancement of natural water retention areas. These projects aim to utilise natural systems to
absorb and manage water flow, thereby reducing the impact of extreme weather events.

Regulatory Tools

Several municipalities in Norway have implemented regulatory measures to integrate NBS into urban planning and development. Municipal zoning policies (Furuseth, Ingvild Skumlien et al., 2024) often mandate a minimum percentage of green areas in new developments, utilising tools like the **Blue-Green Factor (BGF)** to quantitatively assess and promote the integration of green and blue elements. In some municipalities, **tree planting obligations** require the replacement of removed trees with new plantings to maintain urban canopy cover. In others, **green roof and wall** requirements encourage or mandate the installation of green roofs to manage stormwater and reduce heat islands. The concept of **area neutrality** is also gaining traction, aiming to balance land development with the preservation of natural areas to maintain ecological functions and services.

Support and Networking Tools

To facilitate the implementation of NBS, Norway has developed various support and networking tools. Workshops and **training** programs equip municipal planners with the skills to design and implement NBS effectively. **Public awareness campaigns** and collaborative networks, facilitate knowledge sharing among municipalities. (SINTEF, 2022). It is important to highlight that Norway's active participation in numerous **EU research-funded projects** has fostered the development of living labs, **pilot experiments**, and extensive networking opportunities, thereby enhancing innovation and collaborative efforts across various sectors.

IFont is a network that was established in 2015, consisting originally of 11 cities and coordinated by the Norwegian Environment Agency. The network has been contributing to increasing and sharing knowledge and competence across the municipalities and regions, as well as testing and developing climate adaptation measures. iFront is also a reference group for several national processes, such as the assessment of the BGF, as well as some research and **development initiatives related to green roofs** (Di Marino et al., 2025)

Criticalities

The implementation of NBS is facing several barriers and important criticalities. At the national level, guidelines from 2018 and 2024 provide strategic direction, but **enforcement mechanisms remain limited**, making municipal implementation highly dependent on local
political and financial conditions (Barkved, L. J. et al., 2024). First, in terms of financial constraints, the **high upfront costs** of NBS often deter municipalities and developers. Smaller municipalities, in particular, struggle to allocate resources for NBS projects. A second important challenge is related to the **resistance from developers** since frequently they argue that NBS requirements, such as green roofs, increase project costs and complexity (Furuseth, Ingvild Skumlien et al., 2024). Additionally, there are **knowledge gaps**. Limited expertise among municipal planners hinders the effective evaluation and implementation of NBS. Finally, there are **conflicts between urban priorities**. Indeed, balancing NBS with urban densification and affordable housing goals remains a persistent challenge, particularly in high-demand urban areas like Oslo and Trondheim (Cucca et al., 2024).

<table><thead><tr><td>Name</td><td>Tipology</td><td>Actors</td><td>Description</td></tr></thead><tbody><tr><td>Klimasats and other granting schemes</td><td>Financial</td><td>Environmental Directorate</td><td>Support schemes: Municipalities and county authorities can apply for funds for knowledge building and studies on specific climate adaptation measures.<br/>Klimasats schemes for NBS in flood-prone areas (green roofs, urban wetlands, and the restoration of natural waterways to manage stormwater and mitigate flooding risks)</td></tr><tr><td>National environmental Program</td><td>Financial</td><td>Agriculture Directorate</td><td>Maintaining and restoring agricultural landscapes along waterways.</td></tr><tr><td>Support scheme</td><td>Financial</td><td>Norwegian Water Resources and Energy Directorate</td><td>Projects related to flood and landslide risk management and supports initiatives that incorporate solutions like floodplain restoration and the enhancement of natural water retention areas</td></tr><tr><td>BGF</td><td>Regulatory</td><td>Municipalities</td><td>Tools that aim to increase the impact of various blue-green qualities in outdoor spaces, such as open stormwater management initiatives, and conservation and planting of trees. It is a method to ensure the provision of sufficient blue-green areas, together with the management of their water and vegetation. The idea behind them is to plan infill developments more sustainably by providing more permeable surfaces and vegetation. This approach is being used for new construction projects</td></tr><tr><td>No-net loss 'area neutrality'<br/>Municipalities</td><td>Regulatory</td><td>Municipalities</td><td>An approach with the goal of 'net zero loss' of nature, based on the principles of a hierarchy of measures to avoid natural consequences, then mitigate, then restore, and possibly, as a last resort, compensate by implementing natural interventions.</td></tr></tbody></table>
<table><caption>Table NO6. Tools for NBS in Norway</caption><tr><td>Green structure<br>Municipalities</td><td>Regulatory</td><td>Municipalities</td><td>It aims to manage biological diversity in a sustainable way and to protect cultural landscapes and cultural heritage for future generations. It has a regulatory role. It has been introduced as a <strong>land-use category, including its sub-categories of land use nature areas, open spaces, parks and green areas for walking</strong></td></tr><tr><td>IFont</td><td>Networking</td><td>Norwegian Environment Agency</td><td>Arena coordination cities efforts in NBS</td></tr></table>

## 5.3 Size and role of the market

A combination of public, private, and civil society contributions defines the market framework for NBSs in Norway. While the public sector remains central to initiating and supporting NBS projects, the private market has increasingly taken on a role in scaling up and innovating these solutions. However, **purely market-driven NBS** interventions remain still **limited** (Wilbers et al., 2022).

**Public-private partnerships are fundamental** to Norway's NBS market (Barton et al., 2015). Government bodies, such as the Norwegian Environment Agency, provide funding and regulatory guidance, while private actors contribute expertise and resources for implementation. For example, urban green infrastructure projects like rain gardens and green roofs in Oslo are frequently developed through such partnerships, where municipalities offer incentives, and private developers handle construction and maintenance (Wilbers et al., 2022). However, many large-scale NBS projects, such as urban park development or riverbank restoration, depend on significant public funding, while most of the micro-scale interventions are initiated by private developers in the zoning plans (Furuseth, Ingvild Skumlien et al., 2024).

Anyway, the professional private sector's role in NBS is expanding, especially in urban areas. Companies specialising in green infrastructure, landscaping, and architecture increasingly include NBS in their portfolios, driven by demand for eco-certified developments and sustainable solutions. However, many developers still do not expect to gain particular economic benefits from the implementation of NBS, unless these interventions overlap with other specific contextual elements of the projects (central location, proximity to blue infrastructures, public transportation, etc) (Barton et al., 2015; Cucca et al., 2024)

Regulatory frameworks are pivotal in shaping the NBS market. Requirements like zoning regulations and tools such as the Blue-Green Factor (BGF) promote the integration of NBS into urban planning, creating demand for private services in design and installation (Di Marino et al., 2024). Additionally, knowledge transfer from publicly funded pilot projects has helped in building professional expertise, reducing barriers for private actors to participate in NBS implementation (Furuseth, Ingvild Skumlien et al., 2024)
Examples of market-driven NBS in Norway include **eco-certified developments**, where real estate projects integrate green roofs, energy-efficient landscaping, and stormwater management systems to meet **certification standards like BREEAM** (Wiik et al., 2023). Companies specialising in green infrastructure also lead urban NBS implementation, such as permeable pavements and bioretention systems, often under contract with municipalities. Furthermore, corporate social responsibility (CSR) initiatives see businesses investing in NBS to **enhance their environmental branding**, such as sponsoring urban tree planting or biodiversity projects in collaboration with local governments (Time, 2023). However, high upfront costs and long-term economic returns deter purely market-based interventions (Barton et al., 2015). The willingness for immediate profitability indeed limits private sector contributions, as many benefits of NBS—such as reduced flood damage or increased property values—accrue over time (Barton et al., 2015; Cucca et al., 2024).

In conclusion, regulatory frameworks and public funding remain essential in shaping market dynamics, providing the necessary incentives for the implementation of NBS. Some of the municipal practitioners interviewed by Furuset et al. (2024) stated that developers should pay and maintain the NBS, while some government grants to which the developers can also apply (see Section 2.2.1) should support the municipalities to develop and maintain NBS. At the same time, according to the municipal managers, there is a common perception among the private developers that the implementation of NBS is costly, and some developers believe that the implementation of these measures may block new housing construction (Di Marino et al., 2015, p.X). Additionally, the financial support for developing and maintaining NBS is often originated from different public agencies, thus there is not a unique budget but fragmented financial sources (Di Marino et al., 2015). „At the moment, municipalities cannot fund NBS, such as a rain bed or open ditch/stream, through income from water supply fees“ (Di Marino et al., 2015, p. 14). The municipal planners are also aware that not all developers are familiar enough with the concept of NBS and the use of NBS can be perceived as increasing the cost of the process (Furuset et al. 2024). Additionally, the use of NBS also often means that area must be set aside for green areas that could otherwise be residential space with a greater prospect of profit (Furuset et al., 2024). In the context of ongoing housing shortages in major cities, this trade-off can significantly influence political decision-making processes and the dynamics of negotiation between public authorities and private developers. It may also place pressure on local regulatory frameworks, as municipalities attempt to balance environmental objectives with housing demand and market interests. Regulatory frameworks are pivotal in shaping the NBS market. Requirements like zoning regulations and tools such as the Blue-Green Factor (BGF) can be used to promote the integration of NBS into the land use, creating demand for private services in design and installation (Di Marino et al., 2024). Additionally, knowledge transfer from publicly funded pilot projects should help in building professional expertise, reducing barriers for private actors to participate in NBS implementation (Furuseth et al., 2024).

5.4 The multilevel governance process

The implementation and governance of NBS in Norway operate within a **multilevel framework** (Gundersen Enge et al., 2024) that includes the national, regional and local levels and
generally relies on the principles of ministerial responsibility and local self-governance (Christensen & Lægreid, 2020).

At the **national level**, the regulation and implementation of NBS involve multiple ministries, reflecting their relevance across environmental, urban, agricultural, and infrastructural sectors. The **Ministry of Climate and Environment** plays a central role by developing policies, funding programs, and overseeing environmental agencies such as the **Norwegian Environment Agency** (Miljødirektoratet), which supports the practical implementation of NBS. The **Ministry of Local Government and Regional Planning** integrates NBS into urban development and land-use planning, ensuring green infrastructure is included in zoning regulations. The **Ministry of Agriculture and Food** promotes NBS through sustainable land management and biodiversity conservation in rural areas. The **Ministry of Transport** incorporates NBS into infrastructure projects, while the **Ministry of Petroleum and Energy**, through the **Norwegian Water Resources and Energy Directorate (NVE)**, funds projects related to flood risk management and ecosystem restoration. These ministries collaborate to ensure that NBS contribute effectively to climate adaptation, biodiversity, and sustainable urban development.

The responsibility for land use planning in Norway is decentralised, with regional and local authorities playing pivotal roles as authorized by the national **Planning and Building Act**. At the **regional level**, the **county authorities** (Fylkeskommune) are supposed to coordinate planning efforts across municipalities, ensure compliance with national objectives, provide guidance, and support to municipalities. This tier is particularly important for disseminating best practices and addressing regional climate adaptation challenges. The Region of Rogaland, however, stands out as the only region with an explicit climate adaptation plan prioritising NBS (Rogaland Region, 2020), setting ambitious goals for green, multi-functional solutions (COWI, 2024).

Locally, **municipalities** (Kommune) hold the primary authority for detailed land use planning within their jurisdictions. They are responsible for developing municipal master plans (kommuneplan), zoning plans (områdeplan), and detailed zoning plans (detaljregulering), which guide the development and use of land following both local needs and national policies. They are the primary implementers of NBS and are supposed to incorporate NBS into zoning regulations, pilot projects, and community engagement initiatives (Furuseth, Ingvild Skumlien et al., 2024).

The national government provides a range of guidelines to support municipalities in the implementation of nature-based solutions (NBS), with the stated aim of strengthening knowledge, skills, and institutional capacity among local authorities and stakeholders. Despite these efforts, many municipalities continue to face significant technical and financial challenges in translating NBS strategies into practice. Environmental NGOs, such as Naturvernforbundet, actively promote stronger and more ambitious NBS policies. However, their influence on local planning processes tends to vary widely, depending on the political priorities, institutional openness, and resource constraints of individual municipalities. The decentralised governance system, while allowing for tailored solutions, has however led to fragmentation of responsibilities. Smaller municipalities, in particular, struggle with the technical and financial demands of implementing NBS strategies. Environmental NGOs, such
as Naturvernforbundet, advocate for stronger NBS policies, but their influence varies depending on local political priorities.

A notable **gap in coordination exists between NBS policies and housing strategies.** While both should aim to enhance urban livability, investments in green infrastructure can inadvertently contribute to increasing housing costs. For instance, new or revitalised green spaces may drive up property values. Furthermore, in densely populated urban areas, the prioritisation of green infrastructure can reduce available land for affordable housing developments, creating competing priorities.

Municipalities' regulatory autonomy allows them to tailor NBS strategies to local contexts, but this discretion also leads to inconsistencies in how these solutions are prioritised and executed. Additionally, municipalities may rely on national grants and subsidies to fund large-scale NBS projects, such as riverbank restoration or stormwater management systems. This financial dependency limits their ability to independently sustain or expand NBS initiatives.

<table><caption>Table NO7. Governance structure of NBS in Norway</caption><thead><tr><th></th><th>National level</th><th>Regional Level</th><th>Local level</th></tr></thead><tbody><tr><th>Responsible political actors</th><td>Norwegian Government<br>Main actor: Ministry of Climate and Environment<br>Other actors:<br>Ministry of Local Government and regional development<br>Ministry of Agriculture and Food<br>Ministry of Transport<br>Ministry of Petroleum and Energy</td><td>Counties coordinate and support municipalities, according to national recommendations</td><td>Municipalities develop masterplans and area zoning plans, while developers propose detailed zoning plans</td></tr><tr><th>Responsible Technical actors</th><td>Norwegian Environment Agency</td><td></td><td>Municipal Planning Departments<br>Private Developers propose detailed zoning plans</td></tr><tr><th>Key regulatory tools</th><td>SPR Klima<br>Planning and Building Act, Land Act, Nature Diversity Act, National Climate Strategies</td><td>Regional Land-Use Plans, Environmental and Transport Guidelines</td><td>Municipal Masterplan (land use element), Zoning plans (area zoning and detailed zoning)</td></tr><tr><th>Key policies</th><td>National Climate Plans (since the 1990s)</td><td></td><td>Local climate Plans and Municipal Masterplans</td></tr></tbody></table>

## 5.5 Achievements, assessments, and challenges

Local experimentations with NBS have proven effective in enhancing climate resilience and mitigating environmental risks (SINTEF, 2022). Urban biodiversity has also benefited from NBS initiatives, supporting greater species diversity and strengthening ecosystem services. Investments in urban parks and green infrastructure have revitalised public spaces, improved recreational opportunities and contributed to residents' mental well-being (Time, 2023).
However, critical evaluations of NBS implementation highlight challenges and unintended consequences that need attention.

Despite the emphasis on NBS in various Norwegian guidelines and norms, the **availability of green spaces has been decreasing** in several urban areas due to densification, notably in Oslo (Næss et al., 2020). Moreover, the distribution of green and blue infrastructures is often inequitable, leading to disparities in access among different communities (Venter et al., 2023). To address spatial inequalities, the government has, over the past two decades, implemented large-scale area-based policies aimed at improving the quality of green spaces in socioeconomically disadvantaged districts (Områdesatsinger). While comprehensive empirical evidence on the effects of these initiatives on housing values is still lacking, insights from key informants suggest that their implications vary significantly depending on the degree of vulnerability to gentrification in different neighbourhoods. In areas already experiencing market pressure and demographic shifts, investments in green infrastructure may contribute to rising property values and the risk of displacement, whereas in more stable or marginalized districts, such improvements may just enhance quality of life (Cucca et al., 2024). Enhanced green spaces can increase property values, making neighborhoods more desirable but also raising the risk of **green gentrification** (Cucca et al., 2024). The effects of NBS on housing costs appear to be highly context-dependent. Price increases following the implementation of NBS are more likely to affect specific neighbourhoods with pre-existing socio-economic and spatial characteristics that make them susceptible to market-driven pressures (Barton et al., 2015).

The **policy capacity** (Cucca & Ranci, 2022) of municipalities to prevent rising housing costs related to NBS implementation remains uncertain, due to lack of coordination between housing and planning policies in the multilevel governance framework (Di Marino et al., 2023). In Norway, housing affordability policies and tools are relatively **weak**, complicating the integration of NBS without exacerbating housing pressures. Additionally, a lack of alignment between NBS and housing policies may result in **competing priorities**, particularly in high-density urban areas where space for green infrastructure and housing are in direct competition (Cavicchia, 2021a). Policies aimed at preserving carbon-rich areas, wetlands, and forests—while essential for biodiversity and climate mitigation—could further limit land availability for housing, driving up demand and property prices. Moreover, integrating NBS into development plans may **increase construction and maintenance costs**, which could ultimately be passed on to residents, reducing affordability even further.

Establishing robust **monitoring** systems would enable policymakers to better understand how NBS contribute to social and environmental goals and ensure that their benefits are distributed equitably.

<table><thead><tr><th></th><th>Potential Impacts</th></tr></thead><tbody><tr><td>Private Owned Market</td><td>High maintenance costs can increase monthly fees;<br>high production costs of NBS can increase housing price;<br>available land for development can be reduced</td></tr><tr><td>Rental Sector Vulnerabilities</td><td>In some central, dense areas, NBS can increase direct and indirect displacement due to the higher attractiveness of the neighbourhood</td></tr></tbody></table>
<table><caption>Table NO8. Potential impacts of NBS on housing inequalities.</caption>
   <tr>
    <td>
     Cooperative Housing Sector
    </td>
    <td>
     High maintenance costs can increase monthly fees; high production costs of NBS can increase housing prices
    </td>
   </tr>
   <tr>
    <td>
     Territorial Disparities
    </td>
    <td>
     Can increase territorial disparities in housing prices following greening or risk adaptation, if it is not implemented in an equitable way
    </td>
   </tr>
  </table>

6 Densification

6.1 The policy cycle: emergence of the issue and policy decisions

The concept of densification gained currency in Norway already from the Brundtland report (WCED, 1987). The "Nature and Environmentally Friendly Urban Development" (NAMIT) project, which ran from 1988 to 1992, introduced in Norway the principle of densification as a strategy to **counteract undesirable consequences of urban sprawl**. The findings from NAMIT have been foundational for subsequent research on sustainable urbanization in Norway. Since those years, the concept was explicitly tied to climate action and sustainability goals, with the strong rationales of contrasting urban sprawl, protecting green and agricultural areas and promoting mixed development. Another key justification was the imperative to reduce emissions contributing to climate change. The principles of compact urban development, deeply rooted in environmental rationales, have gained widespread acceptance in Norway and have been systematically institutionalized. From the early 1990s onward, these principles were integrated into national policies and regulations, reflecting a proactive approach to sustainable urban planning. In the latest years, the relevance of densification for sustainable development has been further emphasized in Norway in connection to the expansion of the second-home phenomenon, often referred to as "recreational sprawl." Notably, densification has emerged as a prominent planning and land-use concept in Norway well before European directives began to influence its adoption, underscoring the country's early commitment to aligning urban development with environmental sustainability.

Legal requirements

As mentioned above, the **Planning and Building Act** is the Norwegian national planning law. Even though there is no national law imposing densification directly, densification is emphasized in the Act as the most sustainable urban development strategy and expectations for sustainable land-use are established at the national level for both regional and local levels. In the Planning and Building Act it is stated that "More compact cities and places make it easier for people to walk, cycle and use public transport. This improves access to jobs, services and cultural offerings. At the same time, transformation and higher utilisation of already developed areas will reduce the need to reduce agricultural land and land that sequesters carbon." Furthermore, the Planning and Building Act represent the legal framework for coordinated housing, spatial and transport planning, the main principle of the Norwegian national planning
law for sustainable development. The support for densification is also linked to the zero-traffic growth goal, which was first stated in the 2012 Parliament's climate agreement and then incorporated in the subsequent national transport plans (IPAC & OECD, 2021). Densification, indeed, is deemed to reduce the use of cars by increasing proximity and mixed-use development. Furthermore, densification is indirectly affected by other sectoral legislations, which affect urban development and land use in different ways:

- **The Land Act (1995)**, which regulates land use to ensure sustainable management of agricultural and natural resources. Its primary objective is to protect and preserve farmland. The protection of outdoor recreational spaces is a huge topic in the Norwegian Planning. As noted in Hanssen and Hofstad (2013), almost every urban settlement in Norway is characterized by one or more recreational areas, mainly forests called "Marka". These, as in the case of Oslo, usually set the urban growth boundaries.

- **The Nature Diversity Act (2009)**, which protects biological, geological and landscape diversity.

- **The Cultural Heritage Act (1978)**, which protects archeological and architectural monuments and sites and applies for urban areas.

Among these, the legislations concerning the protection of agricultural and recreational areas are considered to be those influencing densification most significantly (Hanssen & Hofstad, 2013).

National climate plans, since the 1990s, have included the following principle as guiding Norway's pathway towards densification:

- Redevelopment of brownfield,

- Development around transportation hub and reduction of car traffic

- Protection of green areas

- Increase housing supply, especially in growing areas

State planning guidelines for land use and mobility assume that the growth in passenger transport in metropolitan areas should be taken by public transport, cycling and walking (Norwegian Government, 2025). The guidelines state that in urban and rural areas and around public transport hubs, special emphasis should be placed on high land use, densification and transformation with quality. At the same time, emphasis should be placed on the cultural environment, site qualities, good outdoor areas, quality of life and access to green structures and natural areas.

Influence of EU Directives

When it comes to the effects of EU regulations, as mentioned, Norway, has been focused on densification well before joining the EU Emission Trading System. However, worth mentioning is that being Norway an EEA member, it is aligned with LULUCF regulations, which are under the "ready for 55" package and focus on achieving a carbon-neutral land use sector by 2035. Norway is required to set and achieve a national net carbon uptake target for its land use sector. Due to an aging forest population, deforestation, and increased logging, Norway's forests have seen declining carbon uptake levels since 2009. To meet the EU-aligned goals,
Norway must focus on limiting deforestation, controlling logging activities, and enhancing reforestation efforts (Farstad, 2022). This might indirectly affect densification, but it should be verified with further research.

<figure><img src="image_78.png" /><figcaption>Figure NO3. Timeline illustrating key policies and regulations in Norway (bottom part) and EU (upper part) affecting densification</figcaption></figure>

## 6.2 The implementation process

### Regulatory tools

As already mentioned, there are various national regulatory tools that affect, more or less directly, the implementation of densification (see previous section). It should be noted that Norwegian municipalities have large autonomy when it comes to land use and thus play a central role for the implementation of densification interventions. At the local level, the most important tool is the municipal masterplan, which sets development objective and regulates land-use. **Municipalities have also significant freedom** when it comes to zoning plans and deciding what to build where. According to the Planning and Building Act, zoning plans might contain provisions on 'the number of dwellings in an area, largest and smallest dwelling size, and further requirements for accessibility and the design of the dwelling where it is appropriate for special needs' (*Plan- og bygningsloven* – pbl 2008, § 12.7). The city council serves as the primary planning authority, responsible for approving or rejecting zoning plans, most of which are submitted by **private developers** (Nordahl, 2014). As Hanssen and Hofstad (2013) observed, the Planning and Building Act Reform of 1985 marked the end of the public planning monopoly by allowing private entities to initiate detailed and area-based zoning plans. These plans are then submitted to the local government for political approval. While this change was
originally intended to enhance democratic participation by involving civil society, it has
increasingly become a tool for market-driven actors, with densification efforts often motivated
by profitability (Cavicchia, 2023b).

6.3 Size and role of the market

Urban planning in Norway has been significantly shaped by neoliberal policies, where private developers play a dominant role despite the public sector's extensive legal authority and oversight. Although municipalities have considerable regulatory tools, it is private developers who effectively implement urban plans (E. Falleth et al., 2011). Developers are responsible for initiating zoning proposals, financing developments, managing land assembly, and driving housing production. Municipalities generally approve income-generating projects on the condition that developers also invest in public infrastructure, such as roads, green spaces, and bike paths (Eika, 2020).

A critical factor in the influential role of private actors is **land ownership**. Since the 1980s, public land ownership in Norway has declined significantly, weakening municipalities' bargaining power in development negotiations. While municipalities can acquire land through pre-emption rights, they must do so at market value.

Land expropriation is permitted by law for 55 specified purposes, including public buildings, infrastructure, housing, and certain commercial projects. Although expropriation rights are available to all levels of government, their use has become rare for local governments, with national transport authorities now being the primary users of this mechanism (OECD, 2017).

This shift in land ownership dynamics, coupled with the reliance on private developers, highlights a market-driven approach to land-use planning in Norway, where the public sector's regulatory oversight is tempered by its reduced control over land resources.

6.4 The multilevel governance process

At the national level, the Planning and Building Act, alongside other sectoral laws like the Land Act and the Nature Diversity Act, provides the legal foundation for sustainable urban development. National climate and transport policies emphasize densification as a means to combat urban sprawl, reduce car dependency, and protect agricultural and green spaces. While these policies establish clear guidelines, municipalities have considerable autonomy in their implementation, reflecting a decentralized approach to land-use governance.

Regions contribute through regional planning instruments such as regional plans and plan strategies, and they facilitate knowledge-building and analytical support to municipalities. This role is particularly important in enabling a shared understanding of housing needs, aligning development goals, and supporting densification strategies where regional infrastructure and mobility planning are involved (Asplan Viak, 2023). Housing, land use, and transport planning (bolig-, areal- og transportplanlegging, BATP) plays a key role in ensuring coordinated regional development, especially in areas facing urban growth and densification pressures. Regions contribute by developing regional plans that integrate housing provision with land use and
transport infrastructure. National planning guidelines emphasize the importance of cross-municipal collaboration to achieve efficient land use, reduced car dependency, and socially sustainable housing development. While BATP provides a strong framework for aligning housing with mobility and spatial planning, its implementation varies, highlighting the need for stronger coordination between regional and local planning levels (Asplan Viak, 2023).

**Local governments, particularly municipalities, are the primary actors responsible for executing densification policies.** Municipal masterplans and zoning regulations serve as the key tools for shaping land use and determining where and how densification occurs. City councils act as political decision-making bodies, approving or rejecting zoning proposals, many of which are submitted by private developers. As mentioned, the significant role of private developers in densification is further reinforced by the decline in public land ownership since the 1980s' governments.

Despite efforts to coordinate national and local priorities, densification policies face a fundamental trade-off between environmental sustainability and housing affordability. Market-driven development is often prioritized, as Norway's neoliberal housing system lacks strong policy mechanisms to promote affordable housing (Cavicchia, 2021b). As a result, while densification increases housing supply and supports sustainability goals, it does not inherently address affordability concerns. The absence of targeted affordable housing initiatives means that densification projects are largely shaped by market forces, often catering to higher-income segments rather than providing inclusive housing solutions.

<table><caption>Table NO6. Table NO 3. Governance structure of densification in Norway</caption><thead><tr><th></th><th>National level</th><th>Regional Level</th><th>Local level</th></tr></thead><tbody><tr><th>Responsible political actors</th><td>Norwegian Government, Ministry of Local Government and regional development define national policies and laws</td><td></td><td>Municipalities develop masterplans, zoning regulations, and negotiate with developers</td></tr><tr><th>Responsible Technical actors</th><td></td><td></td><td>Municipal Planning Departments<br>Private Developers propose zoning plans, finance housing and infrastructure</td></tr><tr><th>Key regulatory tools</th><td>Planning and Building Act, Land Act, Nature Diversity Act, National Climate Strategies</td><td>Regional Land-Use Plans, Environmental and Transport Guidelines</td><td>Municipal Masterplans, Zoning Regulations</td></tr><tr><th>Key policies</th><td>National Climate Plans (since the 1990s)</td><td></td><td>Local climate Plans and Municipal Masterplans</td></tr></tbody></table>
6.5 Achievements, assessments, and challenges

The discourse surrounding urban densification in Norway has primarily been framed within the context of environmental sustainability but is increasingly intertwined with housing provision. Especially in larger Norwegian cities facing significant housing pressure, politicians and developers often argue that densification can help lower housing prices by increasing supply compared to low-density development. However, scholars have identified several challenges that complicate this assumption, highlighting how densification can contribute to housing inequalities. Much of this research has focused on Oslo, where the impacts of densification are particularly pronounced.

One major concern is the effect of densification on housing quality, particularly in terms of dwelling size and access to natural light—an especially critical factor in Nordic countries, where daylight is scarce for much of the year (Schmidt, 2014). In Oslo, this debate has centered around the increasing prevalence of “hyblification”, a term derived from the Norwegian word hybel, meaning small studio apartments typically ranging from 15 to 20 square meters. The proliferation of such micro-units raises concerns about livability, as densification efforts often prioritize maximizing the number of housing units over ensuring adequate living conditions. Furthermore, developers often justify the construction of small apartments as a way to provide more affordable housing, particularly for young people entering the market. However, these units typically have a higher price per square meter than larger ones, ultimately serving as a strategy for developers to maximize profits.

Densification also has significant implications for housing affordability. Norway's housing policies have followed a neoliberal trajectory since the 1980s, with limited public intervention to guarantee affordable housing. Unlike many other European cities that implement inclusionary zoning policies—requiring developers to allocate a share of new units as affordable housing—Norwegian municipalities lack strong regulatory mechanisms to enforce affordability requirements (Cavicchia, 2023b). As a result, densification projects often align with market profitability rather than social equity, contributing to rising housing costs and the exclusion of lower-income groups from newly developed areas.

Moreover, densification is increasingly linked to **gentrification dynamics** (Andersen & Røe, 2017). While traditional gentrification, as seen in cities with lower homeownership rates, may be less evident in Norway due to the high levels of property ownership, research has identified **exclusionary pressures** associated with densification. This refers to the spillover effect where the creation of attractive, high-density residential areas drives up property values in surrounding neighborhoods, making housing less accessible to lower-income populations over time (Cavicchia, 2023c). These dynamics suggest that while densification may contribute to urban sustainability, without targeted policies to address affordability and inclusivity, it risks exacerbating housing inequalities rather than alleviating them.

Finally, another critical trade-off to consider is the impact of densification strategies on the reduction of urban green spaces. In several densification areas across Oslo, this issue has sparked protests against further development.
<table><caption>Table NO7. Potential impacts of densification policies on housing inequalities.</caption>
   <thead>
    <tr>
     <td>
      Potential Impacts
     </td>
     <td>
      Description
     </td>
    </tr>
   </thead>
   <tbody>
    <tr>
     <td>
      Housing Quality and Livability
     </td>
     <td>
      Proliferation of micro-apartments ('hyblification') reduces livability and access to daylight; compromises housing standards.
     </td>
    </tr>
    <tr>
     <td>
      Affordability and Market Pressures
     </td>
     <td>
      Densification aligns with market profitability rather than social equity; limited public tools to ensure affordable housing.
     </td>
    </tr>
    <tr>
     <td>
      Gentrification and Exclusion
     </td>
     <td>
      Spillover effects of high-end developments increase surrounding property values, displacing low-income groups.
     </td>
    </tr>
    <tr>
     <td>
      Regulatory Limitations
     </td>
     <td>
      Lack of inclusionary zoning and affordability mandates in Norwegian planning weakens equity outcomes of densification.
     </td>
    </tr>
    <tr>
     <td>
      Reduction of Urban Green Spaces
     </td>
     <td>
      Densification can lead to loss of green areas, sparking public opposition and reducing environmental quality.
     </td>
    </tr>
   </tbody>
  </table>

7 Summary and discussion of results

7.1 Summary of changes in EEP

Over the past few decades, Norway has progressively integrated environmental and energy objectives into national and urban policies, although the trajectory and maturity of these policies vary significantly across domains. Nature-based solutions (NBS) and densification strategies were institutionalised well before the emergence of EU environmental directives on the matter, whereas energy retrofitting lags behind, both in policy coherence and implementation. This temporal misalignment contributes to uneven integration across levels of governance and complicates the alignment of green transition measures with housing objectives.

National environmental policy is strongly oriented towards sustainability, biodiversity protection, and compact urban development. Densification policies, originating in the 1980s and rooted in national climate strategies, were codified in the Planning and Building Act, enabling local governments to prioritise compact urban form, limit sprawl, and reduce car dependency. Similarly, NBS have gained increasing traction in national and municipal planning frameworks, especially following the 2018 SPR Klima guidelines, which introduced requirements to consider ecosystem-based measures in land-use planning. However, the implementation of these strategies—particularly NBS—remains highly uneven, with stronger uptake in larger municipalities and urban regions that have greater technical and institutional capacity.

In contrast, the development of energy retrofitting policies has been slower and more
fragmented. Norway has no legal obligation for private building retrofits, and national strategies
have largely relied on voluntary incentives rather than mandates. Financial tools, such as
Enova grants and Husbanken loans, are the primary levers used to promote retrofitting; however, they typically cover only a fraction of the total costs and are not income-differentiated. The lack of a clear regulatory mandate or targeted social criteria for retrofitting reflects a policy gap that limits the reach of green transition measures to those who can afford them.

From a governance perspective, territorial disparities emerge as a central challenge across all three policy areas. In NBS and retrofitting, the capacity to plan, fund, and implement projects is highly dependent on local resources and administrative capacity. While national agencies provide technical guidance and some financial support, smaller or rural municipalities often lack the capacity to apply for funding, coordinate across departments, or engage with private actors. In densification, the dominant role of private developers—who initiate most zoning proposals—has led to increasingly market-driven urban development, often at odds with affordability and inclusion goals.

The fragmented distribution of authority and resources across governance levels, combined with the lack of strong horizontal coordination between housing and environmental policies, reinforces these disparities. As a result, the multilevel governance structure remains marked by vertical inconsistencies (between national policy ambitions and local implementation capacity) and horizontal silos (between housing and environmental domains).

## 7.2 Relations and Trade-Offs Between EEPs and Housing Policies

The integration of environmental, energy, and housing policies in Norway remains weak. This is particularly evident in retrofitting, where affordability concerns are largely absent from existing policy tools. Enova and Husbanken schemes are not designed to address social disparities: they provide the same incentives regardless of income, tenure, or vulnerability. This design limits their redistributive potential and risks exacerbating housing inequalities by privileging owner-occupiers with sufficient capital or credit access. Interviewees and Policy Lab participants repeatedly stressed that current schemes are designed more to stimulate market demand for energy technologies than to address affordability gaps or social needs.

In the rental sector, this results in stark vulnerabilities. Tenants have no access to retrofitting subsidies and are reliant on landlords to initiate energy upgrades. Yet landlords, particularly in profit-driven private rental markets, face little incentive to invest in costly renovations they cannot directly capitalise on through energy savings. Moreover, the absence of rent regulation potentially allows any improvement to be passed on to tenants in the form of higher rents, further compounding the problem.

In the cooperative housing sector, affordability is equally precarious. Retrofitting initiatives must be agreed collectively and are often financed through joint debt. This can generate internal tensions and risks of financial overburdening, particularly for residents with lower incomes or higher vulnerability. In practice, decisions to proceed with retrofitting are shaped as much by social negotiation and internal politics as by technical considerations.

NBS present another set of trade-offs. While they contribute positively to climate resilience, they can also generate indirect socio-spatial effects. In some areas, the introduction of green amenities—urban parks, green roofs, restored waterways—can increase property values,
triggering gentrification dynamics and putting pressure on low-income residents. In Oslo and other high-demand cities, the prioritisation of green infrastructure in urban planning has sometimes led to increased housing costs, especially when land reserved for NBS reduces the space available for affordable housing. Moreover, local governments often lack the tools to manage these trade-offs effectively, given the absence of integrated planning frameworks that align environmental goals with housing needs.

Densification is the most institutionalised and mature among the three domains, but its implementation is also marked by strong market orientation and weak affordability safeguards. In fact, in many cities, densification has coincided with a proliferation of small, high-priced units and has been linked to exclusionary pressures. Without robust inclusionary zoning mechanisms or affordability requirements, the housing outcomes of densification remain shaped by market logics rather than social objectives.

In sum, the three environmental and energy policy domains analysed in this report—retrofitting, NBS, and densification—present different levels of maturity, institutionalisation, and alignment with housing goals. Densification is the most embedded in national policy, with a long-standing legal and planning framework, but also the most captured by private interests. NBS are increasingly present in national guidance and legal instruments but uneven in implementation due to local capacity gaps. Retrofitting is the least developed, with fragmented governance, limited affordability considerations, and contested political support, particularly in the current context of political instability and uncertainty around the implementation of EU directives.

Across all three areas, a common challenge lies in the lack of integrated policy design that considers the intersection between environmental transitions and housing inequalities.
8 References

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# 9 Annex

## Annex 1

<table><thead><tr><th colspan="3">EUROPEAN LEVEL</th></tr></thead><tbody><tr><td>2002</td><td>Energy Performance of Buildings Directive (EPBD)<br><a href="https://eur-lex.europa.eu/eli/dir/2002/91/oj/eNg">https://eur-lex.europa.eu/eli/dir/2002/91/oj/eNg</a></td><td>The 2002 EPBD did not impose common, precise numerical targets.<br><br>It required each Member State to develop a national methodology for calculating the energy performance of buildings.<br><br>It required members states to set national minimum requirements on the energy performance of new buildings and only existing buildings with a total useful floor area over 1000 m² that are undergo major renovation<fnref n="146" />.<br><br>Member States may decide not to set or apply the requirements for the residential buildings (new and existing) which are intended to be used less than four months of the year.</td></tr><tr><td>2010</td><td>EPBD revision<br><a href="https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32010L0031">https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32010L0031</a></td><td>The 2010 EPBD did not impose common, precise numerical targets but it included some changes with respect to the 2002 version.<br><br>It established mandatory national minimum requirements on the energy performance of new buildings and only existing buildings that are undergo major renovation, regardless of their surface area. Mandatory national minimum requirements have to be updated every five years and are set with a view to achieving cost-optimal levels<br><br>Member States shall ensure that: by 31 December 2020, all new buildings are nearly zero-energy buildings; and after 31 December 2018, new buildings occupied and owned by public authorities are nearly zero-energy buildings<br><br>Member States may decide not to set or apply the requirements for "residential buildings which are used or intended to be used for either less than four months of the year or, alternatively, for a limited annual time of use and with an expected energy consumption of less than 25 % of what would be the result of all-year use".</td></tr><tr><td>2012</td><td>Energy Efficiency Directive (EED)</td><td>The 2012 EED set out a number of energy efficiency targets, referring not only to the residential or building sector but more broadly to all sectors.</td></tr></tbody></table>

<footnote n="146">¹⁴⁶ According to the Directive: "Major renovations are cases such as those where the total cost of the renovation related to the building shell and/or energy installations such as heating, hot water supply, air-conditioning, ventilation and lighting is higher than 25 % of the value of the building, excluding the value of the land upon which the building is situated, or those where more than 25 % of the building shell undergoes renovation"</footnote>
<table>
   <tr>
    <td></td>
    <td>https://eur-lex.europa.eu/eli/dir/2012/27/oj/eng</td>
    <td>The EU aimed to reduce energy consumption by 20% by 2020. Each Member State was required to set indicative national energy efficiency targets.<br/>Member States also had to renovate each year at least 3% of the total floor area of centrally owned public buildings.</td>
   </tr>
   <tr>
    <td>2018</td>
    <td>EPBD revision<br/>https://eur-lex.europa.eu/eli/dir/2018/844/oj/eng</td>
    <td>Each Member State shall establish a long-term renovation strategy to support the renovation of the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonised building stock by 2050, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings, in particular by an increase in deep renovations.<br/>The long-term renovation strategy shall include indicative milestones for 2030, 2040 and 2050, and specify how they contribute to achieving the Union's energy efficiency targets in accordance with Directive 2012/27/EU.</td>
   </tr>
   <tr>
    <td>2023</td>
    <td>EED revision<br/>https://eur-lex.europa.eu/eli/dir/2023/1791/oj/eng</td>
    <td>2023 EED defines higher targets for energy efficiency and introduces the "Energy-efficient first principle" as a key element, meaning that energy efficiency must be prioritised by member states across all policy and investment decisions<br/>Public bodies at national, regional and local level should fulfil an exemplary role as regards energy efficiency. Each Member State shall ensure that at least 3 % of the total floor area of heated and/or cooled buildings that are owned by public bodies is renovated each year to be transformed into at least nearly zero-energy buildings or zero-emission buildings<br/>Member States shall establish and achieve a share of the required amount of cumulative end-use energy savings among people affected by energy poverty, vulnerable customers, people in low-income households and, where applicable, people living in social housing</td>
   </tr>
   <tr>
    <td>2024</td>
    <td>EPBD revision<br/>https://eur-lex.europa.eu/eli/dir/2024/1275/oj/eng</td>
    <td>2024 EPBD objective is the reduction of greenhouse gas emissions from buildings within the Union, with a view to achieving a zero-emission building stock by 2050<br/>Member States shall establish a national building renovation plans that also includes a roadmap with targets and indicators, including the reduction of the number of people affected by energy poverty.<br/>Member states must implement measures to reduce average primary energy consumption of the national residential building stock by at least 16% compared to 2020</td>
   </tr>
  </table>
<table>
   <tr>
    <td>
    </td>
    <td>
     by 2030; and by at least 20-22% compared to 2020 by 2035.
     <br/>
     Member States shall ensure that at least 55 % of the decrease in the average primary energy use referred to in the third subparagraph is achieved through the renovation of the 43 % worst-performing residential buildings
    </td>
   </tr>
  </table>
# NATIONAL REPORT ON THE REGULATORY SYSTEM OF EEPs IN POLAND

## 1 Executive Summary

The main objective of this report is to provide a national assessment of the regulatory systems of Energy and Environmental Policies (EEPs) in Poland. The report specifically addresses housing retrofitting, nature-based solutions, and densification policies, all considered within the broader framework of national climate change mitigation and adaptation strategies. It explores the three core themes of the ReHousIn project: retrofitting residential buildings, implementing nature-based solutions (NBS) in urban areas, and promoting densification in and around urban centers. Each theme is addressed in a dedicated chapter, further divided into subchapters that examine the policy cycle, implementation processes, market dynamics, and multi-level governance.

The report highlights the significant progress and ongoing challenges in improving energy efficiency and living standards in the country's residential sector. The retrofitting initiatives, largely driven by EU funding and national programs such as Clean Air and Thermomodernization, have led to measurable reductions in energy consumption and substantial decreases in CO2 emissions. Many buildings have undergone various degrees of modernization since 2018, including window replacement, insulation upgrades, and heating system improvements. Despite these successes, the report identifies persistent barriers, including limited outreach in rural areas, financing gaps for low-income households, and fragmented implementation. Strengthening coordination, simplifying procedures, and promoting integrated solutions are key recommendations to accelerate progress toward national and EU climate goals.

The report outlines the growing adoption of sustainable, ecosystem-driven approaches to urban and environmental challenges, with a focus on enhancing climate resilience, biodiversity, and quality of life. Key initiatives include the revitalization of urban green spaces, the restoration of riverbanks and wetlands, and the implementation of green roofs and rain gardens in cities. However, gaps remain in long-term financing, policy integration, and monitoring. Strategic scaling and mainstreaming of NBS into urban planning and climate adaptation strategies are recommended for maximizing impact.

In context of development densification in Poland the report examines national and local efforts to promote more compact urban growth as a response to urban sprawl and inefficient land use. Densification policies aim to improve the use of existing infrastructure, reduce environmental impact, and support more sustainable city development.
## 2 Introduction and methodology

This report attempts to understand how energy and environmental policies implemented in Poland affect housing inequalities. The starting point was an analysis of existing regulations and strategies, conducted from a multi-level governance perspective, considering actions at national, regional and local levels. As a Member State of the European Union (EU), Poland is committed to implementing common climate goals. Although the framework of these commitments is defined at the EU level, specific instruments and actions are taken by national and local governments, with local authorities playing a key role in implementing the strategy on the ground. There is a common consensus on the direction of energy transformation in Poland, but specific solutions are often met with resistance, which is reflected in numerous public discourses and disputes around individual actions.

The report focuses on three areas that are particularly important from the point of view of climate policy: housing retrofitting, implementation of nature-based solutions and densification of development, and which can support both adaptation and mitigation actions. Poland faces the challenge of massively improving the energy efficiency of buildings, especially in the residential sector. The current regulations and programs, such as "Clean Air", "My Electricity" or "Thermal Modernization Relief", create a framework for support for property owners, but their availability is uneven across different social groups. The problem remains the lack of real possibilities for their implementation by local governments and households, and the related limited availability of financing, especially for municipal and social resources.

In recent years, there has been growing interest in the use of nature-based solutions in cities, especially in the context of adaptation to climate change (e.g. stormwater management or counteracting heat islands). Despite this, NBS are still treated as optional measures, not standard elements of public investments. There is a lack of both a systemic approach in national policies and tools supporting long-term maintenance of green infrastructure at the local level.

Although spatial policies promote the idea of "compact cities", in practice, densification often takes place haphazardly and without appropriate infrastructure support. Legal conditions (e.g. lack of effective planning tools or too fragmented ownership structure) make it difficult for municipalities to act effectively in this area. At the same time, development pressure means that densification, instead of improving the quality of life, may lead to social conflicts and deepening territorial inequalities.

The report is based on the analysis of secondary data, including information, thematic studies, statistical data and evaluation reports available prepared by relevant public institutions, such as the Ministry of Development and Technology, the Ministry of Climate and Environment, the Central Statistical Office, and the National Fund for Environmental Protection and Water Management.

Poland's Energy and Environmental Policies have evolved through EU directives, national plans (National Environmental Policy 2030, NEP2030, Energy Policy of Poland until 2040, EPP2040), and subsidy programs like 'Clean Air', 'My Electricity', and 'Stop Smog'. EEPs are partially aligned with housing policy, but integration is weak. Retrofitting efforts support energy-
poor households, but affordability and access issues remain, especially for large-scale or multi-unit retrofits. Programs target individual owners more than rental or social housing.

The review also used information on the applicable legal framework for energy transformation and environmental protection and spatial policy, both at the national and lower levels. Analyses of the mechanisms for implementing public policies were also included with an emphasis on the role of local governments, which in Poland bear a large responsibility for the implementation of many activities. The degree and manner of implementing policies differs significantly depending on local conditions, such as the financial situation of local governments, the availability of technical and human resources, local political priorities and the level of involvement of residents.

The study also considers available scientific literature focusing on the relationships between environmental and energy policies and housing inequalities. However, there are still relatively few studies of this type in Poland. The most attention is paid to the impact of thermal modernisation and revitalisation processes on the availability of housing stock, while issues related to the densification of development, or the implementation of nature-based solutions are less frequently analysed. Studies linking NBS with the issue of housing inclusiveness are exceptional and in most cases are limited to projects implemented under European grants.

While the study provides valuable insights into the regulatory systems of Energy and Environmental Policies in Poland, several methodological limitations should be acknowledged. First, the report is primarily based on desk research, relying on publicly accessible datasets, national legislation, and strategic documents. As such, the analysis is constrained by the availability, timeliness, and completeness of publicly available information. Important aspects of policy implementation, enforcement, or informal governance practices may not be fully captured in official documents. It is further informed by scientific assessments as well as the authors' own research and consultancy experience within the Polish context. Moreover, the research was complemented by the focus group Policy Lab #1, as well as free-form interviews with experts and policymakers.

Policy Lab #1 also made a valuable contribution to the report. They were conducted in two meetings - one in Łódź and one in Warsaw, to accommodate the geographical spread of the case studies and maximize stakeholder participation. The format combined plenary presentations with breakout group work. Each meeting began with an introduction to the ReHousIn project, covering its objectives, partners, and preliminary findings. Participants were then divided into mixed stakeholder groups (4-6 people) for three discussion rounds focused on key challenges related to retrofitting, urban densification, and NBS. Each round was introduced with a short presentation on the topic, followed by group work and a final plenary discussion where teams shared insights and engaged in collective reflection.

For the Polish case, a series of free-form interviews were conducted with key stakeholders from local government to explore the complex relationship between housing and environmental policies (Table PL1). These open-ended conversations, each lasting between 15 minutes to 1 hour, allowed for a flexible discussion of governance practices, inter-sectoral collaboration, and the use of policy tools and funding schemes.
<table><caption>Table PL1. List of conducted interviews</caption><thead><tr><td>Interview</td><td>Key informant/Institution</td><td>Focus</td></tr></thead><tbody><tr><td>Interview 1</td><td>Nine representatives from the municipality of Pabianice</td><td>Energy retrofitting, nature-based solutions, densification and housing policy</td></tr><tr><td>Interview 2</td><td>One representative from the municipality of Radomsko</td><td>Energy retrofitting, nature-based solutions, densification</td></tr><tr><td>Interview 3</td><td>Four representatives from the municipality of Warsaw</td><td>Energy retrofitting, nature-based solutions, densification and housing policy</td></tr></tbody></table>

Source: own elaboration.

The qualitative data collected through free-form interviews with experts and policymakers and focus group provide valuable context and stakeholder perspectives. However, these engagements were limited in number and scope, meaning that the findings may not fully reflect the diversity of opinions or experiences across all governance levels and regions in Poland. These limitations highlight the need for further empirical research, stakeholder engagement, and longitudinal studies to complement this assessment and support evidence-based policy development in Poland's energy and environmental governance landscape.

The report opens with an executive summary. Chapter 2 outlines the methodological framework, based on desk research using publicly available data, national legislation, and strategic documents, complemented by scientific assessments and the authors' own research and consultancy experience in Poland. Chapter 3 describes the general governance system, offering an overview of the institutional setup, key actors, and regulatory mechanisms that shape environmental and energy-related policymaking. Chapters 4 to 6 explore three core policy domains in detail:

- Chapter 4 focuses on housing retrofitting, assessing the policy cycle, implementation mechanisms, market dynamics, governance arrangements, and the outcomes achieved,

- Chapter 5 addresses NBS projects, examining how these initiatives emerge, are governed, and implemented across various administrative levels,

- Chapter 6 investigates densification projects, analyzing urban planning responses aimed at increasing spatial efficiency and the associated governance and market frameworks.

Each of these chapters is structured into 5 recurring sub-sections: (1) the emergence of the issue and policy decisions; (2) implementation processes; (3) the size and role of the market; (4) multilevel governance processes; and (5) achievements, evaluations, and challenges.

Finally, Chapter 7 provides a synthesis of findings, including a summary of changes in the EEP landscape and an analysis of the interactions, synergies, and trade-offs between EEPs and housing policies in Poland.
3 General governance system

Poland (Polska) is a democratic republic with a parliamentary system of government, which means that power is exercised by representatives elected by the citizens, and the parliament plays a key role in the governance process. This system is based on the principle of the separation of powers, which involves the division and mutual balancing of the three main branches of government: the executive, the legislative, and the judiciary.

When analysing the general governance system in Poland from a spatial perspective, it is essential to consider the profound political and socio-economic changes that began in 1989. This period marked a major shift from a centrally planned economy to a market-oriented one, significantly influencing the approach to spatial and land development (Bański, 2007). The post-1989 transformation was characterized by several critical developments: the decentralization of political authority and the revival of local self-governance; the privatization and decentralization of the economy; the alignment of spatial planning legislation with European Union standards; and, following EU accession, access to structural and agricultural funding (Węclawowicz et al., 2006).

A key milestone in this transformation was the administrative reform implemented on January 1, 1999, which replaced 49 smaller provinces with 16 larger voivodeships, further subdivided into counties (powiat) and municipalities (gmina). This reform aimed to establish a clearer allocation of responsibilities between central and local government, reserving national-level administration for matters of overarching state policy (Wendt, 2007).

During the 1990s, Poland also began receiving significant foreign investment and development aid, with a notable focus on regional development. The importance of these resources increased substantially after joining the European Union in 2004. Over the past decade, the country has experienced marked demographic concentration in major urban centres, improvements in technical infrastructure, and a relative decline in the industrial sector's prominence within the national economy. These trends have been accompanied by the adoption of numerous strategic documents shaping spatial development and regional policy at the national level (Bański, 2007; Borowska-Stefańska et al., 2018).

As of January 1, 2025, the administrative division of Poland comprised: 16 voivodeships (provinces), 314 counties (powiats) and 66 cities with county rights, and 2,479 municipalities, including 302 urban, 718 urban-rural, and 1,459 rural municipalities<fnref n="147" />.

The foundations of Poland's political and legal system are defined by the *Constitution of the Republic of Poland* (1997), which is the highest legal act in the country. The Constitution not only guarantees democratic principles of governance but also ensures civil rights and freedoms, the independence of the judiciary, and mechanisms of checks and balances between the various organs of the state. It outlines, among other things, the procedures for appointing top state officials, their competencies, and the relationships between state institutions, thereby ensuring transparency and stability in the political system.

<footnote n="147">¹⁴⁷ https://stat.gov.pl/statystyka-regionalna/jednostki-terytorialne/podzial-administracyjny-polski/ [Last accessed on 31.05.2025]</footnote>
In practice, this means that no single branch of power can dominate the others. The executive branch (the President of the Republic and the Council of Ministers) is responsible for directing the state and implementing internal and foreign policy. The legislative branch (the Parliament, composed of the Sejm and the Senate) creates laws, adopts the budget, and supervises the activities of the government. Meanwhile, the judiciary (courts and tribunals) safeguard the law and the constitutionality of state actions, ensuring the protection of citizens' rights (Grabowski, 2021). This system of government is designed to maintain a balance of power and protect against its abuse, which forms the foundation of the rule of law and a civil society.

The multi-level governance framework in Poland is based on a decentralized system of public administration, which ensures that powers and responsibilities are shared between the national, regional (voivodeship), county, and local/municipal levels. This system was reformed significantly in 1999 and reflects the principles of subsidiarity, decentralization, and partnership (Stec et al., 2018).

In Poland, the competences for ecological transitions, particularly in housing retrofitting, urban densification, and nature-based solutions (NBSs), as well as broader housing policies, are distributed across four main levels of governance: national, regional (voivodeship), county (powiat), and local/municipal (gmina). Each level plays a distinct role, shaped by its legal competences, administrative capacity, and proximity to local needs (Table PL2).

<table><thead><tr><td>Level</td><td>Housing</td><td>Housing retrofitting</td><td>NBS</td><td>Densification</td></tr></thead><tbody><tr><td rowspan="4">National level</td><td>Formulating national housing policy and strategy, including housing support programs</td><td>Develops national programs and strategies for energy efficiency, climate action, and housing quality</td><td>Formulates national environmental including climate adaptation and biodiversity strategies</td><td>Develops national spatial planning policies that encourage sustainable urban development and densification.</td></tr><tr><td>Coordinating state-funded programs for social housing, rent subsidies, and energy efficiency in buildings</td><td>Sets national regulations and standards for building energy performance and retrofitting practices</td><td>Implements EU directives related to environment and nature protection</td><td>Implements national strategies related to urbanization, housing, and infrastructure development</td></tr><tr><td>Allocating EU funds and national grants to regional and local governments for housing projects</td><td>Allocates national budget funds and coordinates EU funding (e.g., from the Cohesion Fund, Recovery and Resilience Facility)</td><td>Establishes legal frameworks promoting ecosystem restoration, green infrastructure, and sustainable land use</td><td>Supports national programs for urban renewal and brownfield redevelopment</td></tr><tr><td>Supervising state-owned housing institutions</td><td>Oversees grant and loan programs for individuals, housing cooperatives, and local governments</td><td></td><td>Allocates funding for infrastructure projects supporting densification (e.g., transport, utilities)</td></tr></tbody></table>
<table><thead><tr><th>Level</th><th>Housing</th><th>Housing retrofitting</th><th>NBS</th><th>Densification</th></tr></thead><tbody><tr><td>Regional level (województwo)</td><td>Planning and coordinating regional housing development strategies, often linked to regional development and spatial planning<br>Managing EU structural funds for housing renovation, energy efficiency, and social inclusion projects (especially in urban regeneration)<br>Supporting and coordinating projects involving multiple counties or municipalities<br>Conducting spatial analysis and regional forecasts to guide housing policy decisions</td><td>Allocates and manages regional Operational Programs, including ERDF funds for energy-efficient renovation of buildings<br>Supports municipal projects and housing cooperatives applying for funding<br>Incorporates retrofitting into regional development strategies and low-emission economy plans<br>Coordinates regional-scale initiatives in collaboration with multiple municipalities</td><td>Integrates NBS into regional development strategies and environmental protection plans<br>Coordinates ecosystem restoration, green infrastructure, and sustainable agriculture at the regional scale<br>Oversees the implementation of protected areas (like Natura 2000) and compliance with environmental standards</td><td>Develops and implements regional spatial development plans that identify areas for urban densification<br>Coordinates between counties and municipalities to ensure coherent regional development patterns</td></tr><tr><td>County level (powiat)</td><td>Limited direct role<br>Managing housing support through social welfare institutions, including temporary accommodation or assisted housing</td><td>Limited direct role<br>May retrofit housing units in social care or educational institutions</td><td>Limited direct role<br>Provides technical support for environmental initiatives in schools, social institutions, and local infrastructure</td><td>Limited direct role<br>Supports municipalities in managing secondary roads and services linked to densification</td></tr><tr><td>Local/municipal level (gmina)</td><td>Primary responsibility for housing provision and management<br>Managing municipal housing stock<br>Allocating social housing and setting rent levels based on income criteria</td><td>Retrofitting and energy modernization of municipal housing stock<br>Applying for national or regional funding to finance projects<br>Developing local energy plans, low-emission development programs, and spatial policies that prioritize</td><td>Establishes and maintains urban green spaces, parks, community gardens, and natural flood defenses<br>Implements local flood prevention and water management solutions based on</td><td>Develops local spatial development plans or issues zoning decisions that regulate building density, land use, and redevelopment<br>Grants building permits and controls compliance with urban planning rules<br>Promotes infill development,</td></tr></tbody></table>
<table><caption>Table PL2. Multilevel governance in housing, retrofitting, NBS and densification in Poland</caption><thead><tr><td>Level</td><td>Housing</td><td>Housing retrofitting</td><td>NBS</td><td>Densification</td></tr></thead><tbody><tr><td></td><td>Maintaining and renovating public housing units<br/>Creating local spatial development plans that determine where residential buildings can be constructed<br/>Cooperating with NGOs and private developers for affordable housing projects<br/>Managing housing subsidies and allowances for low-income residents</td><td>sustainable retrofitting<br/>Informing and assisting residents and housing cooperatives in accessing grants or loans (e.g., Stop Smog program)</td><td>natural ecosystems<br/>Manages local biodiversity, supports pollinator habitats, and tree planting initiatives<br/>Incorporates green infrastructure and NBS into local land-use plans and building regulations</td><td>brownfield redevelopment, and multi-family housing projects<br/>Ensures adequate local infrastructure (water, sewage, roads, public transport) to support higher densities.<br/>Engages in community consultation</td></tr></tbody></table>

Source: own elaboration.

The national level is responsible for setting the overall legal and policy frameworks, including building codes, energy efficiency standards, and strategic programs (e.g., “Clean Air” or the National Housing Program). It allocates national and EU funds, oversees implementation through state agencies, and ensures compliance with EU directives on climate and biodiversity.

The regional level adapts national policies to regional conditions by incorporating housing and ecological goals into development strategies, managing EU Operational Programs (e.g., for retrofitting or environmental protection), and coordinating projects involving multiple municipalities. Regions also play a role in spatial planning and environmental monitoring.

The county level in Poland has limited but supportive functions. It often acts through social welfare institutions and may engage in small-scale retrofitting or infrastructure maintenance. Counties can also assist in coordinating efforts among municipalities, especially in areas like public transport or secondary infrastructure relevant to densification.

The local/municipal level has the most direct implementation role. Municipalities manage public housing, develop local spatial plans, issue building permits, and lead on-the-ground retrofitting projects. They also maintain urban green spaces, apply NBSs in flood management or biodiversity support, and ensure infrastructure is in place to accommodate higher urban density. Their proximity to residents allows them to tailor solutions to local needs and engage communities in planning and decision-making processes.
One of the key challenges in Poland's governance framework for ecological transition and housing policy is the fragmentation of institutional responsibilities. Various ministries and agencies are involved in related area, such as the Ministry of Climate and Environment, the Ministry of Development and Technology, and the Ministry of Infrastructure, often with overlapping or poorly delineated mandates. The absence of a strong, central coordinating authority or an integrated governance mechanism for ecological transition results in limited policy coherence across sectors. This fragmentation complicates efforts to design and implement cross-cutting initiatives such as housing retrofitting or NBS, which require collaboration across environmental, energy, and housing domains.

A significant governance challenge in Poland is the weak horizontal integration between sectors and policy areas, particularly at the national and local levels. Policies related to housing, energy efficiency, climate adaptation, urban planning, and environmental protection are often developed and implemented with limited coordination among responsible departments and agencies. As a result, initiatives such as densification or housing retrofitting are frequently planned without full consideration of ecological goals, NBS may be treated as stand-alone environmental projects rather than being integrated into broader urban development strategies.

4 Housing retrofitting

4.1 The policy cycle: emergence of the issue and policy decisions

Housing retrofitting in Poland has gained increasing importance due to the country's energy
dependency, poor air quality, and aging housing stock, much of which is energy-inefficient.
Poland has been a signatory to the *United Nations Framework Convention on Climate Change*
(UNFCCC) since 1994 and the *Kyoto Protocol (KP)* since 2002, thereby participating in efforts
undertaken by the international community to mitigate climate change. In the first commitment
period following Polish ratification of the KP, Poland committed to reducing greenhouse gas
emissions by 6% between 2008 and 2012 compared to the baseline year (1988). Poland
achieved this reduction target with a significant surplus (Bebkiewicz et al., 2023). In 2016,
Poland ratified the so-called Paris Agreement. This agreement is the next stage in international
climate policy, following the KP, and engages all parties to the UNFCCC in actions aimed at
protecting the climate. Air protection in Poland improved significantly after the fall of
communism in 1989/1990 due to economic reforms and heavy industry closures but
disappeared from public focus for over a decade. It reemerged around 2008 as a household
emissions issue from solid-fuel heating, sparking public debate and responses from various
actors (Matczak et al., 2023).

Over time, several national policies in Poland directly or indirectly impact housing retrofitting (Figure PL1). These policies aim to address energy efficiency, air quality, and greenhouse gas emissions while supporting the social and economic needs of households. The most important regulations within the EU's climate policy are the new EU regulations from the 'Fit for 55' package and the EU energy transformation plan 'REPowerEU'.
<figure><img src="image_79.png" /><figcaption>Figure PL18. Timeline with milestones for introducing housing retrofitting in Poland</figcaption></figure>

Source: own elaboration.

In the case of Poland, the initial impetus for action to improve energy efficiency and air quality came largely from the European Union. It was EU directives, such as the Energy Performance of Buildings Directive (EPBD – first version in 2002 and updates in 2010 and 2018) and the 2020 and 2030 climate and energy packages, that established the legal and directional framework for the modernization of building stocks. Poland transposed these regulations gradually and often with delay, which translated into delayed implementation of national measures. The EU therefore played not only the role of initiator, but also of active corrector – through monitoring mechanisms, fund conditionality and proceedings before the Court of Justice of the EU. As a result, it is the European Union that remains the key driver for national modernization policy, both through regulatory pressure and financial support.

The **Act on the Energy Performance of Buildings** (2014) is Poland's key legal instrument implementing EU directives on building energy efficiency. It establishes national standards for calculating energy performance, defines requirements for nearly zero-energy buildings, and mandates energy performance certificates (EPCs) for new, sold, or rented buildings. The Act also introduces a central register of EPCs and inspections and regulates the control of heating and cooling systems. It supports both compliance with EU law and national climate goals by enabling oversight, improving building performance, and linking retrofitting projects to funding schemes.

Until 2014, Polish cities underwent intensive renovations and modernization. Their appearance improved, and the quality of life was enhanced. Since 2004, infrastructural changes began to be referred to as revitalizations. This shift in terminology resulted from changing conditions - EU funds were allocated for revitalization, so local authorities started using this term for their renovation efforts. The Polish government closely monitored local governments' activities and
achievements in the field of revitalization. Evaluating successes and failures led to the
development of a series of solutions aimed at improving the process. A key tool in this effort
was the adoption of the revitalization law. In 2015, the **Act on Revitalization** was introduced,
establishing a legal framework to regulate the entire process. For the first time in Polish law, it
defined revitalization as an initiative aimed at restoring degraded urban areas from crisis
conditions. These areas are identified by severe socio-economic challenges, including high
unemployment, poverty, and low entrepreneurial activity. The concentration of these issues
within specific territories leads to social segregation, stigmatization, and the perpetuation of
poverty across generations (Hughes et al., 2024; Popławska, 2019).

In Poland, revitalization applies to municipal areas facing crises due to social, economic, and environmental issues. The policy focuses on comprehensive interventions through integrated projects addressing local challenges holistically. Actions are concentrated in specific areas, ensuring complementarity in spatial and problem-solving terms while aligning with strategic programs. Additionally, revitalization efforts are co-financed through EU funds to enhance their effectiveness (Ciesiółka, 2018; Hajduga & Mempel-Śnieżyk, 2023; Kucharska & Piwowarczyk, 2023). Although retrofitting is not the primary objective of the Act on Revitalization, it may be supported indirectly, if it contributes to the implementation of revitalization objectives, especially by improving the quality of life and functionality of buildings in the areas covered by the activities. The period 2015–2019 was crucial for the implementation of the Act, which was the phase of its most intensive application, and the implementation of activities was often linked to the use of EU funds from the 2014–2020 financial perspective. EU cohesion policy funds were the main source of support for investments in urban renewal, including building modernization, especially when it was in line with social objectives, such as combating energy poverty or improving housing conditions.

An interesting example of revitalization efforts is Łódź. The degraded area undergoing revitalization is highly diverse in terms of spatial organization, consisting of residential, industrial, and storage areas, as well as parks and urban green spaces. Additionally, it includes a zone with architectural monuments and 19th-century urban heritage, such as the original land plots and morphogenetic units corresponding to early craft settlements established during the city's initial industrial development. Revitalization efforts in Łódź are carried out by both the public sector (municipal authorities and their designated agencies) and private capital (Kaczmarek, 2024).

In 2015, the **National Air Protection Program until 2020** was adopted. The program recommended the development and dissemination of technologies to improve air quality and increasing the energy efficiency of residential and public buildings through deep thermal modernization. The document aims to coordinate actions within the national air quality policy framework, linking it to sectors such as housing and municipal services, clean energy, heating, renewable energy sources, and transportation. In December 2021, an updated version of the **National Air Protection Program until 2025 (with a perspective extending to 2030 and 2040)** was published. This updated document continues to align air quality policies with key areas, including the residential and municipal sectors, clean energy, heating, renewable energy sources, and transportation.
In 2016, Poland adopted the **Act on Energy Efficiency**. The Act introduced regulatory changes beneficial to both economic development and citizens. Its purpose is to allow anyone who meets specific requirements - such as conducting an energy efficiency audit for a particular investment - to receive benefits in the form of property rights derived from energy efficiency certificates, commonly known as white certificates.

In 2019, the Ministry of Environment published the **National Environmental Policy 2030** (NEP2030) strategy. The strategic goals of NEP2030 include eliminating sources of air pollution or significantly reducing their impact, managing geological resources through the development and implementation of a national raw materials policy, supporting eco-innovation, adapting to climate change, and managing disaster risks. NEP2030 serves as the foundation for investing European funds from the 2021-2027 financial perspective. The strategy also supports Poland's national and international commitments, including those at the EU and UN levels, particularly in the context of the EU's climate and energy policy goals for 2030 and the sustainable development goals outlined in the 2030 Agenda.

In 2019, Poland adopted the **National Energy and Climate Plan for 2021–2030**. The plan outlines measures to adapt to climate change by promoting sustainable management of environmental resources and ensuring the economy and society function effectively under evolving climate conditions, as detailed in the *National Environmental Policy 2030*. It also defines key assumptions, objectives, policies, and actions in areas such as energy security, the internal energy market, energy efficiency, decarbonization, and research, innovation, and competitiveness. However, since 2020, the plan's implementation has faced significant disruptions due to unforeseen crises.

In 2021, Poland adopted the **Energy Policy of Poland until 2040** (EPP2040). The policy aims to ensure energy security while maintaining economic competitiveness, improving energy efficiency, and minimizing the environmental impact of the energy sector, all while optimizing the use of domestic energy resources. Key strategic directions for implementation in Poland include the optimal use of domestic energy resources, expansion of electricity generation and grid infrastructure, diversification of supply sources and expansion of network infrastructure for natural gas, crude oil, and liquid fuels, development of energy markets, implementation of nuclear energy, growth of renewable energy sources, advancement of heating and cogeneration, and improvement of the economy's overall energy efficiency.

The **Energy Policy of Poland until 2040** and the **National Energy and Climate Plan 2021-2030** determine the timeline for Poland's transition away from coal mining and its use in conventional energy production by 2049, as established by the signatories of the social agreement regarding the transformation of the hard coal mining sector. In 2022, **The National Recovery and Resilience Plan** was adopted. Due to the climate considerations, the expected outcomes of the interventions outlined in a plan include: an increase in the share of energy from renewable sources in total gross energy consumption, a reduction in exposure to air pollution from particulate matter (PM2.5 and PM10).
## 4.2 The implementation process

In Poland, several tools have been developed to support housing retrofitting, aimed at improving energy efficiency and reducing environmental impact. These tools include financial incentives and technical guidelines that facilitate the modernization of residential buildings while promoting sustainability and compliance with EU standards (Table PL3).

<table><thead><tr><th>Tool</th><th>Structures of Implementation</th><th>Time Horizon</th></tr></thead><tbody><tr><td>'Clean Program'<br/>[Program 'Czyste Powietrze']</td><td>Poland's first subsidy program aims to replace old furnaces and insulate single-family homes to improve air quality and reduce greenhouse gas emissions. The program co-finances projects covering tasks like replacing heating sources, insulating buildings, upgrading windows and doors, and installing renewable energy systems. The building must already exist, not be under construction, to qualify for the subsidy.<br/>Eligibility criteria: homeowners or co-owners of existing single-family houses; the building must not be under construction<br/>Targeting: strong income differentiation: three subsidy levels based on income brackets; not available to renters or multi-family buildings<sup>148</sup>.</td><td>2018-2029</td></tr><tr><td>Thermal Modernization Relief</td><td>The thermal modernization relief is a financial support program that encourages single-family homeowners to improve energy efficiency. Taxpayers can deduct the costs of thermal modernization projects from their tax base, with the relief available.<br/>Eligibility criteria: owners/co-owners of existing single-family homes; capped at PLN 53,000 (12 550 EUR) per taxpayer.<br/>Targeting: no direct income targeting (available to all taxpayers), but those with higher tax base benefit more; only applicable to owner-occupied housing (not rentals); no support for tenants or social housing<sup>149</sup>.</td><td>From 2019</td></tr><tr><td>'My Electricity' Program<br/>[Program 'Mój prąd']</td><td>Program supports prosumer energy development by providing subsidies for photovoltaic installations and energy efficiency devices. It targets owners of single-family homes planning to install photovoltaic systems. Since 2022, the program has also subsidized energy storage, heat storage, and energy management systems (HEMS/EMS).<br/>Eligibility criteria: residential building owners who register as prosumers.<br/>Targeting: no income differentiation; owner-occupiers only; excludes tenants and social housing<sup>150</sup>.</td><td>From 2019</td></tr><tr><td>'Warm Apartment' Program<br/>[Program 'Ciepłe mieszkanie']</td><td>The program aims to improve air quality and reduce emissions by replacing heat sources and enhancing energy efficiency in multi-family residential buildings. It is directed at municipalities, which then recruit individuals with legal ownership or property rights to residential premises</td><td>2022-2026</td></tr></tbody></table>

<footnote n="148">148 https://czystepowietrze.gov.pl/ [Last accessed on 28.05.2025]</footnote>

<footnote n="149">149 https://www.podatki.gov.pl/pit/ulgi-odliczenia-i-zwolnienia/ulga-termomodernizacyjna/ [Last accessed on 28.05.2025]</footnote>

<footnote n="150">150 https://mojprad.gov.pl/ [Last accessed on 28.05.2025]</footnote>
<table><thead><tr><th>Tool</th><th>Structures of Implementation</th><th>Time Horizon</th></tr></thead><tbody><tr><td></td><td>Eligibility criteria: owners of flats in multi-family buildings; via local government call.<br>Targeting: income-based co-financing (up to 90%); includes rental units and potentially social housing; accessible to individuals with legal property rights<sup>151</sup>.</td><td></td></tr><tr><td>'My Heat' Program<br>[Program 'Moje cieplo']</td><td>The program aims to support the development of individual heating and prosumer energy through the installation of air, water, and ground heat pumps in new single-family homes. It provides co-financing for the purchase and installation of these heat pumps for heating or hot water purposes. The grant covers up to 30% or 45% of eligible costs, with a maximum of PLN 21,000 (4 970 EUR) per investment.<br>Eligibility criteria: owners/co-owners of new buildings (constructed after 2021) meeting energy standards.<br>Targeting: only for owner-occupied housing; not available for rental or social housing; higher co-financing rate (45%) for holders of the Large Family Card (a support program for large families in Poland, which provides discounts and reliefs on various services and products)<sup>152</sup>.</td><td>2022-2026</td></tr><tr><td>'Stop Program Smog'</td><td>Program helps replace or eliminate high-emission heat sources and modernize thermal systems in single-family homes. It is managed by municipalities that apply for funding from the National Fund for Environmental Protection and Water Management. The program aims to reduce pollution, improve air quality, and increase energy efficiency, particularly for low-income households. Key actions include replacing high-emission heat sources, thermal modernization, connecting to heating or gas networks, and providing access to renewable energy sources<br>Eligibility criteria: households in energy poverty; property must be in a municipality that signed a cooperation agreement.<br>Targeting: strong income targeting: focuses on the poorest households; housing tenure must be owner-occupied; does not include tenants or institutional landlords<sup>153</sup>.</td><td>2019-2024</td></tr><tr><td>Energy Advisory System</td><td>Project, run by Provincial Funds for Environmental Protection and Water Management, employs Energy Advisors to promote and raise awareness about low-emission practices, energy efficiency, renewable energy, and circular economy principles. The Advisors' tasks include educational outreach, informational and promotional activities, training, investment advice, energy audit verification, and guidance on available funding sources for energy-related investments<br>Eligibility criteria: Open to all interested citizens, municipalities, and SMEs.</td><td>From 2016</td></tr></tbody></table>

<footnote n="151">151 https://mojprad.gov.pl/ [Last accessed on 28.05.2025]</footnote>

<footnote n="152">152 https://mojecieplo.gov.pl/ [Last accessed on 28.05.2025]</footnote>

<footnote n="153">153 https://czystepowietrze.gov.pl/inne-programy/stop-smog [Last accessed on 28.05.2025]</footnote>
<table><caption>Table PL3. Tools used in the introduction of housing retrofitting in Poland</caption><thead><tr><td>Tool</td><td>Structures of Implementation</td><td>Time Horizon</td></tr></thead><tbody><tr><td></td><td>Targeting: No formal eligibility criteria; primarily serves homeowners, public buildings, and SMEs; not specific to social groups or tenure types<fnref n="154" />.</td><td></td></tr></tbody></table>

Source: own elaboration.

Many entities at different levels of administration are involved in implementing instruments supporting building retrofits in Poland. The largest public institution established to finance environmental protection in Poland is the National Fund for Environmental Protection and Water Management. At the regional level, its functions are supplemented by Provincial Funds for Environmental Protection and Water Management operate which not only implement nationwide programs such as "Clean Air", "Mój Prąd" or "Moje Ciepło", but also provide direct service to beneficiaries and conduct activities adapted to local conditions (Burchard-Dziubińska & Burzyńska, 2023). EU requirements promoting the implementation of environmental protection principles across all sectors of the economy, including construction, implement a model aimed at eliminating non-renewable raw materials, particularly coal, natural gas, and crude oil, used for energy production, replacing them with energy from nuclear power plants and renewable sources like wind, solar, and water (Kempista & Gołębska, 2024).

The Ministry of Climate and Environment is responsible for shaping the policy and is in charge of the support system, while the Ministry of Finance is responsible for managing tax instruments, such as the thermal modernization relief.

In the case of programs aimed at low-income households, such as "Stop Smog" or "Warm Apartment", local governments play a key role as intermediaries - they prepare applications, conduct recruitment and implement investments in cooperation with residents. Additionally, technical and advisory support is provided by Energy Advisors, who support citizens, housing communities and companies in preparing investments, analyzing profitability and obtaining funding. Installation companies, energy auditors and tax advisors are also involved in the implementation of individual activities, supporting beneficiaries in meeting technical and formal requirements (Błasiak-Nowak & Rajczewska, 2015).

## 4.3 Size and role of the market

In Poland, the process of creating the energy market began with the enactment of the **Energy Law** in 1997. It included the demonopolization of the sector, dividing it into subsectors of generation, transmission, distribution, and energy trading, as well as market liberalization, which allowed independent companies to cooperate commercially. Additionally, the privatization of the energy sector involved transforming state-owned enterprises into state treasury companies, which were then sold to domestic or foreign investors. An important role in shaping the Polish energy market at this stage was assigned to the Energy Regulatory Office, established in 1997. The legal basis for the functioning of the energy market in Poland

<footnote n="154">¹⁵⁴ https://doradztwo-energetyczne.gov.pl/ [Last accessed on 28.05.2025]</footnote>
is the *Energy Law* and related executive acts (regulations), mainly from the Minister of Economy and the Minister of the Environment. With Poland's accession to the EU, Polish legislation on the energy market was aligned with European legislation, primarily the EU Directive on the rules for the common electricity market. From the consumer's perspective, an important milestone was 2007, when every individual consumer (household) gained the right to purchase energy from their chosen supplier<fnref n="155" />.

In 2007, the electricity market was liberalized. Since then, every consumer has been able to purchase electricity from a supplier (trading company) of their choice. The liberalization of the electricity market aimed to strengthen competition, which was expected to lead to lower prices. According to the principles of a free market, electricity suppliers are expected to compete for customers by reducing costs and offering electricity at optimal prices. The liberalization of the electricity market is associated with the introduction of the Third-Party Access (TPA) principle. TPA involves granting access to the electricity network infrastructure by the owner of the infrastructure to energy companies engaged in electricity trading, allowing them to deliver electricity to consumers<fnref n="156" />.

**The Government Solidarity Shield** was introduced in Poland in 2023 as an umbrella protecting all individual customers from record-breaking electricity prices. Energy prices for individual consumers have been frozen at 2022 levels within specific electricity consumption limits. The energy voucher is a benefit that, in 2024, was due to every household meeting the income criterion, i.e., where the average monthly income for 2023 did not exceed PLN 2,500 (590 EUR), and for multi-person households, PLN 1,700 (400 EUR) per person. The energy voucher is a support measure introduced in response to rising energy prices, aimed at helping households, especially those in difficult financial situations, to cover energy costs. The energy voucher was part of a government support package that also included other forms of assistance, such as subsidies on energy bills (Figure PL2).

<footnote n="155">155 https://www.gov.pl/web/gov/zloz-wniosek-o-wyplate-bonu-energetycznego [Last accessed on 20.01.2025]</footnote>

<footnote n="156">¹⁵⁶ https://www.gov.pl/web/klimat/taryfowanie-energii-elektrycznej [Last accessed on 20.01.2025]</footnote>
<figure><img src="image_80.png" /><figcaption>Figure PL19. The price of electricity for a household consumer in Poland between 2012-2023</figcaption></figure>

Source: Energy Regulatory Office<fnref n="157" />.

It is worth mentioning that, in 2022, the share of energy from renewable sources in Poland's gross final energy consumption was 16.81%, an increase of 1.2 percentage points compared to 2021. Coal accounted for 69.2% of electricity generation in Poland. Although the share of coal in Poland's energy mix decreased by 19.4 percentage points (from 98.4%) between 2000 and 2022, it remained the second highest in the European Union in 2022. While the share of coal in electricity production in Poland is currently among the highest in the EU, maintaining coal-based power plants is the least economically efficient solution in the long term<fnref n="158" />.

Since the 1990s, the electricity market in Poland has undergone liberalization aimed at increasing market competition and creating better conditions for end consumers. Pro-environmental policies have led to a rise in electricity production from renewable energy sources. Several programs have been introduced to support renewables, reduce greenhouse gas emissions, modernize power grids, and promote the development of electromobility. Despite this progress, the Polish electricity market still faces numerous challenges, including the urgent need to modernize infrastructure, improve energy efficiency, and expand energy storage capacity (Sekuła et al., 2023).

The electricity market in Poland is a complex and evolving system influenced by national energy policy, EU regulations, and growing market liberalization. It includes the production, transmission, distribution, and trade of electrical energy. The key players in Poland's electricity market include a mix of state-owned energy groups, private investors, and regulatory bodies. The largest electricity producers and distributors are state-controlled companies such as PGE, Enea, Tauron, and Energa (now part of the Orlen Group), which dominate both the generation and distribution segments. The Energy Regulatory Office (URE) serves as the national authority responsible for overseeing the market, issuing licenses, and approving tariffs,

<footnote n="157">157 https://www.ure.gov.pl/pl/energia-elektryczna/ceny-wskazniki/7853,Srednia-cena-energii-elektrycznej-dla-gospodarstw-domowych.html [Last accessed on 20.01.2025]</footnote>

<footnote n="158">¹⁵⁸ https://ozzzprc.pl/2023/11/18/miks-energetyczny-w-polsce-raport/ [Last accessed on 20.01.2025]</footnote>
particularly for household consumers. Together, these actors shape the structure, pricing, and future development of Poland's electricity sector (Thlon et al., 2024).

## 4.4 The multilevel governance process

Poland has an extensive system of institutions and programmes supporting activities for environmental protection, energy efficiency and sustainable development. At various levels, the activities are carried out by bodies and institutions that share a common goal (Table PL4). They consistently implement the sustainable development strategy, striving to improve air quality, reduce pollutant emissions and increase the energy efficiency of buildings.

<table><thead><tr><td>Actor</td><td>Type</td><td>Level</td><td>Roles</td><td>Effects</td><td>Coordination Dynamics</td></tr></thead><tbody><tr><td>Ministry of Climate and Environment</td><td>Public</td><td>National</td><td>Developing and implementing national environmental policies and programs and overseeing funding coordination.</td><td>Publishes key programs (e.g. "Clean Air"), oversees strategic documents and EU fund programming.</td><td>Coordination with local governments improving but still inconsistent.</td></tr><tr><td>Banks and Investment Funds</td><td>Financial Institutions</td><td>National/ Regional/ Local</td><td>Offering loans, financial instruments, and co-financing for retrofitting and energy-efficient projects.</td><td>Support financing under programs. Some barriers to access for low-income groups.</td><td>Aligned with developers; weak formal coordination with public policy goals.</td></tr><tr><td>Operators</td><td>Public</td><td>Regional/ Local</td><td>Identifying beneficiaries, encouraging heat source replacement or thermal modernization, and guiding them through the subsidy application, implementation, and settlement process.</td><td>Key role in delivering projects. Efficiency depends on local capacity and clarity of regulations.</td><td>Strong collaboration with municipalities and energy advisors, though capacity varies by region.</td></tr><tr><td>Energy Advisors</td><td>Public</td><td>Local</td><td>Providing advice and guidance to households, businesses, and municipalities on energy efficiency, retrofitting, and renewable energy solutions</td><td>Often first point of contact for citizens. Crucial in improving local programs.</td><td>Frequently underfunded and undertrained. Limited integration into wider planning processes. Coordination with NGOs and municipalities often ad hoc.</td></tr><tr><td>National Fund for Environmental Protection</td><td>Public</td><td>National</td><td>The key institution financing environmental protection and water</td><td>Central in financing programs.</td><td>Good cooperation with Provincial Fund for Environmental</td></tr></tbody></table>
<table><thead><tr><td>Actor</td><td>Type</td><td>Level</td><td>Roles</td><td>Effects</td><td>Coordination Dynamics</td></tr></thead><tbody><tr><td>and Water Management</td><td></td><td></td><td>management projects in Poland, offering loans, grants, and co-financing to local governments, enterprises, and individuals.</td><td></td><td>Protection and Water Management; tensions may arise with local governments over fund allocation and administrative burdens.</td></tr><tr><td>Provincial Fund for Environmental Protection and Water Management</td><td>Public</td><td>Regional</td><td>A strategic partner for local governments and others, providing financial support for environmental protection and sustainable development projects.</td><td>Ensure regional relevance of national programs; key interface for local beneficiaries. Effectiveness varies by voivodeship.</td><td>Generally positive cooperation with municipalities; capacity to advise applicants still under development in some regions.</td></tr><tr><td>Agency for Restructuring and Modernization of Agriculture</td><td>Public</td><td>Regional/ Local</td><td>Providing funding and support for rural environmental projects, including clean energy, retrofitting, and sustainable agricultural practices</td><td>Key funder in rural transition to low-emission systems (solar, biomass, insulation). Often underused due to procedural complexity.</td><td>Weak link to regional energy and spatial planning; coordination challenges with municipalities and advisors.</td></tr><tr><td>Main Office of Construction Supervision</td><td>Public</td><td>National/ Regional</td><td>Supervising construction activities; ensuring compliance with energy efficiency regulations and standards in new and retrofitted buildings.</td><td>Helps enforce energy regulations in new construction and retrofits. Limited role in proactive promotion of efficiency.</td><td>Works in isolation from planning offices. Reactive role; could be better integrated into regional strategies.</td></tr><tr><td>Municipalities</td><td>Public</td><td>Local</td><td>Implementing environmental programs at the local level; enforcing regulations and projects; engaging communities; promoting modernization and clean energy projects; coordinating consultation points</td><td>Critical implementers of programs. Differences in capacity between large and small municipalities.</td><td>Key interface for citizens but often lack staff and technical capacity. Increasing partnerships with NGOs and advisors. Coordination with regional and national actors inconsistent.</td></tr><tr><td>NGOs</td><td>Civil society</td><td>National/ Local</td><td>Increasing awareness of the need to take actions to support the improvement of the</td><td>Active in education and lobbying (e.g. Polish Green Network). Push for</td><td>Often fill coordination and outreach gaps. Limited formal role,</td></tr></tbody></table>
<table><caption>Table PL4. Actors involved in housing retrofitting governance in Poland</caption><thead><tr><td>Actor</td><td>Type</td><td>Level</td><td>Roles</td><td>Effects</td><td>Coordination Dynamics</td></tr></thead><tbody><tr><td></td><td></td><td></td><td>quality of the environment</td><td>better access for energy-poor households.</td><td>but growing influence through campaigns and local partnerships.</td></tr></tbody></table>

Source: own elaboration.

The governance of housing retrofitting in Poland involves a range of actors, including government institutions, local authorities, and private investors, who collaborate to improve energy efficiency and sustainability in buildings. Their roles focus on policy development, funding, technical implementation, and ensuring alignment with environmental and economic goals.

However, while modernisation efforts are primarily aimed at improving energy efficiency and reducing emissions, they also intersect with broader societal challenges. One of the most pressing is energy poverty, which continues to shape household needs and vulnerabilities, particularly in the context of recent economic and geopolitical shocks.

Energy poverty has become increasingly visible in Polish political discourse, especially since 2022. Although the 2022 Russian invasion contributed to a spike in income-based energy poverty rates, this did not reverse the long-term downward trend. Instead, it reinforced the upward trend that began with the economic impoverishment of Polish society because of the COVID-19 pandemic. Energy poverty in Poland manifests unevenly across different types of regions, reflecting deep-rooted spatial and socio-economic disparities (Figure PL3).

<figure><img src="image_81.png" /><figcaption>Figure PL20. The energy poor by type of region</figcaption></figure>

Source: own elaboration based on Lipiński & Juszczak (2023)

In its research, the Polish Economic Institute (2023) has identified four main forms of energy poverty:
1. Fuel poverty (income poverty) – this form is defined by a high share of energy expenditure in the household budget. Depending on the adopted threshold (ranging from 10% to 25% of household income), it affects between 16% and 30% of households in Poland,

2. Structural poverty – affecting 8% to 12% of households, this type arises where energy-related costs deepen existing economic poverty. It results from both high energy expenditures and relatively low incomes,

3. Municipal poverty – this form impacts 3% to 5% of households that are unable to meet their energy needs due to infrastructural deficiencies or because they reside in energy-inefficient buildings,

4. Hidden energy poverty – affecting 13% to 16% of households, this occurs where energy expenditure is artificially low due to extreme limitation of energy use, often at the expense of health and comfort.

A key structural factor behind these challenges is the poor technical condition of Poland's housing stock. Widespread infrastructural deficiencies – especially the lack or poor quality of thermal insulation and outdated, inefficient heating systems – result in significant heat loss and high maintenance costs. These issues are particularly burdensome for low-income households, where energy bills consume a substantial portion of the household budget. It is estimated that as many as 70% of single-family houses in Poland lack any form of thermal insulation (Lipiński & Juszczak, 2023).

The issue of energy poverty has been acknowledged in several strategic national documents. *The National Energy and Climate Plan for 2021–2030* (2019) calls for the development of a comprehensive policy to address energy poverty, including efforts to expand heating networks and support thermal modernization of residential buildings. Similarly, the *Energy Policy of Poland until 2040 2021*) sets the goal of reducing energy poverty to 6% by 2030. Both documents emphasize the need for a clear and consistent definition of energy poverty, a task that was partially undertaken in 2022.

In response to these challenges, in December 2022, the *Act amending certain acts supporting the improvement of housing conditions* came into force. It introduced new financial support mechanisms and expanded existing tools for thermal modernization and the development of renewable energy sources in the housing sector – with particular emphasis on supporting households most at risk of energy poverty.

Vertical governance is essential in retrofitting in Poland because it links European vision, national strategy, and local action. Without strong coordination across these levels, retrofitting policies risk being underfunded, poorly implemented, or misaligned with broader climate goals.

A clear example of this is the City of Kraków, which has gone beyond national requirements by introducing a local ban on coal and wood in households in 2019, ahead of national deadlines, and actively supports retrofitting through local funding schemes and information centers. This demonstrates how local governments can translate national and EU policies into place-specific actions. In fuel combustion installations, only high-methane or nitrogen-rich
natural gas is permitted. Additionally, the use of permanently installed heavy garden grills, such as brick grills permanently fixed to the ground or large grills operating continuously in one location, is prohibited<fnref n="159" />.

## 4.5 Achievements, assessments, and challenges

Housing retrofitting in Poland has emerged over the past few decades as a response to several challenges (Table PL5). A large proportion of residential buildings were constructed before the 1990s, many of which lack modern insulation, energy-efficient windows, or advanced heating systems. This results in high energy consumption and high costs for homeowners and tenants.

<table><caption>Table PL5. Impacts of housing retrofitting policies on housing inequalities in Poland</caption><thead><tr><td>Impact Area</td><td>Measured impacts</td><td>Potential impacts</td></tr></thead><tbody><tr><td>Energy Efficiency</td><td>There is a decrease in the annual primary energy demand index in residential buildings (Table PL6), as well as an increase in the share of renewable energy sources in the energy balance (Figure PL4)</td><td>Further reduction of energy consumption and CO₂ emissions on a regional and national scale; increase of the share of renewable energy sources in powering buildings</td></tr><tr><td>Environmental Impact</td><td>Reducing greenhouse gas emissions because of activities related to improving energy efficiency and thermal modernization (Figure PL5)<br/>The effect of the first recruitment in 2019: Niepołomice, Pszczyna, Rybnik, Skawina, Sosnowiec, Sucha Beskidzka and Tuchów. Currently 26 municipalities, including Warsaw and Łódź and 11 cities of the Upper Silesian Industrial Region, where pollution in Poland is considered the highest</td><td>Long-term improvement of the quality of the natural environment, reduction of low emissions and pollution; adaptation of buildings to climate change and energy standards</td></tr><tr><td>Economic Impact</td><td>Creation of local jobs in construction and HVAC sectors; increased demand for certified installers and energy auditors</td><td>Development of the energy efficiency sector (construction industry, renewable energy technologies)</td></tr><tr><td>Social Impact</td><td>Increased household comfort and reduced energy poverty in targeted retrofitting schemes</td><td>Raising public awareness of sustainable energy consumption; better living conditions for lower-income households</td></tr><tr><td>Policy and Regulations</td><td>Strengthened monitoring and evaluation via EPC registry</td><td>The potential to increase the effectiveness of policies by increasing subsidy opportunities and introducing regulations that support the sustainable development of buildings, achieving national climate goals</td></tr></tbody></table>

Source: own elaboration.

Poland has some of the highest levels of air pollution in Europe, particularly in urban areas where coal-based heating is common in residential buildings. Retrofits that replace coal-based

<footnote n="159">¹⁵⁹ https://powietrze.malopolska.pl/antysmogowa/krakow/ [Last access on 4.06.2025]</footnote>
heating systems with more energy-efficient and cleaner alternatives are seen as critical for reducing emissions and improving air quality<fnref n="160" />.

<figure><img src="image_82.png" /><figcaption>Figure PL21. Total energy supply by product in Poland between 2012 and 2023</figcaption></figure>

Source: Eurostat.

The table no. PL6 presents the median values of EP indicators for buildings of different categories, determined based on energy performance certificates prepared using the Central Register of Energy Performance of Buildings.

<table><thead><tr><th></th><th>&lt;1994</th><th>1994-1998</th><th>1999-2008</th><th>2009-2013</th><th>2014-2016</th><th>2017-2018</th><th>2019-2020</th></tr></thead><tbody><tr><th>single-family building</th><td>263,7</td><td>147,9</td><td>143,5</td><td>126,3</td><td>109,1</td><td>94</td><td>89,3</td></tr><tr><th>multi-family building</th><td>258,9</td><td>139</td><td>110</td><td>142,7</td><td>97,5</td><td>87</td><td>84,9</td></tr></tbody></table>

The shades of the table fields correspond to the levels of the indicator: from the highest (red) to the lowest (blue).

<caption>Table PL6. Median value of the annual primary energy demand indicator for residential buildings depending on the purpose of the building and the year of commissioning [kWh/(m² year)]</caption>

Source: own elaboration based on Central Register of Energy Performance of Buildings

The inefficiency of residential buildings contributes to health risks, particularly in terms of poor indoor air quality and exposure to cold in winter. Housing retrofitting can improve living conditions, reduce fuel poverty, and enhance overall public health. It also addresses economic and social dimensions, as many low-income households are especially vulnerable to energy

<footnote n="160">¹⁶⁰ https://powietrze.malopolska.pl/baza/jakosc-powietrza-w-polsce-na-tle-unii-europejskiej/ [Last accessed on 25.01.2025]</footnote>
poverty due to high heating costs. Retrofitting programs can help alleviate this issue, especially in the context of rising energy prices. Housing retrofitting policies in Poland have generally contributed to reducing housing inequalities by improving living conditions and reducing energy costs for vulnerable populations.

<figure><img src="image_83.png" /><figcaption>Figure PL22: Emission of greenhouses gases in Poland</figcaption></figure>

Source: based on https://www.eea.europa.eu/en/analysis/maps-and-charts/greenhouse-gases-viewer-data-viewers [Last access on: 02.06.2025].

<figure><img src="image_84.png" /><figcaption>Figure PL23. Effects within priority programmes</figcaption></figure>

Source: Statistics Poland (2025).

In the context of retrofitting in Poland, several corrective public policies have been designed to mitigate social and economic inequalities, particularly by ensuring that low-income households can access financial tools and benefit from energy efficiency upgrades. These policies use income-based eligibility criteria, targeted subsidies, and simplified procedures to support vulnerable groups.
The **Clean Air Programme** and the **Stop Smog Programme** are two key corrective public policies in Poland that aim to reduce energy poverty and environmental inequality through targeted support for building retrofits. The Clean Air Programme provides financial assistance for homeowners to replace outdated heating systems and insulate buildings, with subsidy levels adjusted based on household income. The Stop Smog Programme complements this by focusing on the most vulnerable groups in highly polluted municipalities, offering 100% financing for retrofitting projects such as thermal insulation and boiler replacement. Eligibility is strictly income-based and includes property value limits, ensuring that aid reaches those most in need. Both programs exemplify how public policy can promote fair access to clean energy solutions, helping to mitigate inequalities, reduce household energy bills, and improve living conditions for economically disadvantaged populations.

It is worth mentioning that rural Poland faces entrenched housing and energy inequalities, which are both shaped and perpetuated by the uneven rollout and accessibility of EEP. While energy efficiency is a national priority, rural areas often lack the resources and infrastructure to benefit from these policies in practice. Rural areas in Poland typically have older, poorly insulated buildings, many constructed before modern energy standards. These homes often rely on inefficient coal or wood-burning stoves for heating, contributing to higher energy consumption and air pollution. Despite this, they are less likely to be targeted by retrofitting programs due to logistical and economic challenges.

Most EEPs, such as the Clean Air Programme, offer partial subsidies that still require co-financing, which is unaffordable for many rural residents. Moreover, many residents do not have the technical capacity or support to meet the eligibility criteria (e.g., legal property ownership, building standards, tax documentation). Rural populations in Poland are often older, lower-income, and more reliant on subsistence agriculture or pensions. These groups are less resilient to climate and policy shocks, and without targeted interventions, they are systematically left behind in the green transition.

5 Nature-Based Solutions

One of the actions for adapting to climate change involves physical transformations in space, such as increasing the number of green areas. Such actions are recommended by the EU, the UN, the International Union for Conservation of Nature, and other leading international organizations. In this context, particular emphasis is placed on so-called nature-based solutions (Ćwiklińska & Dudzińska-Jarmolińska, 2020).

5.1 The policy cycle: emergence of the issue and policy decisions

The emergence and implementation of Nature-Based Solutions (NBS) in Poland reflect the complex interplay between national policy-making and European Union directives. This chapter examines the governance processes that have shaped Poland's approach to NBS, with a focus on how EU policies influenced national agendas. By analyzing the dynamics of these processes, the chapter sheds light on the evolution of goals and coalitions that underpin Poland's commitment to NBS (Figure PL7).
<figure><img src="image_85.png" /><figcaption>Figure PL24. Timeline with main milestones for introducing NBS in Poland</figcaption></figure>

Source: own elaboration.

Since 1999, at the municipal level, tasks related to broadly understood environmental issues have been carried out by the municipal council, the head of the commune, the mayor, or the city president. The obligations of municipal bodies performing tasks in the field of environmental protection arise primarily from the **Environmental Protection Law** (2001) and the **Nature Conservation Act** (2004). In the area of environmental protection, the executive body of the commune prepares local legal acts, including the commune environmental protection program. In Poland, environmental protection programming at the municipal level takes place in many municipalities, particularly those located in areas with environmental threats (Dumieński et al., 2019).

In the Polish policy context, NBS are most often associated with green areas. However, their conceptual scope is gradually broadening. While many local and regional planning documents still identify NBS with urban parks, green corridors or rain gardens, the more comprehensive understanding promoted by the European Union – including blue infrastructure, ecosystem-based adaptation and multifunctional land use – is only partially integrated into national policy frameworks. In earlier policy and planning discourses, the concept of green infrastructure dominated and was widely used in spatial planning and urban regeneration programmes (Surma, 2015). In contrast, the term ecosystem services were mainly used in scientific research and environmental assessments, especially in the context of strategic environmental assessments. The concept of nature-based solutions is a relatively recent addition, introduced mainly through international policy programmes, and has not yet been fully institutionalised in Polish governance structures.

Since around 2017, NBS has started to appear more systematically in national discussions, especially in relation to climate change adaptation strategies (e.g. Urban climate change adaptation plans) and in scientific papers (Kronenberg et al., 2017). However, the concept is still not binding in the current Polish legal and regulatory framework. NBS often get equated with urban greening due to their visibility and easier policy framing.
In 2011, some recommendations to NBS were included in **The National Spatial Development Concept 2030** which planned to introduce an obligation to retain rainwater in agglomeration areas in order to reduce flood surges in densely built-up areas, and to use the obtained resource to maintain the green infrastructure of urbanized areas and – as the value of water abstracted for the living needs of the population increases – for other uses.

In 2013, Poland adopted **The Strategic Adaptation Plan for Sectors and Areas Sensitive to Climate Change by 2020, with a Perspective to 2030** developed by the Ministry of the Environment. Incorporating climate change considerations into urban spatial policy was identified as one of the plan's key actions. It was the first strategic document to directly address the issue of adaptation to ongoing climate change. The plan's main objective is to ensure sustainable development and the effective functioning of the economy and society in the context of a changing climate. The document identifies priority areas for adaptation actions, focusing on sectors most sensitive to climate change, such as water management, agriculture, forestry, biodiversity, health, energy, construction and spatial management, urban areas, transport, mountainous regions, and coastal zones. Financing for climate adaptation measures is sourced from national public funds, such as the National Fund for Environmental Protection and Water Management (NFEPWM), provincial environmental and water management funds, the state budget, revenue from the sale of Assigned Amount Units (AAUs), and local government budgets. Local governments are also encouraged to leverage EU funds under the New Financial Perspective, which supports instruments for sustainable urban development. The document emphasizes the inclusion of green and water areas, ventilation corridors, and sustainable heating methods in urban development plans, along with stormwater management and natural revitalization initiatives. Key recommendations include restoring degraded green areas and water reservoirs, enhancing small retention in cities, and replacing impermeable surfaces with permeable ones to support climate adaptation.

In 2019, the Ministry of Environment published the strategy called the **National Environmental Policy 2030** (NEP2030). The strategic projects of NEP2030 include clean air, landscape audits, the development and implementation of a coherent and comprehensive State Raw Materials Policy, a green technology accelerator, forest coal farms, wooden construction, adaptation to climate change, a comprehensive program for the adaptation of forests and forestry to climate change, and water for agriculture. NEP2030 serves as the basis for investing European funds from the financial perspective for 2021–2027. The strategy also supports the implementation of Poland's goals and commitments at the international level, including at the EU and UN level, particularly in the context of the EU's climate and energy policy goals until 2030 and the sustainable development goals outlined in the 2030 Agenda.

Poland developed the **National Urban Policy 2023** (NUP2023) as a strategic document for urban development. NUP defined the framework and indicated key directions and areas of urban development. As the newest of public policies, urban policy has moved away from a sectoral approach towards an integrated and interdisciplinary approach (Rzeńca & Sobol, 2020). In 2022 new **National Urban Policy 2030** (NUP2030) was introduced. In principle, the essence of conducting national urban policy is to face development challenges and create conditions for strengthening the capacity of cities and urban functional areas for sustainable development, improving the quality of life of residents and building resilience to observed climate change. A green city is defined in NUP2030 as opposing the deepening climate crisis,
counteracting the effects of climate change, reducing air pollution emissions and rebuilding ecosystems in urban areas (increasing green areas and the continuity of ecosystems interpenetrating urban areas).

The term "Nature-Based Solutions" in Poland is increasingly present but still unevenly adopted across sectors and institutions. The term is more common in English-language materials (EU reports, academic publications) than in Polish-language documents. In Polish, it is often translated very loosely or kept as the acronym NBS in technical texts. At local level only municipal departments in cities Involved in EU projects, dealing with climate adaptation, green infrastructure, and urban development may reference NBS in strategies and tenders. Smaller towns and rural municipalities rarely use the term, even if they implement NBS-like practices (e.g., wetland restoration, tree planting).

## 5.2 The implementation process

The need to implement actions to adapt to the effects of climate change and, consequently, the use of NBS has two reasons: the lack of sufficient and effective steps to stop climate change and the increasingly rapid emergence of the negative effects of this process (Karaczun et al., 2022). Tools that implement NBS in Poland are crucial for addressing climate change and urbanization challenges by integrating natural processes into urban planning and development (Table PL7).

<table><thead><tr><td>Tool</td><td>Structures of Implementation</td><td>Time Horizon</td></tr></thead><tbody><tr><td>Urban climate change adaptation plans</td><td>Prepare climate change adaptation plans for the 44 largest urban centres in Poland.<br/>Plans are based on climate vulnerability assessments, including risk mapping (e.g., heat islands, flooding). Criteria include population density, land sealing, and exposure to climate risks. Identification priority zones used GIS analyses.</td><td>2017-2019</td></tr><tr><td>Water Retention Project</td><td>The "My Water" Project has funded 20,000 home retention installations. The 2021-2027 Retention Development Program, with a perspective to 2030, focuses on rebuilding and expanding land improvement systems, constructing new retention reservoirs, desludging and maintaining existing reservoirs, and creating local small retention systems.<br/>Priority areas identified based on hydrological risk, agricultural needs, and infrastructure capacity. Criteria include flood and drought exposure<sup>161</sup>.</td><td>2020-2027</td></tr><tr><td>Urban greening</td><td>The National Fund for Environmental Protection and Water Management will transfer funds from the European Funds for</td><td>2024-2027</td></tr></tbody></table>

<footnote n="161">161 https://www.gov.pl/web/nfosigw/moja-woda--wsparcie-dzialan-realizowanych-przez-wfosigw [Last accessed on 2.06.2025]</footnote>
<table><caption>Table PL7: Tools used in introduction of NBS in Poland</caption><thead><tr><td>Tool</td><td>Structures of Implementation</td><td>Time Horizon</td></tr></thead><tbody><tr><td></td><td>Infrastructure, Climate, Environment 2021-2027 program for the "deconcreting" of areas in cities.<br/>Calls for projects encourage targeting highly sealed areas and urban heat islands. Municipalities are expected to provide justification based on environmental data. Pilot projects in Łódź and Poznań aim to restore natural soil functions in overbuilt districts. Project selection based on environmental audits.</td><td></td></tr><tr><td>Forestation Initiatives</td><td>Strategic Plan for the Common Agricultural Policy for 2023-2027 - The intervention is dedicated to agricultural land characterized by low suitability for agriculture, constituting a potential area for establishing forest plantations, as well as shaping the landscape structure of rural areas.<br/>Focus on agricultural lands with low production potential. Priority given to degraded areas and regions with low forest cover.</td><td>2023-2027</td></tr><tr><td>Cities adaptation to climate change and Green-Blue Infrastructure</td><td>In 2024 change of the act - Environmental Protection Law was adopted. The Act provides that cities with more than 20,000 inhabitants will develop municipal plans for adaptation to climate change.<br/>Municipalities required to assess vulnerability and propose location-specific adaptation measures. Guidelines encourage the use of spatial data and participatory tools.</td><td>2024-2028</td></tr><tr><td>Clean Transport Zone</td><td>A clean transport zone is an area designated in the city center that is accessible only to vehicles that meet the required emission standards. The possibility of establishing such zones was introduced by the amendment to the Act of January 11, 2018 on electromobility and alternative fuels.<br/>Priority areas are high-density, high-traffic city centers with poor air quality. Assessment based on emissions monitoring and health risk Warsaw introduced Poland's first clean transport zone on July 1, 2024.</td><td>From 2024</td></tr></tbody></table>

Source: own elaboration.

In connection with *The Strategic Adaptation Plan for Sectors and Areas Sensitive to Climate Change by 2020, with a Perspective to 2030* (2013), the Ministry of the Environment decided to prepare climate change adaptation plans for the 44 largest urban centres in Poland. The aim of the preparation of *Municipal Climate Change Adaptation Plans* for cities with more than 100 thousand inhabitants was to increase the resilience of cities to climate threats, and thus to prepare these cities for modern shaping of local policy in response to the identified and predicted negative consequences related to climate change (Dumieński et al., 2019; Sachanbińska-Dobrzyńska, 2024).
Between 2018-2020 the project called ‘*Climate Mitigation Through Nature-Based-Solutions in Urban Poland - Fostering Awareness and Capacity (ClimateNBS Polska)*” was introduced. Its aim was to build awareness of how NBS can contribute to mitigating climate change in the city and to increase the knowledge and skills of city officials, local government employees, planners and landscape architects in the design and implementation of NBS in Polish cities. Based on the developed materials, an original training program was created, addressed to city officials and designers of blue-green infrastructure. The project was financed by the European Climate Initiative<fnref n="162" />. The adaptation plans developed in 2019 for the largest Polish cities – Warsaw, Krakow, Wrocław, Poznan, Gdansk, Szczecin, Bydgoszcz or Białystok – highlight the potential of greenery in helping cities adapt to climate change. Particular emphasis is placed on blue-green infrastructure, including greening walls (Ćwiklińska & Dudzińska-Jarmolińska, 2020).

*The National Energy and Climate Plan 2021-2030* (2019) focuses on enhancing climate resilience and improving urban ecosystem functioning in Poland. It aims to increase the percentage of city residents covered by urban adaptation plans and raise the country's forestation level. The concept of green-blue infrastructure is to be integrated into urban spatial development plans to strengthen ecosystem resilience. Additionally, the plan emphasizes natural revitalization, including the restoration of degraded green areas and water reservoirs to their original functions, with a particular focus on small-scale water retention in cities. It also highlights the importance of replacing impermeable ground surfaces with permeable ones to improve water management and mitigate climate impacts.

*The National Urban Policy 2030 (NUP2030)* adopted in 2022 emphasizes the need to integrate NBS into urban development, specifically through the protection and expansion of greenery. It recommends the implementation of legal standards to assess and compensate for ecosystem service losses using blue-green infrastructure of equal or greater value. The policy advocates for preserving existing trees during construction, ensuring their long-term protection, and requiring detailed tree inventories in building permit applications. Tree removal in urban areas should be restricted, only permitted when unavoidable, and compensated by planting new trees that provide equivalent environmental benefits.

In Poland's spatial planning system, up until September 2023, the standard measure for biologically active areas was defined as the percentage of biologically active land relative to the total surface area of a building plot. These requirements were specified in local spatial development plans established by cities or municipalities. In areas without such plans, the indicator was determined through administrative decisions on building and land development conditions issued by municipal authorities. However, as of autumn 2023, new regulations have been introduced. These regulations require biologically active areas to feature surfaces that support natural plant growth and facilitate rainwater retention, broadening the definition to include surfaces beyond native soil (Michalik-Śnieżek et al., 2024).

NBS are increasingly referenced in national and regional water strategies, particularly in the context of flood risk reduction, retention, and stormwater management. However, the terminology varies, many documents refer to 'natural retention' or 'blue-green infrastructure'.

<footnote n="162">¹⁶² https://www.ecologic.eu/16115 [Last accessed on 10.01.2025]</footnote>
In Poland, there is currently no national standardized framework for identifying priority areas for Nature-Based Solutions implementation. While several cities and regions have begun incorporating spatial criteria, such as flood risk, heat island intensity, or tree canopy deficits, into their local planning processes, these efforts remain fragmented and context-specific, often shaped by the availability of EU funding or participation in international pilot projects. As a result, the selection of NBS intervention areas tends to vary significantly across municipalities, depending on local expertise, technical capacity, and access to environmental data. The absence of a unified national approach or toolkit limits the broader scalability and comparability of NBS planning across Polish cities and territories.

5.3 Size and role of the market

The market framework for NBS in Poland is shaped by a combination of public funding, private sector engagement, and EU-driven initiatives. NBS are promoted within national frameworks like the *National Energy and Climate Plan* (2021–2030), urban adaptation strategies, and EU, which encourage integration of NBS in spatial planning and climate resilience measures. Growing awareness of climate challenges has increased demand for sustainable urban solutions, such as green infrastructure, permeable surfaces, and biodiversity conservation. Financial support comes from a mix of EU funds, national environmental programs, and local budgets. Private investments are incentivized through subsidies and public-private partnerships. NBS are increasingly embedded in urban spatial development plans, with a focus on green-blue infrastructure, water management, and ecosystem restoration.

The National Fund for Environmental Protection and Water Management operates under the Environmental Protection Law, playing a key role in financing environmental protection in Poland. In 2024 *Action Strategy of the National Fund for Environmental Protection and Water Management for 2025-2028* was elaborated. Due to this document NBS initiatives can be financed from various types of financial sources supported by National Fund for Environmental Protection and Water Management (Figure PL8).
<figure><img src="image_86.png" /><figcaption>Figure PL25: NBS funding sources by The National Fund for Environmental Protection and Water Management</figcaption></figure>

Source: own elaboration based on Action Strategy of the National Fund for Environmental Protection and Water Management for 2025-2028, (2024).

An example of the method of financing NBS in Poland can be the "Kłodzko NBS" project financed from the EEA funds and from the state budget, under the "Environment, Energy and Climate Change" Programme, the "Climate Change" programme area. In 2021, the Municipality of Kłodzko, in partnership with the International Development Norway, started implementing a 3-year project. The aim of the project was to prepare the city and its inhabitants for changing climatic conditions by mitigating climate change and adapting to its effects. The tasks completed included: introducing new plantings of plants resistant to climatic conditions, tidying up the accompanying infrastructure, greening the "concreted" market square, supplementing the plantings of plants resistant to climate change, including droughts, introducing pocket green areas in built-up areas, greening the courtyards, creating urban vegetable gardens, introducing a rainwater collection system in market square to water the urban greenery, creating a rainy playground, building absorption basins in city parks, introducing an electric bicycle system, introducing air pollution measurements in educational institutions together with an air purifier system<fnref n="163" />.

In Poland private actors, particularly in the construction, real estate, and water management sectors, promote NBS-compatible practices such as green roofs, retention systems, and landscape-integrated infrastructure, often in response to EU regulations, investor pressure, or certification schemes. These interests are represented by urban development chambers, architecture and planning associations, and environmental consultancies, which serve as intermediaries between the private sector and the state, advocating for regulatory reforms that facilitate green infrastructure integration in planning codes. In parallel, environmental NGOs and think tanks, such as the Sendzimir Foundation or Polish Green Network, function as both watchdogs and facilitators, mediating between civil society, municipalities, and businesses.

<footnote n="163">163 http://nbs.klodzko.pl/ [Last accessed on 20.01.2025]</footnote>
## 5.4 The multilevel governance process

The multilevel governance of NBS policies and strategies in Poland involves a collaborative approach between national, regional, and local levels of government, with various actors playing complementary roles. Below is an analysis of the division of roles, resources, and coordination between these levels (Table PL8).

<table><thead><tr><td>Actor</td><td>Type</td><td>Level</td><td>Roles</td><td>Effects</td><td>Coordination System</td></tr></thead><tbody><tr><td>Ministry of Climate and Environment</td><td>Public</td><td>National</td><td>Leads national climate policy, oversees biodiversity conservation, and coordinates NBS-related strategies and programs.</td><td>Coordinates national NBS efforts, influences environmental regulations and funding allocation.</td><td>Works with other ministries, regional authorities, and EU institutions to align climate and biodiversity goals with NBS strategies.</td></tr><tr><td>Ministry of Agriculture and Rural Development</td><td>Public</td><td>National</td><td>Oversees sustainable land use, agroforestry, and initiatives promoting ecosystem services in rural areas.</td><td>Shapes urban development policies that integrate NBS, contributing to sustainable urban growth.</td><td>Coordinates with agricultural advisory services, rural stakeholders, and EU CAP programs to promote NBS-aligned practices.</td></tr><tr><td>Ministry of Development and Technology</td><td>Public</td><td>National</td><td>Responsible for urban planning and development policies, including green and blue infrastructure in cities</td><td>Promotes rural NBS applications such as agroforestry, supporting ecosystem services in rural landscapes.</td><td>Interfaces with municipalities, developers, and urban planning bodies to implement NBS in spatial planning.</td></tr><tr><td>General Directorate for Environmental Protection</td><td>Public</td><td>National</td><td>Manages Natura 2000 sites and supports NBS implementation in protected areas</td><td>Enforces biodiversity conservation through NBS, promotes ecosystem protection in designated sites.</td><td>Cooperates with environmental agencies, local governments, and NGOs in managing protected areas.</td></tr><tr><td>National Fund for Environmental Protection and Water Management (NFOŚiGW)</td><td>Public</td><td>National</td><td>Provides funding for NBS projects, such as flood management, wetland restoration, and urban greening.</td><td>Finances NBS projects, enabling implementation of environmental protection and climate adaptation measures.</td><td>Collaborates with ministries, municipalities, and project implementers to disburse funds and monitor outcomes.</td></tr></tbody></table>
<table><caption>Table PL8. Actors involved in NBS governance in Poland</caption><thead><tr><td>Actor</td><td>Type</td><td>Level</td><td>Roles</td><td>Effects</td><td>Coordination System</td></tr></thead><tbody><tr><td>Voivodeships Offices</td><td>Public</td><td>Regional</td><td>Oversees regional planning, sustainable development, and implementation of NBS policies.</td><td>Implements NBS policies at the regional level, supports the integration of green infrastructure in regional plans.</td><td>Coordinate with municipalities, regional planning boards, and national ministries to align strategies.</td></tr><tr><td>Municipalities</td><td>Public</td><td>Local</td><td>Responsible for urban planning, integration of NBS in public spaces, and environmental governance.</td><td>Directly implements NBS in cities, improving urban resilience, air quality, and biodiversity in urban areas.</td><td>Engage with residents, private developers, and national programs to co-finance and deploy local NBS.</td></tr><tr><td>Ecological NGOs</td><td>Civil Society</td><td>National/ Local</td><td>Advocate for environmental protection, green infrastructure, and policy reform on NBS</td><td>Raises public awareness, influences policy, and supports grassroots NBS initiatives.</td><td>Collaborate with local communities, schools, municipalities, and EU-funded projects to advance NBS.</td></tr><tr><td>Construction and Development Companies</td><td>Private investors</td><td>National/ Local</td><td>Incorporate NBS into new development projects (e.g., green roofs, rain gardens).</td><td>Advances urban NBS integration, promotes green building practices in urban development.</td><td>Coordinate with municipalities and planners, often through public-private partnerships.</td></tr><tr><td>Community-Based Organizations/ Citizens and local communities</td><td>Civil Society</td><td>Local</td><td>Implement grassroots NBS projects like tree planting and river clean-ups.</td><td>Directly contributes to local NBS projects, fostering community engagement in environmental protection.</td><td>Collaborate with NGOs, local authorities, and schools through participatory planning and volunteering.</td></tr><tr><td>Banks and Investment Funds</td><td>Financial Institution</td><td>National/ Regional/ Local</td><td>Provide green financing options for NBS projects, including sustainable urban development.</td><td>Support private sector investment in NBS, helping to scale up green infrastructure initiatives.</td><td>Work with developers, municipalities, and international donors to structure financing and de-risk NBS investment.</td></tr></tbody></table>

Source: own elaboration.
NBS and housing affordability policies are not always fully coordinated, as these two areas typically fall under different ministries with distinct priorities. Housing affordability is primarily managed by the Ministry of Development and Technology, focusing on affordable housing construction and urban renewal, while NBS policies are often driven by environmental and climate ministries like the Ministry of Climate and Environment.

In Poland, the governance of Nature-Based Solutions (NBS) operates through a mix of vertical and horizontal coordination mechanisms, although these remain uneven and often project-driven. Vertical governance connects the national level (e.g. Ministry of Climate and Environment, National Fund for Environmental Protection) with regional (Voivodeship Offices) and local authorities (municipalities), mainly through the implementation of EU-funded programs, national climate strategies, or urban adaptation plans. For instance, Lublin's Green City Action Plan aligns with national climate goals and EU financing criteria, illustrating how local planning integrates upward policy frameworks. However, gaps persist due to unclear mandates or limited capacity at lower levels. Horizontal governance, on the other hand, is increasingly visible among municipalities, NGOs, and the private sector, particularly in co-designed urban greening and stormwater management projects.

## 5.5 Achievements, assessments, and challenges

During the socialist period in Poland, Nature-Based Solutions were implemented through ecological corridors designed to improve air exchange in cities. Green spaces were also used for noise and pollution isolation, particularly around hospitals and schools. Despite efforts to protect these areas, they faced constant pressure from urban expansion, which intensified after the fall of socialism and the weakening of urban spatial planning due to deregulatory activities (Kronenberg et al., 2017).

The main achievements of NBS policy in Poland include the successful utilization of EU funding mechanisms to support NBS projects, such as small-scale water retention systems and reforestation efforts. Additionally, NBS policies have contributed to raising public awareness about the importance of nature-based solutions in addressing climate challenges, fostering collaboration between local governments, the private sector, and civil society (Table PL9). The adoption of NBS in Poland often requires significant public sector involvement, as market forces alone typically do not provide sufficient incentives for large-scale implementation. Private sector participation is still developing and often depends on subsidies or regulatory requirements. Market-based tools, such as subsidies, incentives for eco-friendly infrastructure, and funding for small retention systems, are essential to attracting private actors, highlighting the need for public financial support.

<table><thead><tr><td>Impact Area</td><td>Measured Impacts</td><td>Potential Impacts</td></tr></thead><tbody><tr><td>Improved Access to Green Spaces</td><td>Many cities are implementing "deconcreting" programmes, often using EU funds.<br>Examples: Łódź has become an example of integrating deconcreting into broader urban revitalization, especially in the historic central district.</td><td>NBS could significantly improve access to green spaces in underserved urban areas, especially for low-income housing.</td></tr></tbody></table>