Green Certificates 2025–2028:
What Will Change with the New Regulation and How Will It Affect Energy Prices?
Green certificates (PMOZE_A) are once again in the spotlight - legal changes taking effect at the end of August 2025 are expected to significantly impact the final cost of electricity for businesses and institutional consumers starting in 2026.. Although the share of certificates in the electricity price may seem small, their impact on the budget is noticeable.
In this article, we discuss the latest draft regulation, analyze the PMOZE_A market, and show - with numbers - how the right approach to certificates can save tens of thousands of zlotys.
In this article, we discuss the latest draft regulation, analyze the PMOZE_A market, and show - with numbers - how the right approach to certificates can save tens of thousands of zlotys.
Where Are Green Certificates Hidden in the Electricity Price?
Before we move on to the latest changes in the green certificates market in Poland (not to be confused with guarantees of origin), it is worth understanding where certificate-related costs are embedded in the electricity price structure.
Currently, property rights from certificates of origin (green, blue, etc.) make up a relatively small portion of the so-called active energy cost - just around 2% of the final electricity price. For comparison, just a few years ago, this share ranged from 5% to even 10%.
However, in times when companies and institutions are looking to cut costs wherever possible, this component cannot be overlooked. Especially since changes to the PMOZE_A system, planned in the latest draft regulation from July 14, 2025, may have a real impact on the final energy price in the coming years.
Currently, property rights from certificates of origin (green, blue, etc.) make up a relatively small portion of the so-called active energy cost - just around 2% of the final electricity price. For comparison, just a few years ago, this share ranged from 5% to even 10%.
However, in times when companies and institutions are looking to cut costs wherever possible, this component cannot be overlooked. Especially since changes to the PMOZE_A system, planned in the latest draft regulation from July 14, 2025, may have a real impact on the final energy price in the coming years.
Key Assumptions of the 2026–2028 Draft Regulation
1. Gradual reduction of the mandatory share of green certificates:
- 13% in 2026
- 12% in 2027
- 11% in 2028
2. Maintaining the share of blue certificates (PMOZE_B) at 0.5%.
The goal of these changes is to improve market stability and predictability for certificates of origin, which currently face significant oversupply - 25.1 TWh as of the end of May 2025.
Three-Year Perspective = More Planning
Introducing a three-year regulatory outlook aims to enable better planning for obligated parties and RES market participants.
The regulation takes into account, among others:
The regulation takes into account, among others:
- the number of active RES installations
- entrepreneurs’ expectations regarding regulatory stability
Market Intervention and Flexibility in Case of Change
The regulation also has an interventionist character - it aims to prevent further devaluation of certificates and to support the resale of unused certificates.
In the event of major market developments - such as the migration of installations to other support systems or a rapid increase in energy consumption (e.g., due to the development of electromobility) - regulatory adjustments may be made during the regulation's effective period.
The regulation is scheduled to enter into force on August 31, 2025, in line with legal requirements.
In the event of major market developments - such as the migration of installations to other support systems or a rapid increase in energy consumption (e.g., due to the development of electromobility) - regulatory adjustments may be made during the regulation's effective period.
The regulation is scheduled to enter into force on August 31, 2025, in line with legal requirements.
General Conclusions - What’s Next for the Green Certificate System (PMOZE_A)?
1. The system of certificates of origin (green and blue) is in a phase-out stage. New RES installations have not been allowed to join since 2016, and some older installations will end support after 15 years. Between 2026 and 2028, approximately 2 GW of RES capacity will leave the system.
2. The three-year obligation schedule - 13% (2026), 12% (2027), 11% (2028) - is intended as an orderly phase-out, ensuring market liquidity and stable demand for certificates.
3. The oversupply of certificates of origin still dominates - currently at 25.1 TWh. This excess has led to the PMOZE_A price dropping to around 25 PLN/MWh - the lowest in years and well below historical peaks (e.g., ~300 PLN/MWh in 2021).
2. The three-year obligation schedule - 13% (2026), 12% (2027), 11% (2028) - is intended as an orderly phase-out, ensuring market liquidity and stable demand for certificates.
3. The oversupply of certificates of origin still dominates - currently at 25.1 TWh. This excess has led to the PMOZE_A price dropping to around 25 PLN/MWh - the lowest in years and well below historical peaks (e.g., ~300 PLN/MWh in 2021).
Oversupply of PMOZE_A Certificates - Market Data
The chart below shows how the oversupply of PMOZE_A green certificates has changed in recent years. A clear downward trend is visible from 2020 to 2023, followed by a rebound in 2024–2025. Despite a temporary decline in supply, the stockpile remains high, negatively impacting prices.
Historical PMOZE_A Prices - Lowest Since the System's Inception
In terms of pricing, current PMOZE_A quotes are at historic lows since the start of the system.
The chart below shows how PMOZE_A prices evolved on the Polish Power Exchange (TGE) from 2013 to July 2025.
The chart below shows how PMOZE_A prices evolved on the Polish Power Exchange (TGE) from 2013 to July 2025.
How Have PMOZE_A Prices Changed Over the Last Decade?
Over the past 10 years, PMOZE_A green certificate prices have shown considerable volatility, reflecting both market supply-demand dynamics and legislative changes:
- 2015–2017: period of rapid price decline - from 123.60 PLN/MWh down to 38.83 PLN/MWh
- 2018–2021: strong price surge, peaking at around 300 PLN/MWh
- 2022–2023: price stabilization between 190 - 200 PLN/MWh
- 2024–2025: sharp market downturn - prices dropped to around 25 PLN/MWh (as of June 2025), driven by excess supply (over 25 TWh) and limited regulatory demand due to the planned reduction in obligation (13% → 11%)
What Do Changes to PMOZE_A Obligations Mean for Energy Buyers?
The percentage change in mandatory certificate obligations (PMOZE_A) is a key factor in negotiating electricity prices with suppliers.
4 Key Facts:
4 Key Facts:
- The Energy Law still stipulates a 19.35% PMOZE_A obligation
- Each year, the Ministry of Climate and Environment issues a new decision
- typically setting the share lower than the legal provision - For 2025, the obligation is set at 8.5%
- According to the new regulation draft, in 2026 the obligation will rise to 13%
What to Watch For? Example of Surplus Certificate Settlement
If you buy PMOZE_A green certificates in advance or in tranches, be sure to check how many certificates your supplier is securing on your behalf, and based on what obligation level.
Example: you purchase energy for 2026, and the supplier secures PMOZE_A at 19.35% (in line with the law). However, the actual regulatory obligation will only be 13% - leaving a surplus that may need to be settled, often at lower market prices on the date of adjustment.
Practical Example:
Example: you purchase energy for 2026, and the supplier secures PMOZE_A at 19.35% (in line with the law). However, the actual regulatory obligation will only be 13% - leaving a surplus that may need to be settled, often at lower market prices on the date of adjustment.
Practical Example:
- Annual energy consumption: 10,000 MWh
- Purchase volume based on 19.35%: 1,935 MWh
- Certificate purchase price: 30 PLN/MWh
- Purchase volume based on 13%: 1,300 MWh
- Certificate price at the time of obligation change: 20 PLN/MWh
Settlement:
Purchase cost
(1,935 MWh × 30 PLN)
(1,935 MWh × 30 PLN)
58,050 PLN
Sale of surplus
(635 MWh × (20 - 30 PLN))
(635 MWh × (20 - 30 PLN))
- 6,350 PLN
Final cost
64,400 PLN
Final price per MWh
49.54 PLN/MWh
Cost at 13% and 20 PLN
26,000 PLN
Comparison: Buying only 13% at 20 PLN = 26,000 PLN
Difference: Over 38,000 PLN loss if the security mechanism is not verified in advance
Difference: Over 38,000 PLN loss if the security mechanism is not verified in advance
Green Certificates - Summary
Changing regulations - both in terms of mandatory certificate levels (PMOZE_A) and market prices - mean that certificates of origin remain a key component of electricity contract negotiations.
Proper tender preparation and a clear understanding of the actual obligation level and certificate price can make or break the profitability of the entire agreement.
Don’t overlook certificates in energy procurement. Any change in law - including green, white, or blue certificate obligations - can significantly impact the real cost of electricity. A poor hedging strategy may result in unnecessary expenses or settlement losses.
Proper tender preparation and a clear understanding of the actual obligation level and certificate price can make or break the profitability of the entire agreement.
Don’t overlook certificates in energy procurement. Any change in law - including green, white, or blue certificate obligations - can significantly impact the real cost of electricity. A poor hedging strategy may result in unnecessary expenses or settlement losses.
Author: Bartosz Palusiński, Consultant
