Support for biomethane in Poland in 2024: what works and what is missing

In September 2024 the Polish biomethane support system rested on one new statutory mechanism — the sale of biomethane from installations with a capacity of up to 1 MW (after conversion to electrical capacity) at a price based on the reference price, with the right to coverage of the negative balance — and on market instruments: sales to entities fulfilling the National Indicative Target and guarantees of origin. The biggest gap was the lack of a dedicated mechanism for larger installations.

What worked

How Chapter 4a works

1. Declaration. The producer submits to the President of URE a declaration of intent to sell biomethane injected into the gas grid, electronically, through the online auction platform.
2. Reservation. Together with the declaration, a reservation fee is paid to the designated account or a bank guarantee is provided — PLN 12 for every 1 kW of installation capacity — and the producer undertakes to produce the first biomethane within 48 months of the issue of the certificate. The declaration is accompanied by, among other things, the conditions of connection to the gas grid, a physical and financial schedule and a diagram of the installation.
3. Certificate. The President of URE issues a certificate of the possibility to sell biomethane within 45 days of the submission of a complete declaration; if the commitment is not met, the security is forfeited.
4. Price. The fixed purchase price equals the reference price on the day the declaration is submitted, indexed annually by the consumer price index; the prices from the regulation are PLN 545/MWh (agricultural biogas) and PLN 538/MWh (biogas). Investment aid reduces the price.
5. Period. The right to coverage of the negative balance lasts 20 years from the first sale, at most until 30 June 2048.
6. Limits. The Council of Ministers may limit the maximum capacity of installations that can obtain a certificate in a given year.

The mechanism does not cover undertakings in difficulty within the meaning of EU state aid rules.

NCW, guarantees and registers

The Act clearly separates operating support from the transport market: biomethane that benefits from support under Chapter 4a is not counted towards the fulfilment of the NCW obligation. A producer not benefiting from support may sell biomethane to entities fulfilling the NCW and is obliged to record these quantities in its documentation. Guarantees of origin are not state aid and do not confer property rights; they serve to confirm the origin of the gas to the buyer. Producers of biomethane from agricultural biogas register with KOWR, and the others with URE.

What was missing

• A mechanism for installations above 1 MW. For larger projects the Act contained no operating support, so viability depended on gas market prices and the NCW.
• Long-term price stability beyond the threshold. The lack of a guaranteed price for over a dozen years may make bank financing harder.
• Certainty about capacity limits. A regulation of the Council of Ministers may reduce the capacity pool for the following year.
• A transparent link with grants. Investment aid lowers the price, so combining grant funding with operating support requires calculations.

These are the editors' assessments based on the wording of the regulations; the financing conditions of individual projects depend on contracts and programmes that must be verified separately.

What to do first

1. Measure the planned capacity after conversion to electrical capacity and compare it with the 1 MW threshold.
2. Check whether the feedstocks qualify the biomethane as "from agricultural biogas" (KOWR register) or "from biogas" (URE register).
3. Calculate the corrected price after deducting the expected investment aid.
4. Plan the schedule: first biomethane within 48 months of the certificate.

How to choose a route — a short decision list

1. An installation of up to 1 MW (after conversion to electrical capacity)? Consider Chapter 4a: a predictable price and a 20-year period, but the biomethane then does not count towards the NCW.
2. A larger installation or one without operating support? The market route is sale to the grid or to entities fulfilling the NCW; viability depends on gas prices and contract terms.
3. Are there investment grants? Investment aid reduces the fixed price in Chapter 4a — calculate both variants.
4. Time to completion. The URE certificate is tied to a 48-month deadline for first production; a project that is too slow risks forfeiting the security.
5. Origin documentation. Guarantees of origin and registration in the appropriate register (KOWR or URE) are needed regardless of the route chosen.

This text is for information purposes and does not constitute legal advice; before an investment or formal decision, check the current wording of the regulations and consult a lawyer or the competent authority.