Poland is working on restructuring its Guarantees of Origin (GO) framework by transferring full issuance authority from the Energy Regulatory Office (URE) to the Polish Power Exchange (TGE) – a strategic move intended to meet Association of Issuing Bodies’ (AIB) membership requirements and enable the integration of Polish GOs into the wider EECS cross-border market.

Current GO structure

Poland’s GO framework currently follows a dual-responsibility model that conflicts with AIB membership standards. The Energy Regulatory Office (URE) is legally responsible for issuing and recognising GOs, while TGE manages the GO register (RGP) and facilitates domestic trading. This split structure has been identified by the President of URE as the main obstacle preventing Poland’s AIB membership under the current legal framework.

Proposed restructuring

To address this, URE has proposed consolidating all GO-related functions under TGE, granting it full authority over issuance, recognition, and registry operations. The President of URE has officially requested that the Minister of Climate and Environment initiate legislative amendments to transfer these powers – including the right to apply for AIB membership – to TGE, an URE representative confirmed.

Advanced negotiations between URE and TGE, supervised by the Ministry of Climate and Environment, are already underway to implement this transfer. Once completed, TGE would represent Poland within the AIB, managing the entire GO process end-to-end and engaging directly with the AIB and the European Energy Certificate System (EECS) standard. This model would mirror the system that is in place for most other AIB members.

Market impact

Poland remains the largest EU member state still outside the AIB system. In 2024, the country generated around 45 TWh of renewable electricity — a volume comparable to Austria’s within the AIB, but well above Romania’s 24 TWh, the second-largest renewable producer outside the AIB. Strong renewable generation growth, combined with relatively softer domestic demand, has in most cases resulted in Polish GOs trading at a discount compared to AIB GOs.

The discount between Polish and AIB-compliant GOs currently range between EUR 0.05 – 0.21/MWh across all vintages. In the current environment, AIB membership would allow Polish renewable producers to export certificates and enable international buyers to source Polish GOs, supporting greater market liquidity, transparency, and price convergence with broader AIB market.  In 2024, Poland cancelled 24.4 TWh of GOs, suggesting an export potential of around 15–25 TWh — roughly 2–3 % of the total AIB market — implying that any broader price impact would likely remain limited.

Market sources indicate that the legislative and technical processes needed to complete this transfer suggest a realistic timeline targeting potential AIB membership around 2027, contingent on the pace of Renewable Energy Sources Act amendments, finalisation of URE–TGE operational arrangements, system alignment with EECS standards, and formal AIB approval procedures.