Poland’s Hydrogen Market

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Last updated: 24.09.2025 Poland’s Hydrogen Market

Poland’s Hydrogen Regulation

Energy transformation, EU regulations, and ambitious climate targets are opening a new chapter for the hydrogen market in Poland. In this context, the importance of well-designed and legally compliant hydrogen infrastructure is growing.


Green Hydrogen in Poland – A Strategic Fuel of the Future

Hydrogen is becoming a key component of a sustainable energy mix. Poland, as one of the largest hydrogen producers in Europe, is focusing on its green variant, produced using renewable energy sources.

However, to realize hydrogen’s potential, essential infrastructure is required: pipelines, refueling stations, storage facilities, and terminals.

At the end of 2024, GAZ-SYSTEM published the “Hydrogen Map of Poland” – a document based on the analysis of over 170 planned hydrogen projects. Simultaneously, the ORLEN Group announced an expanded investment strategy aimed at creating a network of hydrogen refueling stations and significant renewable hydrogen production capacities.

At the end of 2024, GAZ-SYSTEM published the "Hydrogen Map of Poland" – a document based on the analysis of over 170 planned hydrogen projects.

Source: GAZ-SYSTEM Hydrogen Map of Poland


Hydrogen production in Poland – New Legal Regulations

The amendment to the Energy Law comprehensively regulates the hydrogen sector for the first time. What changes have been introduced?

Appointment of Hydrogen System Operators by URE

The President of the Energy Regulatory Office (URE) will be responsible for appointing operators of hydrogen transmission, distribution, and storage systems. Candidates will have to meet specific requirements, particularly concerning organizational independence, absence of conflicts of interest, and adequate technical and personnel resources.

Exceptions to full independence are provided for local operators operating in limited territories. Operators will also be obliged to ensure the reliability and high quality of transmission and storage infrastructure.

This approach aims to organize the structure of hydrogen operators and support the development of a stable and secure energy infrastructure in the sector.

Coordination Between Energy System Operators

Operators of hydrogen, electricity, and gas systems are required to coordinate their activities to ensure the safe, stable, and efficient operation of the entire energy infrastructure. Regulations emphasize the necessity of joint management of technical constraints and the development of integrated infrastructure strategies.

Such cooperation is intended to enable the smooth integration of hydrogen with existing gas and electricity transmission systems.

Regarding supply security, operators are required to prepare and publish system operation and maintenance manuals, similarly to the electricity sector. Additionally, operators are obliged to actively manage system congestion to ensure continuity and reliability of supply.

Licensing and Certification Requirements

According to the new regulations, conducting hydrogen storage and trading activities will require an appropriate license. Only entities operating on a small scale – with minor installations and turnover not exceeding the equivalent of 10 million euros annually – are exempt.

According to the new regulations, conducting hydrogen storage and trading activities will require an appropriate license. Only entities operating on a small scale – with minor installations and turnover not exceeding the equivalent of 10 million euros annually – are exempt.

Furthermore, a certification mechanism for renewable and low-emission hydrogen has been introduced, to be overseen by the President of URE, ensuring transparency and compliance with EU green transition requirements.

Rules on Tariffs and Market Transparency

Rates for hydrogen transmission, distribution, and storage services will be based on actual costs incurred by operators and approved by the President of URE.

Operators will be required to publish transparent, non-discriminatory tariff templates to promote market transparency. Cost-based tariff mechanisms are expected to increase investor confidence and ensure financial predictability for entities involved in developing hydrogen infrastructure.

Small-Scale Hydrogen Storage Installations

The new regulations introduce the concept of a “small hydrogen storage installation,” aimed at enhancing local diversification and system resilience – particularly in connection with renewable energy installations. Hydrogen system operators will be obliged to maintain a registry of such storage facilities, including their capacity, precise location, and legal basis for use.

This solution aims to support the development of local and decentralized storage systems, significantly facilitating the expansion of hydrogen technologies at the municipal and regional levels.

Unbundling and Organizational Independence

Operators responsible for hydrogen transmission and distribution will be required to maintain full organizational and ownership separation from entities involved in hydrogen production and trading – in line with the unbundling principle.

However, exceptions are allowed for operators within local networks with limited territorial coverage. Shared infrastructure use within the same capital group is also permitted, provided cross-subsidization is avoided and full transparency of financial settlements is maintained.

These regulations significantly reduce legal uncertainty for investors while laying the foundation for the development of a competitive market.


5 Reasons to Invest in Hydrogen in Poland

5 Reasons to Invest in Hydrogen in Poland

Extensive Support from EU and National Funds

Investments in hydrogen infrastructure are eligible for funding under various instruments such as CEF Transport, the Modernisation Fund, IPCEI (Important Projects of Common European Interest), and the National Recovery and Resilience Plan (KPO).

For example, the ORLEN Group received €62 million in funding for the development of a network of 16 public hydrogen refueling stations. The 2021–2027 financial perspective foresees continued support for hydrogen projects, especially in energy transformation and transport decarbonization.

Significant Increase in Demand for Low-Emission Hydrogen

According to GAZ-SYSTEM analyses, by 2040, annual hydrogen consumption in Poland may reach 2.62 million tonnes – more than double the declared domestic production capacity. Simultaneously, EU energy policy envisions the gradual replacement of grey hydrogen with its green or low-emission counterpart.

This market gap creates real opportunities for new investors and suppliers to enter the sector.

According to GAZ-SYSTEM analyses, by 2040, annual hydrogen consumption in Poland may reach 2.62 million tonnes – more than double the declared domestic production capacity.

Source: GAZ-SYSTEM Hydrogen Map of Poland

Preferential Conditions for Hydrogen Valleys and Regional Initiatives

Regional Hydrogen Valleys are actively developing across Poland – including in the Świętokrzyskie region, Mazovia, Silesia, and Pomerania.

Projects implemented under such initiatives are often prioritized in public funding procedures and local energy policy planning.

Development of Logistic and Transport Infrastructure

Hydrogen mobility – the use of hydrogen in transportation – is one of its main commercialization paths. Poland is expanding its network of hydrogen refueling stations (HRS), with new spatial and environmental regulations facilitating the siting and implementation of such projects.

The potential includes not only road transport (buses, trucks) but also rail, maritime, and industrial applications.

New Regulatory Framework and Support Mechanisms

Government announcements and ongoing legislative work indicate the introduction of dedicated support mechanisms for the production of renewable and low-emission hydrogen – including contracts for difference (CfD), modeled on proven solutions from the RES sector.

Additionally, new regulations envisage the introduction of certification, transparent tariffs approved by URE, and participation in support auctions. This regulatory environment supports investment stability and long-term predictability.

New regulations envisage the introduction of certification, transparent tariffs approved by URE, and participation in support auctions. This regulatory environment supports investment stability and long-term predictability.


Uses of Hydrogen in the Polish Economy

Hydrogen plays an increasingly strategic role in the transformation of modern energy systems. As Poland moves away from fossil fuels, hydrogen use is growing in industry, power generation, and transport. The Polish hydrogen strategy identifies hydrogen as a critical element of national energy transition.

In the industrial sector, hydrogen gas is used in chemical processes such as ammonia and methanol production. It is also vital in refining, steelmaking, and other heavy industries requiring high temperature conditions.

In transport, hydrogen fuel is being developed for road vehicles and other applications where direct use of clean fuel reduces emissions. Fuel cells powered by pure hydrogen are promising for long-haul transport, offering a zero-emission alternative to diesel.

Hydrogen can also be used to generate electricity and heat energy in decentralized systems. With further infrastructure development, Poland aims to integrate hydrogen into a national hydrogen transmission network, including the emerging hydrogen valleys.

Currently, methods used to produce hydrogen in Poland are largely based on natural gas (methane) through steam reforming or autothermal reforming – both carbon-intensive processes. In the long term, Poland plans to expand electrolytic hydrogen production via electrolysis powered by solar and wind or even nuclear power. This shift aligns with the Polish hydrogen strategy aims of reducing carbon dioxide and carbon monoxide emissions, while supporting a low carbon Polish economy.


FAQ – Production of hydrogen in Poland

FAQ - Production of hydrogen in Poland

What are hydrogen molecules made of?

A hydrogen molecule (H₂) consists of two hydrogen atoms. In production via electrolysis, water molecules (H₂O) are split into hydrogen and oxygen using electricity.

This process can produce pure hydrogen with no direct carbon dioxide emissions, especially when powered by renewables.

What is hydrogen used for in Poland?

Hydrogen use in Poland spans several sectors, including the industrial sector, chemical production, power generation, and transport. It is a vital component in refining, steelmaking, and ammonia synthesis, and is gaining momentum as a clean fuel for vehicles and decentralised energy systems.

How is hydrogen currently produced in Poland?

Most hydrogen in Poland is still produced using natural gas through processes like steam reforming and autothermal reforming, both of which emit carbon dioxide and carbon monoxide.

These methods are being gradually replaced by electrolysis using renewable sources such as solar and wind to produce electrolytic hydrogen.

In some industrial processes, hydrogen also appears as a by product, although volumes remain limited compared to dedicated production.

What is the goal of the Polish hydrogen strategy?

The Polish hydrogen strategy aims to develop a sustainable hydrogen economy by:

  • increasing low carbon hydrogen production,
  • expanding infrastructure development (including a national hydrogen transmission network),
  • and supporting hydrogen imports where necessary.

The strategy also promotes hydrogen as a tool for decarbonizing the Polish economy.

Will Poland be able to meet its future hydrogen demand?

According to GAZ-SYSTEM’s Hydrogen Map of Poland (2024), forecasts indicate a potential gap between supply and demand. By 2030, the deficit may reach 0.8 million tonnes, and by 2040 as much as 1.4 million tonnes.

This may require increased investment in production facilities, scaling up of electrolysis, or relying on hydrogen imports to ensure availability.

Is hydrogen a cost-effective energy solution?

While some hydrogen production methods remain costly, other methods – such as renewable-powered electrolysis – are becoming more cost-effective due to falling technology costs and increased efficiency.

Government support and the development of the hydrogen transmission network are also expected to improve economic viability.

Expert team leader D&P Legal Michał Dudkowiak
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Write an inquiry: [email protected]
check full info of team member: Michał Dudkowiak
Expert team leader D&P Legal Anna Cichoń
Contact our expert
Write an inquiry: [email protected]
check full info of team member: Michał Dudkowiak