Poland is preparing for a fundamental shift in its renewable energy auction system. Under the EU’s Net Zero Industry Act (NZIA), from 2026 the lowest price may no longer be the sole deciding factor – new non-price criteria will play a significant role, potentially weighing between 15 and 30 percent in the evaluation of bids.
The NZIA, adopted in June 2024, requires member states to introduce qualitative criteria for the pre-qualification and award of renewable energy auctions. These include responsible business conduct, cybersecurity and data security, project delivery capability, resilience, and sustainability. The European Commission’s implementing regulation from June 2025 detailed these criteria.
New criteria under NZIA
According to the Ministry of Climate and Environment (MKiŚ), the obligation to include non-price criteria enters into force on 30 December 2025. Kacper Stanosz, a lawyer at CMS Poland, explained that unless there are grounds to refrain from applying these criteria due to implementation costs, they must be applied to auctions held in 2026 and later years.
The ministry confirmed that analytical work is underway. “Given the nature of the non-price criteria and the obligations that member states must also impose on RES investors, the implementation of these provisions requires thorough analysis,” the MKiŚ told the press. The ministry added that if it decides to adopt the guidelines as components of bid evaluation, their combined weight could range from 15 to 30 percent and would apply to at least 30 percent of the annual auctioned volume or 6 GW.
Implementation challenges and timelines
The government is currently assessing various scenarios for the 2026 auctions. However, applying non-price criteria to projects scheduled for this year’s auctions appears extremely difficult due to the need to adapt the auction platform and regulations. The Energy Regulatory Office (URE) plans to launch consultations with the ministry in August regarding the 2026 auction schedule, with auctions expected in the fourth quarter.
For offshore wind, the situation is clearer. “Advanced work is underway to implement non-price criteria for the offshore wind sector. The new rules are expected to apply from the auction planned for 2027,” the ministry noted. Aleksandra Kolenda, a senior associate at KPMG Law, pointed out that without knowing the specifics of domestic legislation, it is hard to predict whether the new criteria will raise energy prices in auctions and for which project types.
A June 2026 report by the Polish Wind Energy Association and partners noted that implementation of the NZIA non-price criteria remains in a preparatory phase across most EU member states.
Źródło: WNP.PL, Fot. Raphael Ruz / Shutterstock
