COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Poland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 9728/22 INIT; ST 9728/22 ADD 1) of 17 June 2022 on the approval of the assessment of the recovery and resilience plan for Poland
Date: 2023-11-21
Institutions: European Commission, Secretariat-General
Subjects: EU aid, EU loan, Poland, digital transformation, economic recovery, economic reform, energy policy, green economy, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 21.11.2023  SWD(2023) 381 final  COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Poland Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION amending Implementing Decision (EU) (ST 9728/22 INIT; ST 9728/22 ADD 1) of 17 June 2022 on the approval of the assessment of the recovery and resilience plan for Poland {COM(2023) 745 final}  
 
 
Table of contents 

1.  Executive summary ..........................................................................................................................2 

2.  Objectives of the modification of the plan .......................................................................................3 

2.1. 

The modified plan addresses Poland’s main newly emerged challenges .................................3 

2.2.  Overview of new and modified components ............................................................................3 

2.3.  Other elements not covered by assessment criteria ..................................................................9 

3.  Summary of the assessment of the plan .........................................................................................10 

3.1.  Comprehensive and adequately balanced response to the economic and social situation ......10 

3.2. 

Link with country-specific recommendations and the European Semester ............................11 

3.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar 
of Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence

13 

3.4. 

The principle of ‘do no significant harm’ ...............................................................................14 

3.5.  Green transition ......................................................................................................................17 

3.6.  Digital transition .....................................................................................................................19 

3.7. 

Lasting impact of the plan ......................................................................................................20 

3.8.  Milestones, targets, monitoring and implementation .............................................................21 

3.9.  Costing....................................................................................................................................21 

3.10.  Controls and audit ..................................................................................................................23 

3.11.  Coherence ...............................................................................................................................24 

3.12.  REPowerEU ...........................................................................................................................25 

3.13.  Cross-border or multi-country dimension or effect ................................................................28 

ANNEX I: Climate tracking and digital tagging ....................................................................................30 

1 

 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

The Polish economy recovered quickly from the COVID-19 pandemic, but economic growth 
is  expected to  stall  in  2023. Poland was one of the fastest-growing  economies in  the EU 
during the post-pandemic period, benefiting from strong policy support, low unemployment, 
and continued inflows of foreign direct investment. However, Russia’s invasion of Ukraine 
has put significant pressure on the economy. Elevated commodity prices are weighing on 
both real disposable incomes (i.e. incomes adjusted for inflation) and consumption growth, 
especially  given  the  high  share  of  energy  in  the  consumer  basket.  High  uncertainty,  a 
deteriorating  business  sentiment,  and  the  increased  cost  of  borrowing  are  impacting 
economic activity. As a result, the Commission’s forecast projects economic growth to slow 
considerably in 2023 before picking up in 2024 and 2025.  

To  tackle  these  challenges,  Poland  submitted  on  31  August  2023  a  modified  national 
Recovery  and  Resilience  Plan  (RRP),  including  a  REPowerEU  chapter  on  the  basis  of 
Article 21c  of the RRF Regulation, to  the Commission. For the modification of its  RRP, 
Poland has relied on the following legal bases: Article 14(2) of Regulation (EU) 2021/241 
(RRF Regulation) to include additional loan support, Article 18(2) of the RRF Regulation to 
take into account the updated maximum financial contribution published on 30 June 2022 
and Article 21 of the RRF Regulation considering that its initial RRP is partially no longer 
achievable  because  of  objective  circumstances.  Poland  therefore  made  a  request  to  the 
Commission to make a proposal to amend the Council implementing decision approving the 
assessment of Poland’s RRP. 

The modifications submitted by Poland affect six measures on the basis of Article 14 of the 
RRF Regulation, four measures on the basis of Article 18(2) of the RRF Regulation and 55 
measures on the basis of Article 21 of the RRF Regulation. In addition, errors of a clerical 
nature  that  do  not  reflect  the  content  of  the  initial  plan  submitted  by  Poland  have  been 
identified in the text of the Council Implementing Decision and Poland proposed corrections.  

The REPowerEU chapter contains measures to help address the key energy challenges that 
Poland is currently facing. The REPowerEU chapter includes seven new reforms, six new 
investments and three investments transferred from the initial RRP (two of which have been 
scaled-up).  

The reforms concern (i) the streamlining of permitting processes for RES, (ii) the removal 
of barriers to the integration of RES into electricity grids, (iii) the development of models 
and tools to support the development  of renewable energy sources (RES),  (iv) the policy 
support to energy efficiency and the accelerated phase-out of fossil fuels in home heating, 
(v) the policy support to skills for the green transition, (vi) the facilitation of development of 
local energy communities and (vii) the policy support to sustainable mobility.  

The  new  investments  include  (i)  support  for  institutions  implementing  the  REPowerEU 
measures,  (ii) the  development of  electricity distribution  networks in  rural areas, (iii)  the 
establishment of a fund  supporting  offshore wind farms,  (iv)  the establishment of a fund 
supporting the energy transformation, (v) improving energy infrastructure and facilities to 
meet immediate security of supply needs for gas and (vi) non-repayable and loan support to 
energy storage systems. Finally, the REPowerEU chapter includes investments transferred 
from the initial RRP, which concern (i) a scaled-up support to RES installations implemented 

2 

 
by energy communities, (ii) a scaled-up support to electricity transmission networks and (iii) 
the acquisition of zero-emission buses. 

Based on the assessment of the submitted modification and the  REPowerEU chapter, the 
Polish modified plan receives an A-rating on all criteria (including the two additional criteria 
for  the  REPowerEU  chapter),  except  for  costing,  where  the  plan  receives  a  B-rating 
(unchanged from the assessment of the initial plan). 

(1) 
Balanced 
Response 

(2) 
CSRs 

(3) 
Growth, 
jobs… 

(4) 
DNSH 

(5) 
Green 
target 

(6) 
Digital 
target 

(7) 
Lasting 
impact 

(8) 
M & T 

(9) 
Costing 

(10) 
Control 
Systems 

(11) 
Coherence 

(12) 
REPowerEU 

(13) 
Cross-
border  

A 

A 

A 

A 

A 

A 

A 

A 

B 

A 

A 

A 

A 

2.  OBJECTIVES OF THE MODIFICATION OF THE PLAN  

2.1. The modified plan addresses Poland’s main newly emerged challenges 

Poland’s modified RRP continues to address a significant subset of the challenges identified in 
the country-specific recommendations (CSRs) for Poland in 2020 and 2019. The modified plan, 
including  the  REPowerEU  measures,  effectively  addresses  all  or  a  significant  subset  of  the 
challenges identified in the relevant energy CSRs issued in 2022 and 2023 in the context of the 
European Semester. 

2.2. Overview of new and modified components  

The most important modifications of the modified RRP, including the REPowerEU chapter are 
listed below by component.  

•  Component A.1 (Reducing the impact of COVID-19 on businesses) is modified 
by removing the measure concerning the support for the preparation of investment 
sites for investments of key importance for the economy (A1.2 and A1.2.2), which 
are no longer achievable due to lack of demand on the side of main beneficiaries 
(investment zones) following the increased costs of preparation of the investment 
sites. Support to investments for enterprises in products, services and competences 
of employees and staff related to the diversification of activities (A1.2.1) is modified 
due to reduction of allocation and increased costs of services to be provided. The 
requirements of the land-use planning reform (A1.3) are revised to better address 
the challenges in spatial planning policy in Poland. The targets linked to the process 
of the implementation of the reform and adoption of the general spatial development 
plans  (A1.3.1)  are  also  adapted  due  to  increased  costs  of  preparing  the  spatial 
documents. 

•  Component  A.2 

(Development  of 

the  National  Innovation  System: 
strengthening coordination, stimulating innovation capacity and cooperation 
between  businesses  and  research  organisations,  including  in  environmental 
technologies) is modified by deleting investments for the creation of a model hub 
to  support  creative  industries  (A2.5.2)  due  to  unexpected  difficulties  in  the 
implementation process. All resources freed up are used for increasing the allocation 

3 

 
 
 
and  target  for  the  programme  to  support  the  activities  of  cultural  and  creative 
operators  to  stimulate  their  development  (A2.5.1).  Furthermore,  support  to  the 
system  and  infrastructure  for  unmanned  vehicle  traffic  management  (A2.3.1)  is 
being  reduced  due  to  finding  a  better  alternative  for  the  implementation  of  the 
measure. Consequently, the description of the measure and its milestones and targets 
were adapted. Finally, the interim deadline of investments supporting extension of 
the national system of monitoring services, products, analytical tools, services and 
associated infrastructure using satellite data (A2.6.1) is postponed due to unforeseen 
legal and technical difficulties linked to a very complex public procurement process 
with the participation of international consortia.  

•  Component A.3 (Education for the modern economy) is modified by decreasing 
an  intermediary  target  for  investments  in  modern  vocational  training,  higher 
education and lifelong learning (A3.1.1), as a cost increase has led to delays. 

•  Component A.4 (Increasing structural matching, efficiency and crisis resilience 
of  the  labour  market)  is  modified  by  removing  the  investment  on  supporting 
telework  schemes  in  companies  (investment  A4.4.1),  which  turned  out  to  be  no 
longer needed since most companies have implemented teleworking schemes in the 
meantime.  Freed  up  RRF  resources  are  reallocated  to  an  existing  investment 
providing for childcare facilities (A4.2.1) to allow the latter to keep the same level 
of ambition despite increased costs. Furthermore, the description of the reform on 
labour  market  segmentation  (A4.7)  was  slightly  amended  to  keep  the  sickness 
insurance  contribution  voluntary  for  contracts  for  specific  task,  which  takes  into 
account a short duration of these contracts. The timeline for this measure is adjusted 
to prepare the enterprises for increase in labour costs and Social Insurance Institution 
to adjust its IT system.  

•  Component B (Green energy and energy-intensity reduction) is modified under 
article  21  due  to  increased  prices,  better  ways  to  implement  the  corresponding 
measures, delays in the design of the measures as well as a measure being no longer 
achievable. Targets related to the replacement of heating sources (B1.1.2, B1.1.3), 
and to investments in sustainable water in rural areas (B3.3.1) were reduced due to 
a high level of inflation affecting the  cost. For the investment in energy efficient 
housing  for  low-  and  medium-income  households  (B3.5.1),  the  timeline  for 
implementation  was  also  extended,  while  for  the  investment  in  water  and  waste-
water infrastructure (B3.1.1), the scope of the measure was also amended to address 
the impact of inflation. Additionally, for B.2.1.1 the measure is amended to reflect 
the  impact  of  costs  in  hydrogen-related  infrastructure.  Amendments  to  B2.2.3 
(construction  of  offshore  terminal  infrastructure)  reflected  modifications  to  the 
scope  of  the  measure  due  to  increased  cost.  Moreover,  due  to  the  increased 
construction costs, the investment in remediation of a former brownfield site under 
measure  B3.2.1  was  removed.  Under  Article  21,  Poland  also  removed  measure 
B2.4.1 on energy storage, which was no longer achievable in the original form, and 
deleted measure B2.3.1. related to the construction of offshore wind farms due to 

4 

 
 
 
 
lack of demand for the support under this measure. With regards to  the financial 
instrument on the green transition of cities (B3.4.1), the final target of signature of 
contracts  was  reduced  to  address  the  impact  of  inflation  and  increased  costs. 
Allocations freed up by the removals of A2.5.2, B2.3.1, B2.4.1, C1.2.1, E2.3.1 and 
the decreased allocations of B3.2.1, B3.3.1, B3.5.1 and C2.2.1 from the loan part of 
the  original  plan  are  reallocated  to  the  instrument  and  two  additional  targets  are 
included for this revised allocation. A new target B27aL covers projects completed 
for the revised budget allocation. Measure B2.2 (Improving the conditions for the 
development of renewable energy sources) has been moved to the loan part. Finally, 
under  article  18,  measures  covering  the  development  of  transmission  networks 
(B2.2.1)  and  the  installation  of  renewables  operated  by  energy  communities 
(B2.2.2)  were  transferred  to  REPowerEU  to  account  for  the  decrease  in  the 
maximum financial contribution for Poland.  

•  Component  C  (Digital  Transformation)  is  modified  by  decreasing  its  budget, 
adjusting the scope of the measure on public e-services and targets (C2.1.1) to take 
into  account  implementation  difficulties  and  focus  on  e-services  and  IT  systems 
enabling citizens to deal with administrative matters online. The measure related to 
ensuring the level-playing field for schools with mobile multimedia devices (C2.1.2) 
has been amended to reflect a better alternative in the delivery method, introducing 
a voucher system for provision of laptops for teachers. The measure concerning e-
competences (C2.1.3) has been revised due to a cost increase, with targets related to 
digital  coordinators  in  municipalities  being  removed  and  targets  related  to  the 
trainings being reduced. The cybersecurity measure (C3.1.1) has been restructured 
to take into account the changed risk assessment caused by the Russian aggression, 
resulting in the revision of the decision on a secure location for the data centres and 
to harmonise the scope of the cybersecurity projects. As for the loans part, measure 
C1.2 has been amended to reflect a better alternative by adjusting its scope to the 
identified  needs,  while  measure  C1.2.1  has  been  removed  as  the  change  in 
parameters for the auction of one of the bands pioneering 5G networks resulted in 
the  coverage  obligations  of  the  winners  of  the  planned  auction  to  cover  the  vast 
majority of Poland by market operators, thus rendering the public investment in this 
field  redundant.  The  Measure  C2.2.1  on  equipping  schools/institutions  with 
adequate  ICT  devices  and  infrastructure  to  improve  the  overall  performance  of 
education system has been amended to provide a greater flexibility in the selection 
of the IT equipment for teachers. The investment on high-speed internet connection 
in  schools  is  transferred  from  the  loan  part  (measure  C2.2.1)  to  the  grant  part 
(C1.1.1). The modified RRP also includes a new digital measure, to be implemented 
via  a  financial  instrument,  related  to  supporting  the  digital  transformation  of 
businesses through the use of cloud computing (C4.1.1). 

•  Component  D  (Effectiveness,  accessibility  and  quality  of  health  system)  is 
modified  by reflecting the influx of Ukrainian  refuges on  certain  hospitals  in  the 
description  of  the  milestone  relative  to  the  restructuring  of  health  services  under 
reform D1.1. In reform D2.1 the target on the number of paramedics who complete 

5 

 
 
 
their  master's  degree  is  decreased  proportionally  which  is  due  to  the  delay  in 
adoption of the relevant acts of law in order to fully reflect the outcome of the public 
consultation.  For  the  same  reason,  the  fulfilment  of  the  target  concerning 
certification of competences of doctors and dentist is postponed. The establishment 
of  the  Centre  for  digitisation  of  medical  documentation,  which  is  a  part  of 
investment  D1.1.2,  is  postponed  for  one  year  (to  Q3  2025)  due  to  supply  chain 
disruptions  that  caused  serious  delays  in  deliveries  of  essential  elements  of  IT 
infrastructure and equipment. Investment D.2.1.1 is changed by adding mentoring 
for graduates of nursing, midwifery and paramedical studies next to mentoring for 
students  of these faculties  to  align the measure  and milestone requirement  to  the 
original  RRP  proposal.  In  addition,  the  breakdown  of  renovated  libraries  and 
dormitories was adjusted to the current needs of universities without changing the 
overall target, hence not affecting the level of ambition of the  whole measure.  In 
investment  D3.1.1  the  number  of  additional  Clinical  Trial  Support  Centres  is 
reduced due to high inflation. For the same reason, the targets in investment D1.1.1. 
on modernisation of hospitals’ infrastructure are revised downwards. Finally, in the 
loans part, milestone description in investment D1.2.1. to support the transformation 
of  district  hospitals  into  long-term  care  and  geriatric  care  units  is  changed  by 
allowing hospitals to present an equivalent document to the restructuring plan. 

•  Component E (Green, smart mobility) is modified by changing the timeline of the 
implementation of the investment in low and zero-emission buses for use in inter-
urban transport (E1.1.2) due to supply constraints. In investment E1.1.1, the targets 
for the annual production capacity of new zero-emission vehicles, production and 
installed storage capacity (batteries) and number of SMEs and mid-caps supported 
are  revised  downwards  due  to  high  inflation.  For  the  same  reason,  the  targets  in 
investments  E2.1.1  on  the  railway  lines,  E2.1.2  on  the  railway  passenger  rolling 
stock and E2.1.3 on the intermodal projects are reduced. Due to a significant cost 
increase, the investment in single railways passenger ticketing system is removed. 
Freed  up  RRF  resources  are  reallocated  to  two  other  existing  investments  in 
digitalization of transport (E2.2.2).  Finally, in the loan part, targets in investment 
E1.2.1  aimed  at  purchasing  zero-emission  urban  transport  (trams)  are  revised 
downwards to reflect high inflation. Moreover, due to supply chain disruption, the 
reform  under  E3.2  has  been  amended  and  the  investment  in  new  electric  and 
ERTMS-equipped regional trains under E2.3.1 has been removed.  

Component G – REPowerEU chapter 

Under the REPowerEU chapter and based on Article 18 and 21c of the RRF Regulation, Poland 
has  proposed  an  ambitious  set  of  measures,  comprised  of  seven  new  reforms  and  nine 
investments. Within these investments, three are transferred from the initial RRP (of which two 
have been scaled-up) and two are new and different versions of investments removed from the 
initial RRP. These reforms and investments are spread across six sub-components (three related 
to non-repayable financial support and three to repayable financial support):  

6 

 
 
 
-  stimulating  investments  in  renewable  energy  sources  by  empowering  citizens  and 
businesses  to  participate  in  the  clean  energy  transition  and  removing  barriers  to  the 
deployment of renewable energy sources (sub-component G1.1.); 

-  overhauling  the  electricity  grids  to  accelerate  the  integration  of  renewable  energy 

sources (sub-component G1.2.); 

-  developing sustainable transport (sub-component G1.3.); 
- 

improving  renewable  energy  deployment,  green  skills,  and  energy  efficiency  (sub-
component G3.1.);  
improving  energy  infrastructure  and  facilities  to  meet  immediate  security  of  supply 
needs for gas (sub-component G3.2.); and 

- 

-  energy storage system (repayable support) (sub-component G3.3). 

Within these sub-components, the REPowerEU chapter includes a set of reforms intended to 
address  many  facets  of  the  energy  transition.  These  reforms  are  in  line  with  the  objectives 
described in Article 21c(3)(b) of the RRF Regulation (increasing the share and accelerating the 
deployment  of  renewable  energy),  Article  21c(3)(c)  (addressing  energy  poverty),  Article 
21c(3)(e)  (addressing  internal  and  cross-border  energy  transmission  and  distribution 
bottlenecks)  and  Article  21c(3)(f)  (requalifying  the  workforce  towards  green  skills).  These 
reforms concern:  

- 

- 

- 

- 

- 

- 

- 

the streamlining of permitting for RES (G3.1.1.), with the objective of accelerating the 
deployment of RES installations and with a focus on photovoltaic and onshore wind1; 
the removal of barriers to the integration of RES into electricity networks (G1.2.2.), by 
facilitating, in particular, the process of connecting new RES, thereby better integrating 
them into electricity transmission and distribution network; 
the regulatory solutions for accelerated integration of renewables into distribution grids 
(G1.2.1.), with the objective of improving the Energy Regulatory Office’s capacity to 
assess Distribution System  Operators’ development  plans and shape tariffs to  reduce 
barriers to RES development; 
the boosting of energy efficiency and phase-out of fossil fuels in home heating (G3.1.3.), 
in particular by facilitating home renovations; 
the update of key sectoral qualification frameworks (G3.1.2.), to help accommodate the 
growing demand for workers with green skill at the labour market; 
the facilitation of the development of local energy communities (G1.1.1.), by identifying 
barriers hindering the development of these communities; and 
the support to sustainable transport (G1.3.1.), by mandating action plan for the transport 
sector in Poland to reduce emissions of greenhouse gases and air pollutants. 

In parallel, the investments in the REPowerEU chapter accompany these reforms, by financing 
the following investments: 

-  Installations  of  renewable  energy  sources  implemented  by  energy  communities 
(G1.1.2.).  This  investment  shall  consist  of  financial  pre-investment  support  and 

1 The target set in this measure for photovoltaic and onshore wind installations is without prejudice to the 
Commission’s assessment on the updated target in the coming National energy and climate plans (NECPs). 

7 

 
 
 
 
investment support to energy communities and is a scaled-up version of measure B2.2.2. 
in the original RRP. 

-  Non-repayable and loan support to energy storage systems (G1.1.3 and G3.3.1). This 
investment  shall  consist  in  implementing  energy  storage  projects,  with  the  aim  of 
increasing efficiency of the use of RES sources by facilitating electricity balancing in 
the electricity system. 

-  Support  to  institutions  implementing  the  REPowerEU  reforms  and  investments 
(G1.1.4.).  This  is  a  new  investment  that  aims  to  provide  financial  support  to  the 
institutions responsible for the implementation of the chapter.  

-  The development  of transmission  networks, smart  electricity infrastructure (G1.2.3.). 
This investment shall consist of the development of transmission lines, along with the 
construction  or  modernisation  of  relevant  stations  and  the  implementation  of 
information technology systems required for their operation. This measure was scaled-
up compared to investment B2.2.1 included in the original RRP.  

-  The construction or modernisation of electricity distribution networks in rural areas to 
enable the connection of new renewable energy sources (G1.2.4.). This new investment 
shall consist of the extension, modernisation, and digitalisation of distribution networks 
in rural areas, with a view to enabling the connection of new renewable energy sources 
in these areas. 

-  The purchase of zero-emission buses for urban transport (G1.3.2.). This is an investment 
that consists of transfer of part of measure E1.1.2 from the original RRP, on the basis 
of  Article  21c(2)  of  the  RRF  Regulation  and  following  the  decrease  in  Poland’s 
maximum financial contribution. 

-  Support to the national energy system, via the Energy Support Fund (G3.1.4.). This new 
investment  shall  consist  of  financial  support  in  the  form  of  loans  provided  by  Bank 
Gospodarstwa  Krajowego  (BGK)  to  the  private  sector  and  households,  as  well  as  to 
public  sector  entities  engaged  in  similar  activities,  in  order  to  incentivize  private 
investment and improve access to finance in the sectors of the Polish economy directly 
bearing the costs of the energy transition.  

-  A public investment in a facility, in order to incentivize private investment and improve 
access to finance in Poland’s offshore wind energy sector (G3.1.5.). This investment 
shall consist of financial support in the form of loans, provided by an Offshore Wind 
Energy Fund managed by BGK, for the development of offshore wind farm projects. 
-  Finally, the investments include the construction of natural gas infrastructure (G3.2.1.), 
specifically a 250 km extension of the gas transmission network between Gdańsk and 
Gustorzyn,  which  improves  energy  infrastructure  and  facilities  to  meet  immediate 
security  of  supply  needs  for  gas,  including  liquified  natural  gas,  notably  to  enable 
diversification of supply in the interest of the Union as a whole (thereby contributing to 
the objective set out in Article 21c(3)(a)). 

Together, these reforms and investments are expected to increase the resilience, security, and 
sustainability of the Union energy system, notably by contributing to energy security, to the 
necessary reduction of dependence on fossil fuels before 2030, and to the diversification of the 
Union’s energy supply, as further explained in section 3.12 below. 

8 

 
 
 
Table 1: New and modified components and associated costs. 

Component  

Status 

Costs (EUR million) 

A - Resilience and competitiveness of the economy  

B - Green energy and energy intensity reduction  

C - Digital transformation  

Modified 

Modified 

Modified 

D - Efficiency, accessibility and quality of the health system   Modified 

E – Green, smart mobility  

G - REPowerEU  

Modified 

New 

4 395 

15 370 

3 940 

4 381 

6 457 

25 276 

2.3. Other elements not covered by assessment criteria  

The previous description of the Polish RRP’s focus on gender equality and equal opportunities 
for  all,  as  set  out  in  the  previous  Staff  Working  Document  SWD(2022)  161  final,  remains 
relevant.  Poland  has  explained  that  several  new/REPowerEU  measures  will  have  a  positive 
impact on gender equality and equal opportunities for all. Poland notably explained that the 
horizontal criterion for the selection of investments, concerning compliance with the principles 
of  equal  opportunities  and  non-discrimination  and  equal  opportunities  for  women  and  men, 
shall  be  maintained  and  that  it  is  checked  that  the  project  does  not  restrict  equal  access  to 
resources (goods, services, infrastructure) on the grounds of sex, racial or ethnic origin, religion 
or belief, disability, age or sexual orientation. 

State  aid  and  competition  rules  fully  apply  to  the  measures  funded  by  the  Recovery  and 
Resilience Facility. Union funds channelled through the authorities of Member States, like the 
RRF funds, become State resources and can constitute State aid. When this is the case and State 
aid  is  present,  these  measures  must  be  notified  and  approved  by  the  Commission  before 
Member States can grant the aid, unless those measures are covered by an existing aid scheme 
or  comply  with  the  applicable  conditions  of  a  block  exemption  regulation,  in  particular  the 
General Block Exemption Regulation (GBER) declaring certain categories of aid compatible 
with the internal market in application of Articles 107 and 108 TFEU2. When State aid is present 
and it requires notification, it is the duty of the Member State to notify State aid measures to 
the Commission before granting them, in compliance with Article 108(3) TFEU. In this respect, 
the  State  aid  analysis  carried  out  by  Poland  in  the  RRP  cannot  be  deemed  a  State  aid 
notification. In as far as Poland considers that a specific measure contained in the RRP entails 
de minimis aid  or aid  exempted from  the notification requirement, it is the responsibility of 
Poland to ensure full compliance with the applicable rules. 

2 Commission Regulation (EU) 2023/1315 of 23 June 2023 amending Regulation (EU) No 651/2014 declaring 
certain categories of aid compatible with the internal market in application of Articles 107 and 108 of the Treaty 
and Regulation (EU) 2022/2473 declaring certain categories of aid to undertakings active in the production, 
processing and marketing of fishery and aquaculture products compatible with the internal market in application 
of Articles 107 and 108 of the Treaty, OJ L 167, 30.6.2023, p. 1–90, available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1315. 

9 

 
 
 
3.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

3.1. Comprehensive  and  adequately  balanced  response  to  the  economic  and  social 

situation 

The  modifications  to  Poland’s  RRP  do  not  affect  the  previous  positive  assessment,  which 
concluded that the RRP is a comprehensive and adequately balanced response to the country’s 
economic and social situation. The update of the Polish RRP makes use of non- repayable and 
loan support in line with the increased need of a stronger response to the renewed economic 
challenges.  The  economic  and  social  consequences  of  COVID-19  crisis  have  been  further 
aggravated by Russian’s unprovoked military aggression on Ukraine and the consequent energy 
crisis, which led to a significant increase in inflation (HICP in Poland reaching 13.2% in 2022, 
one of the highest in EU). This contributed to further challenges in terms of achieving the green 
and digital transition, maintaining a social equity when confronted with the high inflation and 
ensuring further economic growth.  

As  a  result,  the  update  of  the  plan  modifies  several  existing  components  and  adding  new 
measures which address all the six pillars of the facility, including: (i) green transition due to 
the REPowerEU chapter, (ii) social and territorial cohesion with the revised measure B3.4.1 
Investing  for  the  green  transition  of  cities  and  a  new  measure  G1.2.4.  Construction  or 
modernisation of electricity distribution networks in rural areas to enable the connection of 
new RES sources, (iii) smart, sustainable & inclusive growth addressed in a revised measure 
A2.5.1 Programme to support the activities of cultural and creative operators to stimulate their 
development, (iv) Policies  for the next  generation addressed in  an  extended  measure A4.2.1 
Support  to  childcare  facilities  for  children  up  to  three  years  old  (crèches,  children’s  clubs) 
under the MALUCH+ programme, (v) Health, and economic, social and institutional resilience 
addressed in the increased measure A1.4.1 Investments to diversify and shorten the supply chain 
of agricultural and food products and build the resilience of the entities in the chain, and (vi) 
Digital  transformation  addressed  in  a  new  measure  C4.1.1  Supporting  the  digital 
transformation of businesses using cloud computing (new investment). 

Table 2: Coverage of the six pillars of the Facility by the new or modified RRP components 

Green 
transition 

Digital 
transformation 

Smart, 
sustainable 
& inclusive 
growth 

Social 
and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutiona
l resilience 

Policies for 
the next 
generation 

-  Resilience 

A 
competitiveness  of 
economy 

and 
the 

B  -  Green  energy  and 
energy 
intensity 
reduction 

C 
transformation 

- 

Digital 

○ 

● 

○ 

○ 

● 

● 

○ 

○ 

○ 

 ○ 

○ 

○ 

○ 

10 

 
 
  
  
  
  
  
  
  
  
  
Green 
transition 

Digital 
transformation 

Smart, 
sustainable 
& inclusive 
growth 

Social 
and 
territorial 
cohesion 

Health, and 
economic, 
social and 
institutiona
l resilience 

Policies for 
the next 
generation 

- 

D 
Efficiency, 
accessibility  and  quality 
of the health system 

E – Green, smart mobility 

● 

○ 

○ 

F – Improving the quality 
of  institutions  and  the 
the 
conditions 
the 
implementation  of 
RRP 
the 
(not  under 
revision) 

for 

○ 

○ 

○ 

○ 

● 

○ 

G - REPowerEU 

 ● 

○ 

● 

 ○ 

○ 

○ 

Key:  “●”  investments  and  reforms  of  the  component  significantly  contribute  to  the  pillar;  “○”  the  component  partially 
contributes to the pillar 

Taking into consideration all reforms and investments envisaged by Poland, its modified RRP 
continues to represent, to a large extent, a comprehensive and adequately balanced response 
to  the  economic  and  social  situation,  thereby  contributing  appropriately  to  all  six  pillars 
referred to in Article 3 of the RRF Regulation, taking the specific challenges and the financial 
allocation  of  Poland  into  account.  This  would  warrant  a  rating  of  A  under  criterion  2.1  in 
Annex V to the RRF Regulation. 

3.2. Link with country-specific recommendations and the European Semester  

The RRP addendum together with the REPowerEU addresses a significant subset of Country-
Specific Recommendations identified in the European Semester. The modified plan includes 
several  targeted  changes  to  Poland’s  original  RRP  that  do  not  undermine  the  level  of  the 
ambition of the reform agenda for Poland and therefore do not affect the previous assessment 
of  the  coverage  of  a  significant  subset  of  the  challenges  identified  in  the  country-specific 
recommendations  (CSRs)  2020  and  2019.  In  particular,  Poland  continues  its  effort  to  make 
public spending more efficient, increase labour market participation and effective retirement 
age, address labour market segmentation, provide more childcare and long-term care places, 
promote  the  sustainability  of  transport,  improve  digital  skills  and  promote  the  digital 
transformation of companies and public administration. 

Furthermore, as the maximum financial contribution for Poland has been adjusted downwards 
and  the  loan  requested  is  only  intended  to  be  used  for  REPowerEU  objectives  or  energy 
measures  of  the  current  plan,  the  2022  and  2023  recommendations  not  related  to  energy 
challenges are not considered in the overall assessment.  

11 

 
 
  
  
  
  
  
  
  
  
 
  
 
 
On  14  July  2023,  the  Council  recommended  Poland  to  take  action  in  several  energy  policy 
areas. Since the progress over the energy-related CSRs from 2022 was assessed as limited, 2023 
CSRs were mostly repeated from 2022. Poland was recommended to accelerate the phase-out 
of fossil fuels (2023 CSR 4.1 and 2022 CSR 6.1.) and (accelerate) the deployment of renewable 
energy. It was recommended to reform the legal framework for grid connection permitting and 
for  renewable  energy  sources,  including  energy  communities,  biomethane  and  renewable 
hydrogen  (2023  CSR  4.2.  and  2022  CSR  6.2).  Moreover,  Poland  was  recommended  to 
implement measures to promote energy savings and gas demand reductions as well as scale up 
investment in energy efficiency for buildings and decarbonise the heat supply in district heating 
to address energy poverty (2023 CSR 4.3. and 2022 CSR 6.3). In addition, CSRs recommend 
to  further  promote  sustainable  public  transport  modes  (2023  CSR  4.4.  and  2022  CSR  6.4). 
Finally,  Poland  was  recommended  to  step  up  policy  efforts  aimed  at  the  provision  and 
acquisition of skills and competences needed for the green transition (2023 CSR 4.5).  

The  REPowerEU  chapter  includes  an  extensive  set  of  mutually  reinforcing  reforms  and 
investments that contribute to effectively addressing significant subset of the energy challenges 
identified  in  the  relevant  2022  and  2023  country-specific  recommendations  for  Poland. 
Reducing  overall  reliance  on  fossil  fuels  by  accelerating  the  deployment  of  renewables, 
including through further streamlining permit procedures and making grid access easier (CSR 
4.1 2023, CSR 4.2 2023 and CSR 6.1 2022 and CSR 6.2 2022) is addressed by several reforms 
starting  with  identifying  barriers  hindering  the  development  of  local  energy  communities, 
followed by establishing a legal framework for the connection of multiple renewable energy 
sources  to  a  single  connection  point  (cable  pooling)  as  well  as  making  the  reservation  of 
capacity  and  the  connection  of  renewable  energy  sources  to  electricity  networks  less 
burdensome  and  more  efficient.  Furthermore,  a  new  regulatory  model  will  be  adopted  that 
enables the national energy regulator to better assess the needs of the distribution grid and plan 
its  development.  The  permitting  process  for  renewables  will  be  streamlined  through  the 
mapping of renewable energy potential, the acceleration of permitting procedures relevant to 
photovoltaic and onshore wind installations and the setting up of an IT platform with a single 
digital  framework  for  permitting  procedures.  These  reforms  will  be  combined  with  the 
investments support to energy communities, construction of a large-scale battery energy storage 
system (BESS), modernise and digitalise the transmission and distribution networks in several 
regions  and  construction  of  offshore  wind  farms.  The  Energy  Support  Fund  will  mobilise 
private investment and improve access to finance in the sectors of the Polish economy directly 
bearing  the  costs  of  the  energy  transition,  which  is  expected  to  contribute  to  expand  public 
investment for the green transition (CSR 1.2, 2022 and CSR 1.3 2023). 

In  order  to  scale  up  investment  in  energy  efficiency  for  buildings  and  decarbonise  the  heat 
supply in district heating to address energy poverty (CSR 6.3. 2022 and CSR 4.3. 2023) the 
REPowerEU  chapter  provides  for  the  adoption  of  a  new  priority  programme  to  support 
integrated home renovation services. 

To promote more sustainable public transport (CSR 4.4 2023) and uptake of electric vehicles 
(CSR  6.4.  2022)  the  component  includes  measures  for  replacing  polluting  urban  public 
transport vehicles with zero-emissions vehicles and through the adoption of an action plan for 
green transport in line with EU climate objectives.  

12 

 
Finally, the reform that reviews sectoral qualification frameworks in sectors key for the green 
transition is expected to boost the acquisition of green skills according to the unified standards 
(CSR 4.5 2023).  

Taking into consideration the reforms and investments envisaged by Poland its modified RRP 
is  expected  to  contribute  to  effectively  addressing  all  or  a  significant  subset  of  challenges 
identified in the country-specific recommendations, or challenges in other relevant documents 
officially  adopted  by  the  Commission  under  the  European  Semester,  and  the  modified  RRP 
represents a partially adequate response to the economic and social situation of Poland. This 
would warrant a rating of A under criterion 2.2 in Annex V to the RRF Regulation. 

3.3. Growth  potential,  job  creation,  economic,  institutional  and  social  resilience, 
European Pillar of Social Rights, mitigating the impact of the crisis, and social 
territorial cohesion and convergence  

The modified RRP continues to address social and territorial challenges relevant for Poland and 
contributes to the implementation of the European Pillar of Social Rights. Likewise, the scope 
of the modified measures does not affect the positive assessment of the Commission that the 
Plan contribute to alleviate social and territorial disparities. 

The  REPowerEU  chapter  includes  additional  resources  in  the  area  of  energy,  through 
investments  to  extend  and  modernise  transmission  infrastructure  as  well  as  to  develop 
distribution  networks  in  rural  areas,  to  accelerate  the  pace  of  the  energy  transition  while 
bringing  further  regional  economic  development.  This  chapter  also  includes  a  reform  and 
investment  related  to  energy  communities,  in  particular  with  the  objective  of  improving  the 
regulatory environment for such communities and the potential use of renewable energy sources 
by such communities at local level. The REPowerEU measures also include reforms aiming to 
accommodate the growing demand for green jobs and to accelerate home renovations with a 
view to boosting energy efficiency. In addition, Poland also commits to make transport more 
sustainable, notably by investing in zero-emission buses in cities. 

In view of reforms and investments put forward as part of the amendment of the RRP, the initial 
positive assessment of the impact of the plan on growth potential, job creation, and territorial 
and social cohesion, remains unchanged.  

Poland  updated  its  estimate  of  the  expected  impact  of  the  plan  on  the  growth  potential,  job 
creation and investment. The short-term impact until 2025 estimated by Poland does not take 
into account measures of the REPowerEU chapter. In 2025, the level of GDP is projected to be 
2.0%  higher  and  the  number  of  jobs  created  to  increase  by  0.3%  compared  to  the  baseline 
scenario without the implementation of the RRP. The long-term estimates include the effects 
of the plan as well as the REPowerEU chapter. In 2040, Poland’s real GDP is set to be 2.6 % 
higher than in the baseline scenario.  

Model  simulations  conducted  by  the  Commission  using  the  QUEST  model  show  that  the 
economic impact of the NGEU in Poland could lead to an increase of GDP of 2.3% by 2026 of 
which 0.7 percentage point GDP is generated by additional requested loans of EUR 23 bn. After 
20  years,  GDP  could  be  0.7%  higher.  This  stylised  scenario  does  not  include  the  possible 

13 

 
 
positive impact of structural reforms. Hence, the results of this stylised assessment cannot be 
directly compared to the numbers reported by Poland. 

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of A) of the plan’s impact on the growth potential, 
job  creation,  and  economic,  social  and  institutional  resilience  of  the  Member  State,  on 
contributing to the implementation of the European Pillar of Social Rights, including through 
the promotion of policies for children and youth, and on mitigating the economic and social 
impact of the COVID-19 crisis, thereby enhancing the economic, social and territorial cohesion 
and convergence within the Union.  

3.4. The principle of ‘do no significant harm’  

The modifications of the measures included in the RRP do not  affect their previous positive 
assessment regarding the principle of ‘do no significant harm’.  

Poland’s REPowerEU chapter includes a systematic assessment of each measure against the 
principle  of  ‘do  no  significant  harm’  (DNSH),  for  each  of  the  six  environmental  objectives 
within the meaning of Article 17 of the Taxonomy Regulation. Poland’s self-assessment often 
stresses  the  environmental  and  climate  benefits  of  measures,  it  also  provides  information 
allowing to assess that measures will comply with the ‘do no significant harm’ principle – for 
instance  by  providing  reassurance  that  the  implementation  of  the  existing  EU  and  Polish 
legislative framework will prevent any significant harm, or by indicating that any measure that 
could have had a significant impact carved out from funding under the Recovery and Resilience 
Facility.  

For  financial  instruments,  where  it  is  not  known  ex-ante  which  projects  are  to  be  financed, 
adherence  with  the  ‘do  no  significant  harm’  principle  is  ensured  by  introducing  specific 
safeguards in the measure description and in the related milestones and targets, to monitor the 
implementation  of  the  measures.  This  is  of  relevance  for  instance  for  the  new  financial 
instrument  under component  G on  loans to  enterprises to  support the energy transition. The 
Plan includes one measure for which, in accordance with Article 21c(6) of Regulation (EU) 
2021/241  the  principle  of  “do  no  significant  harm”  does  not  apply,  i.e.,  investment  G3.2.1. 
“Construction  of  natural  gas  infrastructure  to  ensure  energy  security”,  which  includes  the 
construction  and  commissioning  of  250  kilometres  gas  pipeline  between  Gdańsk  and 
Gustorzyn. This measure contributes to the objective set out in Article 21c (3), point (a) of the 
RRF Regulation, notably by enabling diversification of supply in the interest of the Union as a 
whole.  

The Commission considers that the principle of ‘do no significant harm’ does not apply to that 
measure, since it positively assessed that the conditions of Article 21c(6) of the RRF Regulation 
have been met: 

The  measure  is  necessary  and  proportionate  to  meet  immediate  security  of  supply  needs, 
taking into account cleaner feasible alternatives and the risk of lock-in effects. 

14 

 
 
The new onshore pipeline should have a maximum capacity of up to 1 320 000 m3/h and should 
allow to  diversify gas  supplies to  improve  the security  of supply of Poland and Central  and 
Eastern Europe.  

The demand for gas in the region (in particular Slovakia, the Czech Republic and Hungary) is 
42.8 bcm/y, including 19.5 bcm/y for Poland. The region has traditionally been characterized 
by  a  high  dependence  on  a  single  gas  source  of  supply  (i.e.,  Russia)  and  still  has  limited 
opportunities  to  diversify.  As  of  its  commissioning,  the  pipeline  will  increase  transmission 
possibilities in Poland and towards the Polish-Slovak interconnector and, beyond, to the region. 
The pipeline will create additional transport routes and relieve congested existing infrastructure, 
allowing the transmission of additional capacities from diversified sources. It would improve 
the transmission of gas from the Świnoujscie LNG terminal (the enhancement planned for 2024 
would bring additional up to 2.1 bcm/y of natural gas), the gas from the Klaipeda LNG terminal 
in Lithuania arriving to Poland through the Interconnector Lithuania-Poland, the gas imported 
from Germany, as well as the optimisation of the transportation routes from the existing Baltic 
Pipe  (currently  available  capacity  of  10  bcm/y).  An  additional  6.1  bcm/y  of  diversified  gas 
would be brought by the future Floating and Storage Regasification Unit in Gdańsk in 2027. 

Without  the  construction  of  the  Gdansk-Gustorzyn  pipeline,  it  would  not  be  possible  to 
maximize the utilisation of the above-mentioned capacities due to the bottlenecks in the Polish 
grid. Firstly, the existing North-South gas corridor in western Poland currently serves as the 
main  route  for  dispatching  non-Russian  gas  from  Świnoujscie  LNG  terminal  and  the  Baltic 
Pipe, but it faces significant capacity constraints (i.e. limited possibility to inject more gas). 
Secondly,  the  existing  infrastructure  between  Gdańsk  and  Gustorzyn  only  allows  to  supply 
customers in this region and has a very limited capacity (Diametre Nominal 400 and Diametre 
Nominal  500).  The  planned  Gdańsk-Gustorzyn  pipeline  would  bring  significant  additional 
capacities that can transmit significant volumes of gas from the diversified sources mentioned 
above to Poland and its neighbours, namely Slovakia, Czechia, Hungary and Baltic States. The 
pipeline, together with other completed and ongoing projects (such as Gustorzyn-Wronów and 
Wronów-Strachocina)  is  part  of  the  emerging  North-South  corridor  in  eastern  Poland,  an 
important  alternative transportation corridor in  Poland which aim is  to  decrease the region's 
dependence on a single natural gas supplier, open access to new supply sources for Central-
Eastern and South-Eastern Europe, and increase integration of regional gas markets. Therefore, 
the investment is considered necessary to meet immediate security of supply needs. 

The investment in the pipeline is limited, while it brings significant security of supply benefits 
to the region and ensures that additional capacities in the Polish grid are available to ensure full 
capacity  on  the  Polish-Slovakia  interconnector.  The  new  pipeline  is  also  adequately 
dimensioned (Diametre Nominal 1000) to ensure effective transmission of all available sources 
and necessary flexibility in transmission management. Therefore, the investment is considered 
proportionate to meet security of supply needs.  

As  regards  cleaner  alternatives,  the  production  or  import  of  green  hydrogen  cannot  be 
considered  a  technologically  and  economically  feasible  alternative  that  could  be  deployed 
within  a  comparable  timeline,  by  end  2026.  The  transmission  part  of  the  project  will  be 
technically capable of accommodating hydrogen blends and biomethane and synthetic methane 
from the start of the operations. Therefore, the risk of lock-in effect is considered mitigated 
since the measure can be considered future-proof. 

15 

 
In light of the above, the Commission considers that the measure is necessary and proportionate 
to meet immediate security of supply needs, taking into account cleaner feasible alternatives 
and the risk of lock-in effects, in line with Article 21c(6), point (a) of the RRF Regulation. 

The  Member  State  has  undertaken  satisfactory  efforts  to  limit  the  potential  harm  to 
environmental objectives where feasible and to mitigate harm through other measures 

The results of the relevant environmental impact assessments and the environmental decisions 
issued  by  the  Regional  Directorate  of  Environmental  Protection  in  Gdańsk  regarding  the 
Gdańsk -Gustorzyn pipeline confirm that the project will be implemented within the applicable 
EU and national environmental legal framework. Mitigation measures have been imposed by 
the environmental decision in relation to biodiversity protection (including Natura 2000 sites) 
and protection of water bodies (in particular during construction phase). Additional measures 
relate to soil protection. The environmental decision for a large part of the project states that 
the investment is 'climate-proof' meaning resistant to risks (e.g., landslides) related to climate 
change  and  the  decision  puts  an  obligation  on  the  investor  that  the  investment  must  not 
contaminate water or soil in case of flooding. Given the nature of the measure, it is not feasible 
to take fully into account the climate mitigation and climate adaptation objectives.  

Based on the analysis of the supporting documents provided by Poland, and taking into account 
that no other measure, including the other measures in the REPowerEU chapter, is expected to 
do  a  significant  harm  to  environmental  objectives  within  the  meaning  of  Article  17  of 
Regulation (EU) No 2020/852, the Commission considers that satisfactory efforts have been 
undertaken to limit the potential harm to environmental objectives, where feasible, in line with 
Article 21c(6), point (b) of the RRF Regulation. 

The measure does not jeopardise the achievement of the Union’s 2030 climate targets and 
the objective of EU climate neutrality by 2050 

The Gdańsk-Gustorzyn pipeline will contribute to replacing carbon-intensive fuels, in particular 
coal; support the increase in the use of renewable energy sources by providing a  back-up to 
stabilise  electricity  and  heat  supply;  contribute  to  reducing  air  pollution  resulting  from  the 
combustion of high-carbon and low-quality fuels, especially during the winter period.  

In  addition,  the  modified  RRP,  including  the  REPowerEU  chapter,  contains  reforms  and 
investments to promote energy efficiency, renewable energy, and sustainable mobility, all of 
which are expected to contribute to the achievement of the Union climate target by 2030 and 
climate neutrality by 2050. 

In  light  of  the  above,  the  Commission  considers  that  the  measure  does  not  jeopardise  the 
achievement of the Union’s 2030 climate targets and the objective of EU climate neutrality by 
2050, in line with Article 21c(6), point (c) of the RRF Regulation. 

The measure is planned to be in operation by 31 December 2026 

According to the supporting documents provided by Poland, the end of the construction works 
and the technical acceptance of the pipeline between Gdańsk and Gustorzyn should take place 
in June 2026 and the infrastructure is planned to be in operation by 31 December 2026, in line 
with Article 21c(6), point (d) of the RRF Regulation. 

16 

 
The total estimated cost of this measure is EUR 630 940 000 million. 

Taking into consideration the assessment of all the measures envisaged, no measure for the 
implementation  of  reforms  and  investments  projects  included  in  Poland’s  modified  RRP, 
including  its  REPowerEU  chapter,  is  expected  to  do  significant  harm  to  environmental 
objectives within the meaning of Article 17 of Regulation (EU) No 2020/852 (the principle of 
‘do no significant harm’). This would warrant a rating of A under criterion 2.4 of Annex V to 
the RRF Regulation. 

3.5. Green transition 

Climate target  

The modified RRP of Poland correctly follows the methodology for climate tagging set out in 
Annex  VI  to  the  RRF  regulation,  by  identifying  intervention  fields,  and  corresponding 
coefficients for the calculation of support to the climate objectives, for each measure (the table 
in Annex I presents the detailed application of the climate tagging methodology). It should be 
noted that:  

a.  the tagging and the estimated expenditure of existing measures was not modified, with the 
exception  of  measure  B2.1.1  (investment  in  hydrogen,  hydrogen  manufacturing,  storage 
and transport) due to the changes introduced in the measure, the subsequent assessment that 
a climate tagging per sub-investment was needed and the amendment in order to not tag the 
production  of  low-carbon  hydrogen  and  of  measure  B3.4.1  (investing  for  the  green 
transition of cities) due to the introduction of new activities covered by the fund and the 
scale-up of the fund.  

b.  For the new measures of the modified plan:  

-  The choice of intervention fields for the green transition is well justified and it reflects 
the  nature,  focus,  objective,  or  expected  outcome  of  the  investments  included  in  the 
component.  

-  The modified plan does not propose to increase the climate coefficients of the selected 
intervention fields for any measure but proposes to split the climate coefficients further 
for B2.1.1 (investment in hydrogen, hydrogen manufacturing, storage and transport) and 
to apply new intervention fields to the scale-up part of B3.4.1 (investing for the green 
transition  of  cities).  The  modified  Polish  plan  includes  measures  supporting  climate 
objectives for an amount representing 46.6% of the total plan’s allocation in the form 
of  loan  and  non-repayable  financial  contribution,  including  the  allocations  of  the 
REPowerEU chapter. 

Measures supporting climate change objectives represent 66% of the total estimated costs of 
measures in the REPowerEU chapter, according to the methodology for climate tracking set out 
in Annex VI to the RRF Regulation. All measures in the REPowerEU chapter have received a 
climate tag of 100%, except for the measure to build natural gas infrastructure (G3.2.1) which 
is subject to a DNSH derogation and therefore has a 0% climate tag, the energy fund (G3.1.4) 
which is  only  partially tagged due to  the broad scope of the activities covered  and complex 

17 

 
 
investment  lines  and  investment  G1.2.1  to  support  institutions  implementing  REPowerEU 
reforms which is not tagged. Therefore, the climate change contribution of the total plan, as 
well as of the REPowerEU, exceeds the minimum climate target of 37%.  

The climate change contribution for each of the components of the plan is set out in Table 3 
below.  The  largest  contributions  come  from  REPowerEU  (27.7%  of  the  overall  climate 
contribution) and component B ‘Green energy and energy-intensity reduction’ (10.2% of the 
overall climate contribution).  

Table 3. Climate contribution by component  

Budget 
(EUR m)  

Climate contribution 
(EUR m) 

Climate contribution as 
percentage of the total 
budget of the plan  

4 395 

80.7     

0.1%  

C1. A - Resilience and competitiveness 
of the economy 

C2. B - Green energy and reduction of 
energy intensity 

C3. C - Digital transformation 

C4. D - Effectiveness, availability and 
quality of the health care system 

15 370 

3 940 

4381 

C5. E- Green and smart mobility 

6 456    

C6. F- Improving the quality of 
institutions and the conditions for the 
implementation of the RRP  

C7. G – REPowerEU  

Total  

0  

25 276 

59 818 

6 093 

74  

0  

5059 

0  

16 551 

27 858  

10.2%  

0.12%  

0.0%  

8.5%  

0.0%  

27.7% 

46.6% 

Additionally,  with  the  REPowerEU  chapter,  Poland  responds  to  the  REPowerEU  objectives 
and  increases  its  ambitions  regarding  the  green  transition,  overall  compensating  for  the 
withdrawn  or  reduced  measures  (in  comparison  to  the  original  RRP).  The  modified  RRP 
continues to significantly contribute to the achievement of the Union 2030 climate targets on 
the way to EU climate neutrality by 2050.  

The  REPowerEU  chapter  is  deemed  ambitious  as  regards  the  green  transition,  since  all  the 
reforms and most investments contribute to stimulating the development of renewable energy 
sources,  thereby  reducing  the  reliance  on  fossil  fuels,  to  increasing  energy  efficiency,  and 
generally  to  improving  the  regulatory  framework  enabling  the  fight  against  climate  change. 
Notable green investments included in the REPowerEU chapter concern the development of 

18 

 
 
 
  
 
 
 
 
 
transmission  and  distribution  networks  and  financial  support  to  green  projects  through  an 
Energy  Support  Fund  and,  as  regards  specifically  offshore  wind  farms,  an  Offshore  Wind 
Energy Fund. 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  modified  RRP, 
including  its  REPowerEU  chapter,  is  expected,  to  a  large  extent,  to  make  a  significant 
contribution to the green transition or to address the challenges resulting from it and ensures 
that at least 37% of its total allocation contribute to the climate target. At least 37% of the total 
estimated costs of the REPowerEU chapter contribute to the climate target. This would warrant 
a rating of A under criterion 2.5 of Annex V to the RRF Regulation. 

3.6. Digital transition 

The modification of the RRP did not impact its ambition towards the digital transition as well 
as the initial assessment. The modified RRP continues to significantly contribute to the digital 
transition  with  interventions  in  e-services  in  the  public  administration,  digitalisation  of 
education,  development  of  digital  skills  and  cybersecurity.  Thus,  the  implementation  of  the 
envisaged  measures  as  set  out  in  the  modified  RRP  is  expected  to  continue  to  significantly 
contribute to addressing the challenges resulting from the digital transition and have a lasting 
impact. 

The measures withdrawn or reduced do not impact the overall ambition of the plan regarding 
the digital transition. The modifications are justified by cost increases for certain measures (e.g. 
the development of e-competences), while several measures are revised to cater for identified 
better  alternatives  (e.g.  equipping  schools/institutions  with  adequate  ICT  devices  and 
infrastructure to improve the overall performance of education system or increasing the level 
of accessibility and use of modern wired and wireless communication for social and economic 
needs)  or  due  to  technical  difficulties  (e.g.  public  e-services,  IT  solutions  improving  the 
functioning of administrations and economic sectors). A new investment to support the use of 
cloud technologies by enterprises is also included in the modified RRP. 

Hence,  the  contribution  to  the  digital  transition  of  the  modified  RRP  (excluding  the 
REPowerEU chapter) stands at 21.3% (EUR 7 379 000 000), which is above the required target 
of  20%  established  by  the  RRF  Regulation.  Several  of  the  measures  included  in  the 
REPowerEU chapter were identified as contributing to the digital transition, including but not 
limited to the development of transmission networks, smart electricity infrastructure (G1.2.3.) 
and the streamlining of permitting for RES (G3.1.1.). 

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of A) of the contribution of the plan to the digital 
transition and to the digital target. 

19 

 
 
Table 4: Digital contribution of the components of the Polish RRP 

Component 

Cost (EUR 
million) 

Digital 
contribution 
(EUR million) 

Digital 
contribution 
(% of total 
cost) 

A - Resilience and competitiveness of the economy 

B - Green energy and energy intensity reduction 

C - Digital transformation 

D  -  Efficiency,  accessibility  and  quality  of  the 
health system 

E - Green, smart mobility 

F  -  Improving  the  quality  of  institutions  and  the 
conditions for the implementation of the RRP 

4 
395 

15 370 

3 
940 

438
1 

6 456 

0 

877 

1 300 

2.5% 

3.8% 

3 861 

11.1% 

1 000 

2.9% 

341 

- 

1% 

- 

Total 

59 818 

7 379 

21.3% 

3.7. Lasting impact of the plan 

With  the  modified  RRP,  the  implementation  of  the  envisaged  reforms  and  investments  is 
expected to stay on its course and deliver lasting structural changes. The modified RRP plan 
does not reduce the ambition of the initial plan as a whole. It takes into account the prolonged 
impact of the COVID-19 crisis, higher inflation and supply chain disruptions, as well as some 
unexpected  legal  or  technical  difficulties  or  the  availability  of  better  alternatives  for  the 
implementation of some measures by modifying measures in accordance with Article 21(2) of 
the RRF Regulation.  

It also includes new and scaled-up measures as a result of the significant increase in the up-take 
of  loans  and  includes  a  new  REPowerEU  chapter.  The  REPowerEU  chapter  contains  new 
reforms  as  well  as  new  and  scaled-up  investments  expected  to  increase  the  deployment  of 
renewable  energy  sources,  including  via  an  expanded  and  modernised  electricity  grid,  to 
facilitate  the  development  of  technologies  for  the  energy  transition,  and  to  diversify  energy 
supplies. These additional measures, together with the existing measures, are expected to have 
lasting positive effects on the Polish economy and further boost its green and digital transition. 

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of A) of the lasting impact of the measures proposed 
by Poland. 

20 

 
 
 
 
 
 
 
3.8. Milestones, targets, monitoring and implementation 

The milestones and targets of the modified Polish RRP enable an adequate monitoring of the 
plan’s  implementation.  Each  of  the  new  reforms  and  investments  introduced  under  the  new 
REPowerEU chapter includes at least one target and/or milestone that contains the key elements 
of  the  measure  and  allows  for  the  assessment  of  the  achievement  of  its  objectives.  The 
REPowerEU  chapter  includes  a  set  of  31  new  milestones  and  20  targets  (reforms  will  be 
monitored  by  14  milestones  and  2  target,  investments  by  17  milestones  and  18  targets). 
Milestones set for reforms are based on the achievement of decisive steps in the implementation 
process, such as the adoption of revised actions plans and strategies, the entry into force of legal 
acts,  the  entry into operation of digital applications or the publication of evaluation  studies. 
These  milestones  are  clear  and  realistic  as  they  reflect  decisive  steps  towards  the  complete 
implementation of each reform. 

The performance of the investments included in the new and revised components, as well as 
REPowerEU chapter, will be assessed on the basis of the achievement of multiple milestones 
and  targets  monitored  by  each  public  entity  in  charge  of  implementing  the  measures  and 
capturing  the  key  implementation  stages  of  each  investment.  The  targets  chosen  –  some  of 
which build on existing targets, for scaled up measures - are consistent with the objectives, cost 
estimates and implementation schedule of each measure and quantified by specific indicators 
reflecting the result of the works undertaken. 

The adjustments made to the plan’s original milestones and targets under Article 21 of the RRF 
Regulation do not affect the plan’s overall level of ambition and are expected to contribute to 
its timely delivery by addressing current implementation challenges. 

The overall organisational arrangements  remain  unchanged, with  the Ministry of  Funds and 
Regional Policy being responsible for the coordination of implementation of the RRP in Poland. 
The main bodies responsible for implementation of REPowerEU  chapter are the Ministry of 
Climate, the Ministry of Infrastructure, and the Polish national promotional bank (BGK), tasked 
with implementation of EUR 32 182 400 000 in the form of financial instruments.  

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of A) of the adequacy of the arrangements proposed 
by Poland to ensure the effective monitoring and implementation of the plan. 

3.9. Costing 

Poland has provided individual cost estimates for all investments and reforms included in the 
RRP  for  which  funding  through  the  facility  is  requested.  Overall,  for  the  new  or  modified 
measures,  Poland  has  submitted  clear  and  sufficient  evidence  and  explanations  for  the  cost 
estimates to be considered reasonable and plausible and information regarding the additionality 
with other Union funds has also been provided. The costs can be considered commensurate and 
in line with the principle of cost efficiency.  

21 

 
 
Reasonable costs 

Based on the assessment of individual cost estimates and related supporting documents, the cost 
estimates for most of the measures in the plan are deemed reasonable. Measures representing a 
significant majority of the plan are rated as “reasonable” to a “medium” extent. For the majority 
of the new of measures included in the plan, Poland provided clear and sufficient information 
and  evidence  on  costs,  based  on  the  template  tables,  backed  up  by  descriptions  of  the 
methodology used, the cost calculations as well as the budgetary implications of the measure.  

For  the  modified  measures  where  the  revision  had  an  implication  regarding  costs,  Poland 
provided  sufficient  information  and  evidence  of  the  impact  of  the  changes  on  the  costs 
allocated, including adjustments of the unit costs due to the effect of the high inflation or based 
on more recent costs resulting from completed tenders or responses from market actors as well 
as  on  the  proportionality  of  the  relevant  amendments  under  Article  21(1)  of  the  RRF 
Regulation. 

The reforms and investments included in the plan comply with the eligibility criteria set out in 
the Regulation. Based on the information provided by the authorities, costs supported under the 
RRF are incurred only for reforms and investments implemented after 1 February 2020 or 1 
February 2022 for REPowerEU chapter measures, exclude value-added tax (VAT), and do not 
substitute recurring national budgetary expenditure. Costs that could have a recurring nature 
are included in the plan only to a limited extent and for duly justified exceptions, in accordance 
with Article 5(1) of the Regulation. There is no evidence or indication that the costs incurred 
may be incompatible with the eligibility criteria of the RRF. The provided materials generally 
allow for identifying the methodology used in costing calculations, even if for a small number 
of measures this information is missing or not as clear. 

Plausible costs  

Based on the assessment of individual cost estimates and related supporting documents, most 
of the measures in the Polish plan are deemed plausible at least to a medium extent. Measures 
representing a significant majority of the plan are rated as “plausible” to a “medium” extent.  

The amount of the estimated costs of new measures, including those in the REPowerEU chapter, 
is in line with the nature and type of the envisaged reforms and investments. Poland provided 
supporting  documents  and  evidence  to  substantiate  the  cost  estimates  for  most  of  the  new 
measures,  including  those  in  the  REPowerEU  chapter.  For  the  updated  measures  where  the 
revision had an implication regarding costs, the update is plausible when considering the high 
inflation in the sector, or considering the results of tenders conducted for similar projects or the 
project itself in case where the tendering has already started. 

In some cases, adjustments to comparative costs have been made, ensuring the comparability 
of the projects financed under the RRF with past projects. Nevertheless, the exact comparability 
of these projects cannot be established in all instances, in particular, for the case of demand-
driven schemes. 

No double funding 

Poland has indicated that the costs for most individual new and REPowerEU measures will not 
be funded at the same time by other Union funding sources. The commitment to put in place 

22 

 
safeguards which are meant to prevent double funding remains and has not been altered by the 
plan’s modification. 

For the very limited number of measure where other EU financing is envisaged, the name of 
the programme and information on the amounts covered has been provided. In many cases, the 
exact same measure is not covered by other EU funds, but other EU funds provide financing 
for  similar  measures  or  areas  of  intervention.  In  these  cases,  the  authorities  have  provided 
explanation about the complementarity of the projects and information on the delineation was 
provided, based on differences in the timing of the funding or the nature of the intervention. 
For example, RRF financing covers nonrecurrent capital expenditure while other EU funding 
cover non-capital costs like maintenance.  

Commensurate and cost-efficient costs 

The justification provided by Poland on the amount of the estimated total costs of the modified 
RRP  is  to  a  high/medium  extent  reasonable,  plausible,  in  line  with  the  principle  of  cost-
efficiency and is commensurate to the expected national economic and social impact. Poland 
provided  sufficient  information  and  evidence  that  the  amount  of  the  estimated  cost  of  the 
reforms and investments of the modified RRP to be financed under the Facility is not covered 
by existing or planned Union financing. This would warrant a rating of B under criterion 2.9 of 
Annex V to the RRF Regulation. 

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of B) of the reasonability and plausibility of the costs, 
their  additionality,  and  that  they  are  in  line  with  the  principle  of  cost  efficiency  and 
commensurate to the expected social and economic impact of the modified plan. 

3.10. 

Controls and audit  

The  original  assessment  of  the  robustness  and  adequacy  of  the  control  system  and  other 
arrangements included in the RRP had concluded that these arrangements are adequate, taking 
also  into  account  the  milestones  pertaining  to  the  organisation  of  the  judiciary  system  and 
ensuring an effective audit and control. This included a dedicated milestone to ensure that the 
conditions for the systematic and extended use of the functionalities of the Arachne risk-scoring 
tool in the implementation of the Polish plan  is set out, as well as two dedicated reforms to 
ensure, on the one hand, that the independence and impartiality of courts are strengthened and, 
on the other hand, that the situation of judges affected by decisions of the Disciplinary Chamber 
of  the  Supreme  Court  in  disciplinary  cases  and  judicial  immunity  cases  is  remedied  This 
warranted a rating of A under the assessment criterion 2.10 of Annex V to the RRF Regulation. 

The Polish authorities have confirmed that the internal control system, as well as arrangements 
for the prevention, detection and correction of fraud, corruption, conflict of interest and double 
funding as previously assessed remain in place.  

The modifications to the original plan and the introduction of the REPowerEU chapter as such 
do not affect the original assessment. However, in the context of the modification of the Polish 
RRP, its audit and control system need to be reassessed on the basis of criteria 2.10 of Annex 
V to  the RRF Regulation. Since the original  assessment,  the Commission has had access  to 

23 

 
 
information on its actual implementation. This includes the findings of the system audit on the 
protection of the financial interests of the Union performed by the Commission in Poland. In 
light of this information, the Commission considers that the internal control system of the RRP 
is overall adequate.  

Robustness of internal control system and distribution of roles and responsibilities 

The previous assessed arrangements as regards the roles and responsibilities of the actors for 
control and audit, segregation of functions and independence of actors performing audits remain 
adequate. 

Adequacy of control systems and other relevant arrangements 

The control system and other arrangements to prevent, detect and correct fraud, corruption and 
conflicts of interest when using funds provided by RRF continue to appear overall adequate.  

Adequacy of arrangements to avoid double EU funding 

The  previous  assessed  arrangements  as  regards  the  prevention,  detection  and  correction  of 
double funding remain in place as initially assessed by the Commission.  

Legal empowerment and administrative capacity of control function 

Legal mandate of all the institutions involved in implementation, monitoring, audit and control 
has been approved through the adoption of Government’s Resolution no. 56 of 17/05/2021. In 
line  with  this  Resolution,  the  Ministry  of  Funds  and  Regional  Policy  as  coordinating  body, 
exercises all the tasks related to monitoring, verification, control and recovery, drawing up and 
signing  payment  declarations  management  declaration.  The  implementation  of  the  RRP  is 
ensured by line ministries and their subordinated structures, through conclusion of financing 
agreements with the coordinating body. Data on the achievement of milestones and targets shall 
be  recorded  in  the  centralised  national  IT  system  (CST10121),  which  shall  ensure  that  the 
implementing bodies submit the required information to the IT system. Audits are entrusted to 
the National Revenue Administration within the Ministry of Finance. This body will audit the 
implementation  of  the  RRP.  Its  independence  from  the  coordination  body  and  institutions 
responsible for the implementation of the reforms and investments is confirmed. 

The nature and extent of the proposed modifications to Poland’s recovery and resilience plan 
do not have a material impact on the previous assessment (rating of A) of the adequacy of the 
control  and  audit  arrangements  proposed  by  Poland,  as  reflected  in  the  previous 
SWD(2022)161 final approved on 01/06/2022. 

3.11. 

Coherence 

The modified RRP presented by Poland is structured in 7 coherent components that support the 
objective of stimulating the Polish economy and mitigating the socio-economic impact of the 
COVID-19 pandemic, which has been further aggravated by high inflation, energy crisis and 
Russia’s war of aggression against Ukraine. On the top of the original 6 components, Poland 
proposes  an  additional  component:  the  REPowerEU  chapter  that  includes  sixteen  measures. 

24 

 
 
This new component shows synergies with the rest of the plan, in particular those related to the 
green transition. 

Mutually reinforcing measures 

The  modifications  to  the  RRP  do  not  negatively  alter  the  components’  coherence,  nor  the 
coherence of the plan as a whole. There is a good interplay between reforms and investments 
in each component, despite some investments being removed from the Plan, e.g. in the area of 
creative industries or support to investment sites, or some reforms being revised since better 
alternative was found (e.g. in the labour market). They do not alter the way they are mutually-
reinforcing.  The  additional REPowerEU  chapter is fully in  line with  the  measures deployed 
under the initial RRP to support the green transition and further increases their ambition.  

The REPowerEU chapter is built around a consistent package of both reforms and investments 
that are mutually reinforcing and aim to support the modernisation of the electricity grids (both 
distribution and transmission), the generation of renewable energy, the promotion of energy 
efficiency  renovations,  and  supporting  institutions  implementing  REPowerEU  reforms  and 
investments.  The  reforms  in  this  chapter  are  expected  to  reinforce  the  investments  in  the 
REPowerEU chapter, while being in line with measures set out in the original RRP. 

Complementarity of measures 

The modifications made to the existing 6 components of the RRP do not negatively alter the 
complementarity  of  these  components.  The  new  and  updated  components  complement  each 
other and the original ambition of the plan. Firstly, the new measure on the cloud computing 
expands the efforts of the RRP to digitalise entrepreneurs. Moreover, the REPowerEU reforms 
and  investments  complement  the  efforts  of  the  RRP  on  green  transition,  especially  in  RES 
deployment, investments in electricity networks, and support to energy efficiency.  

The plan does not present inconsistencies or contradictions between the different components. 
In order to promote wider coherence across instruments, notably with the European cohesion 
policy funds, a balanced territorial allocation of resources is encouraged. Poland is expected to 
promote coherence and complementarity between RRP and cohesion policy investments by i.a. 
ensuring that clear demarcation lines are applied for similar types of investments.  

The nature and extent of the proposed modifications to Poland’s RRP do not have a material 
impact on the previous assessment (rating of A) of the coherence of the actions proposed by 
Poland. 

3.12. 

REPowerEU 

Poland’s  REPowerEU  chapter  aims  to  contribute  to  a  series  of  the  objectives  listed  in 
Article 21c(3)  of  the  RRF  Regulation.  As  described  in  Poland’s  modified  RRP,  the  main 
objective of the chapter is to increase the resilience of the Polish energy system and to accelerate 
the green transition of key economic sectors. 

More specifically, a combination of reforms and investments in Poland’s REPowerEU chapter 
contributes to the objectives described in Article 21c(3)(b) of the RRF Regulation, notably by 

25 

 
 
aiming  to  increase  the  share  and  accelerate  the  deployment  of  renewable  energy  with  the 
following measures: 

−  Firstly, the reform and investment related to energy communities aim to facilitate the 
deployment  of  renewable  energy  sources  by  such  communities,  by  establishing  an 
enabling, simple and comprehensive framework for and by providing (pre-)investment 
support to energy communities.  

−  Secondly, the REPowerEU chapter includes reforms aiming to streamline the permitting 
for renewable energy sources and to accelerate home renovations, thereby accelerating 
the deployment of renewable energy and boosting energy efficiency in buildings.  

−  Thirdly,  significant  investments  in  an  Energy  Support  Fund,  which  will  provide 
financing for a wide range of investments, and in an Offshore Wind Fund, which will 
incentivise private investment and improve access to finance in Poland’s offshore wind 
energy sector.  

All  of  these  measures  are  expected  to  have  a  long-lasting  impact  on  reducing  fossil  fuel 
consumption and greenhouse gas emissions, and on increasing the uptake of renewable energy. 
Some of these measures, notably the reform related to home renovations and the investment in 
support to institutions implementing REPowerEU reforms and investments, also aim to address 
energy poverty, identified in Article 21c(3)(c) of the RRF Regulation. 

Further,  other  reforms  and  investments  shall  contribute  to  the  objectives  identified  in 
Article 21c(3)(e) of the RRF Regulation, notably to address internal and cross-border energy 
transmission  and  distribution  bottlenecks,  to  support  electricity  storage,  to  accelerate  the 
integration  of  renewable  energy  sources,  and  to  support  zero-emission  transport  and  its 
infrastructure. Specifically: 

− 

− 

− 

− 

two reforms aim, firstly, to improve the Energy Regulatory Office’s ability to support 
the deployment  of  renewable energy, by enabling it to  better assess the needs of the 
distribution grid and plan its development, and, secondly, to remove barriers related to 
the integration of renewable energy into the grid by facilitating the connection process 
and enable the connection of multiple renewable energy sources to a single connection 
point; 

in  parallel,  the  chapter  includes  an  investment  in  the  support  to  the  national  energy 
system through the creation of an Energy Support Fund, as well as investments into the 
transmission  and  the  distribution  networks,  in  order  to  expand  or  modernise  and 
digitalise these networks;  

the  chapter  further  includes  an  investment  in  energy  storage,  thereby  contributing  to 
balancing the grid; and 

the objective of zero-emission transport, covered by the same objective, is supported to 
by a reform related to Poland’s national transport strategy and an investment in zero-
emission buses. 

The REPowerEU chapter also aims to support the abovementioned measures and to contribute 
more specifically to the objective of requalifying the workforce towards green skills, laid out 

26 

 
in  Article 21c(3)(f)  of  the  RRF  Regulation,  by  including  an  investment  in  the  support  to 
institutions implementing REPowerEU reforms and investments through improved mapping of 
the requalification needs of the workforce towards green skills. 

Beyond contributing to the energy transition, the REPowerEU chapter also aims to contribute 
to the objective, described in Article 21c(3)(a), of improving energy infrastructure and facilities 
to meet immediate security of supply needs for gas, including liquified natural gas, notably to 
enable diversification of supply in  the interest  of the Union  as  a whole.  Indeed, the chapter 
includes  an  investment  in  the  construction  of  a  250  km  extension  of  the  gas  transmission 
network between Gdańsk and Gustorzyn. 

Lastly, the investment consisting in support to institutions, be they public institutions or NGOs, 
involved in the coordination and implementation of REPowerEU reforms and investments, is 
expected  to  contribute  in  a  cross-cutting  way  to  the  abovementioned  measures  and  to  the 
objectives listed in Article 21c(3), points (b), (c), (e) and (f) of the RRF Regulation. 

Moreover, the measures in the REPowerEU chapter are part of Poland’s wider efforts to cut 
emissions in view of the EU’s 2030 climate reduction target of 55%. These measures are aligned 
with Poland’s National Energy and Climate Plan (NECP), as submitted in 2019, which aims to 
achieve 21-23% of RES share in gross final energy consumption by 2030.  

Finally, the preparation of the REPowerEU chapter involved consultations with stakeholders. 
In particular, a public consultation process was carried out in the spring of 2023 in accordance 
with  the  Polish  national  legal  framework,  involving  local  and  regional  authorities,  social 
partners, civil society organisations and other relevant stakeholders. This  process included a 
direct  consultation  of stakeholders, notably  via  the organisation  of a conference  on 24 April 
2023 on the modified RRP and the REPowerEU chapter, with a panel entirely dedicated to this 
chapter and the proposals related to the energy transition. The conference was also streamed 
online,  with  a  view  to  allowing  the  widest  possible  audience  to  familiarise  itself  with  the 
proposed changes in the RRP and the draft REPowerEU chapter. These changes and this draft 
chapter were also presented to the Social Dialogue Council, the Public Benefit Council, and the 
Joint Commission of Government and Local Government.  

The indirect consultation was carried out using an online form published on the website of the 
Polish  RRP.  Through  this  online  form,  49  entities  expressed  their  views  on  the  proposed 
changes  to  the  RRP  and  the  draft  REPowerEU  chapter,  representing  local  and  regional 
authorities  (voivodship,  district,  municipalities,  cities),  entrepreneurs  and  employers,  and 
NGOs  and  social  and  economic  partners.  More  specifically,  the  draft  REPowerEU  chapter 
received 68 comments from local authorities and administrations, companies (including State-
owned companies), energy trade organisations, associations, foundations, as well as think tanks 
active in the field of energy transition and environmental protection. 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the chapter is expected, to a large extent, to contribute effectively to energy security, 
the diversification of the Union’s energy supply, an increase in the uptake of renewables and in 
energy  efficiency,  an  increase  of  energy  storage  capacities  or  the  necessary  reduction  of 
dependence on fossil fuels before 2030. This would warrant a rating of A under criterion 2.12 
of Annex V to the RRF Regulation. 

27 

 
3.13. 

Cross-border or multi-country dimension or effect  

The majority of the measures included in Poland’s REPowerEU chapter have a multi-country 
or cross-border dimension. 

In particular, in the first place, several measures are expected to contribute to securing energy 
supply  in  the  Union  as  a  whole,  notably  the  reforms  aiming  to  facilitate  the  deployment  of 
renewable energy sources, such as the reforms related to permitting for and the connection of 
such energy sources to the electricity grid.  Investments related to renewable energy projects 
(including but not limited to offshore wind) and the deployment of energy storage facilities as 
well  as  investments  in  the  expansion  and  modernisation  of  the  Polish  transmission  and 
distribution networks, should likewise contribute to securing energy supply in the Union. 

In  the  second  place,  several  reforms  and  investments  contribute  to  increasing  the  pace  of 
renovation  of  buildings  and  improving  energy  efficiency,  thereby  reducing  dependency  on 
fossil fuels and reducing energy demand. 

The investment related to between Gdańsk and Gustorzyn has a particularly strong cross-border 
dimension, considering that the pipeline’s capacity will be able to be used for regional purposes.  

The total costs of these measures account for a total of EUR 23 473 million representing more 
than 30% of the estimated costs of the REPowerEU chapter. 

Table 5: Cross-border or multi-country dimension or effect 

REPowerEU measure with cross-border or multi-country 

dimension or effect 

Costs (EUR m) 

Contribution to the target 
in % of the REPowerEU 
chapter estimated costs 

Development  of 
electricity infrastructure 

transmission  networks,  smart 

600 

implemented 

by 

energy 

189 

installations, 

RES 
communities 

Energy storage system 

Construction  or  modernisation  of  electricity 
distribution  networks  in  rural  areas  to  enable  the 
connection of new RES 

Energy Support Fund 

Offshore Wind Energy Fund 

Construction  of  natural  gas  infrastructure  enabling 
further diversification of supply and ensuring energy 
security in the national and regional context 

200 

972  

17 069 

4 785  

631 

2% 

1% 

1% 

4% 

68% 

19% 

2.50% 

Total 

23 473 

92.9% 

28 

 
 
Taking  into  consideration  the  assessment  of  all  the  measures  envisaged  in  the  REPowerEU 
chapter, the measures in the chapter are expected, to a large extent, to have a cross-border or 
multi-country dimension or effect. This would warrant a rating of  A under  criterion  2.13  of 
Annex V to the RRF Regulation. 

29 

 
 
 
ANNEX I: CLIMATE TRACKING AND DIGITAL TAGGING  

Measure/ Sub-
Measure ID 

PL-C[A]-I[1.2.1] 

Measure/Sub-Measure Name 

Investments for enterprises in products, services and 
competences of employees and staff related to the 
diversification of activities 

PL-C[A]-I[1.4.1.2]  Agriculture 4.0 

PL-C[A]-I[2.1.1] 

PL-C[A]-I[2.2.1] 

PL-C[A]-I[2.3.1] 

PL-C[A]-I[2.6.1] 

Investments supporting robotisation and digitalisation in 
enterprises 
Investments in the deployment of environmental 
technologies and innovation, including those related to 
circular economy 
Development and equipment of competence centres 
(specialist training centres, implementation support 
centres, Observatories) and unmanned vehicle industry 
management infrastructure, as an ecosystem of 
innovation 
Investment – Development of the national system of 
monitoring services, products, analytical tools, services 
and accompanying infrastructure using satellite data 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. Field 

Coeff. 
% 

Int. Field  Coeff. % 

320 

110 

450 

016 

40% 

055 

100% 

010bis 

100% 

162 

023 

40% 

40.00 

084bis 

40% 

084bis 

100% 

150.00 

0% 

055 

100% 

PL-C[B]-I[1.1.1] 

Investment in heat sources in district heating systems 

300 

034 

40% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

PL-C[B]-I[1.1.2.2] 

Building renovations and heat source Replacements 
with non-gas boilers 

PL-C[B]-I[1.1.3]  Thermal modernisation of schools 

PL-C[B]-I[1.1.4] 

PL-C[B]-I[1.2.1] 

PL-C[B]-I[2.1.1.1] 

PL-C[B]-I[2.1.1.2] 

Strengthening the energy efficiency of local social 
activity facilities 
Energy efficiency and RES in companies – investments 
with the highest greenhouse gas reduction potential 
Investments in hydrogen technologies, production, 
storage and transport of hydrogen - refueling stations 
Investments in hydrogen technologies, production, 
storage and transport of hydrogen - R&I 

PL-C[B]-I[2.2.3]  Construction of offshore terminal infrastructure 

PL-C[B]-I[3.4.1.1] 

PL-C[B]-I[3.4.1.2] 

PL-C[B]-I[3.4.1.3] 

Investments for increasing the use of RES as a source of 
energy in the city 
Investments in increasing biologically active surfaces in 
urban and functional areas and reducing soil sealing 
Investments in the development of zero-emission 
transport infrastructure  

1 920 

025bis 

100% 

290 

67 

025 

025 

40% 

40% 

300.00 

024bis 

40% 

50.00 

077 

100% 

110.00 

366 

2 415 

682 

212 

022 

031 

026 

100% 

100% 

40% 

040 

40% 

048 

050 

025 

40% 

40% 

40% 

PL-C[B]-I[3.4.1.4] 

Investments in nature-based urban investments (NBS)  

170 

PL-C[B]-I[3.4.1.5]  Building renovation leading to greater energy efficiency  4 100 

PL-C[B]-I[3.4.1.6] 

PL-C[B]-I[3.4.1.7] 

PL-C[B]-I[3.5.1] 

PL-C[C]-I[1.1.1] 

PL-C[C]-I[2.1.1] 

Optimisation of transport work in urban public transport 
eliminating fossil energy consumption, including ICT 
solutions 
Education and Training Centres for the green transition 
of cities using advanced technologies,  
Investment in energy-efficient housing for low- and 
average-income households 
Ensuring access to very high-speed internet in white 
spots 
Public e-services, IT solutions improving the 
functioning of administrations and economic sectors, 
and breakthrough technologies in the public sector, the 
economy and society 

700 

600 

76 

100% 

011 

100% 

582 

025ter 

40% 

0% 

1 431 

0% 

051 

100% 

100 

0% 

011 

100% 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/ Sub-
Measure ID 

PL-C[C]-I[2.1.2] 

Measure/Sub-Measure Name 

Level playing field for schools with mobile multimedia 
devices – investments related to the fulfilment of 
minimum equipment standards 

PL-C[C]-I[2.1.3]  E-competences 

PL-C[C]-I[2.2.1.1] 

LAN Connection, STEM laboratories – digital part, AI 
laboratories, examination commissions 

PL-C[C]-I[3.1.1.1]  Cyber security – CyberPL 

PL-C[C]-I[3.1.1.2] 

PL-C[C]-I[3.1.1.3] 

Infrastructure for data processing and delivery of digital 
services 
Optimisation of the infrastructure of law enforcement 
services 

PL-C[C]-I[3.1.1.4] 

IPCEIs on Next Generation Cloud 

PL-C[C]-I[4.1.1] 

PL-C[D]-I[1.1.2] 

Supporting the digital transformation of businesses 
through the use of cloud computing 
Accelerating the digital transformation of health by 
further developing digital health services 

PL-C[E]-I[1.1.1] 

Support for a low-carbon economy 

PL-C[E]-I[1.1.2.2]  Zero-emission public transport (electric busses) 

PL-C[E]-I[1.2.1]  Zero-emission public transport in cities (TraMS) 

PL-C[E]-I[2.1.1.1]  Modernisation and revitalisation of railroads 

PL-C[E]-I[2.1.1.2] 

Improving safety of railway-road crossings 

PL-C[E]-I[2.1.1.3] 

Increasing the capacity of the railway network 

PL-C[E]-I[2.1.1.4]  Preparatory works for high speed railway line 

550 

184 

415 

193 

185 

54 

100 

650 

1000 

1 114 

139 

200 

1 243 

237 

251 

660 

Budget 
(EUR 
m) 

Climate 

Digital 

Int. Field 

Coeff. 
% 

Int. Field  Coeff. % 

0% 

0% 

0% 

012 

108 

012 

100% 

100% 

100% 

0% 

021quinquies 

100% 

011bis 

40% 

011bis 

100% 

0% 

0% 

0% 

0% 

100% 

100% 

100% 

100% 

100% 

40% 

022 

074 

074 

065 

064 

066 

066bis 

100% 

011 

100% 

021quarter 

100% 

012 

095 

100% 

100% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

070 

100% 

PL-C[E]-I[2.1.2]  Railways passenger rolling stock 

1 160 

072bis 

100% 

PL-C[E]-I[2.1.3] 

Intermodal projects 

PL-C[E]-I[2.2.2]  Digitalisation of transport 

PL -C[G]-I[G1.1.2.1] 

Renewable energy sources’ installations implemented 
by energy communities – investment part 

PL -C[G]-I[G1.1.3]  Energy storage systems 

PL -C[G]-I[G1.2.3] 

PL -C[G]-I[G1.2.4] 

PL -C[G]-I[G1.3.2] 

PL -C[G]-I[G3.1.4.1] 

PL -C[G]-I[G3.1.4.3] 

Development of transmission networks, smart electricity 
infrastructure 
construction or modernisation of electricity distribution 
networks in rural areas to connect new RES sources 
Zero and low-carbon collective transport (buses), sub-
investment in zero-emission transport 
Energy Support Fund - Distribution and transmission 
networks 

175 

341 

118 

200 

600 

972 

754 

079 

070 

027 

033 

033 

40% 

40% 

100% 

100% 

100% 

033 

100% 

074 

100% 

6 879 

033 

100% 

Energy Support Fund - energy storage 

033 

100% 

PL -C[G]-I[G3.1.5] 

Construction of offshore wind farms (Offshore Wind 
Energy Fund) 

2 213 

028 

100% 

PL – C[G] – I [G3.3.1] Energy storage systems (repayable support) 

35 

033 

100% 

31