NIS2 directive impacts photovoltaic sector. Regulator may order equipment replacement

The NIS2 cybersecurity directive is now affecting Poland’s photovoltaic sector, with regulators potentially ordering retroactive replacement of equipment already installed on solar farms. Wojciech Cetnarski, CEO of Wento (Equinor group), highlighted this as one of the key risks for large-scale PV investors in Poland.


Poland’s large-scale PV segment (farms of 10 MW or more) reached 3.7 GW of installed capacity at the end of May 2026, according to data from the Energy Regulatory Office. This represents a 36.4% year-on-year increase, reflecting a wave of investment decisions made 18–24 months earlier when market conditions were different. Cetnarski notes these projects are the result of rational choices made in a less saturated market environment.

Wento is currently developing the Grabin solar farm, with a target capacity of 191 MW. The installation will consist of around 270,000 photovoltaic panels covering roughly 180 hectares. The first phase (123 MW) is scheduled to become operational in the second half of 2027, with the second phase (68 MW) following shortly after – approximately a quarter later.

The NIS2 challenge for Polish solar farms

Cetnarski pointed out that NIS2 regulations require the use of equipment meeting specific security classes. What makes this especially concerning for investors is the possibility of retroactive enforcement. – The regulations provide that in certain cases the regulator may order retroactive action, meaning replacement of technological equipment that has already been installed – he said. Because these rules are new and their implementation is still taking shape, investors currently see them as a significant source of risk.

The NIS2 directive primarily concerns cybersecurity of critical infrastructure, and large solar farms are now included. The potential for forced upgrades of inverters, transformers, or control software adds uncertainty to project economics and timelines.

Local content and Polish expertise

Despite imported components – photovoltaic panels, inverters and sometimes transformers – large PV farms generate substantial value for Poland’s economy. Cetnarski estimated the local content of the Grabin investment at 65–70%. – In the area of component production for photovoltaics, price competition with the world’s largest producers is a major challenge. Greater potential for Poland lies in developing high value-added areas we are already known for, such as software, automation, engineering services, or installation management and operation – he explained.

He added that Polish companies have begun developing software for non-EU equipment manufacturers, and some foreign suppliers are now starting to accept such third-party control software for their devices.

Other challenges mentioned by Cetnarski include building partnerships with local communities (Wento has abandoned projects when local opposition was too strong) and the limited availability of contractors. – Increased investment activity means greater demand for the same construction resources. At present, this applies to OZE projects, energy storage, and grid modernization alike. All these segments compete for the same contractors and specialists – he noted.

Wento’s current operational portfolio stands at over 200 MW, consisting of four solar farms and one wind farm. The company’s development pipeline includes both projects below 100 MW and larger ones above that threshold.

Źródło: WNP.PL, Fot. Quality Stock Arts / Shutterstock

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