The CCUS Poland Association is the first nationwide initiative in Poland bringing together industry, academia, and the third sector with the goal of supporting public administration and other stakeholders in the implementation of carbon capture, transport, and storage technologies.
The Association aims to promote a data- and science-based dialogue on the development of this technology in Poland.
The Draft Act Represents a Step in the Right Direction
The CCUS Poland Association welcomes the launch of public consultations on the draft act amending the Emissions Trading System Act and certain other acts (UC39). The draft aims to implement changes stemming from Directive 2023/959, including provisions related to the allocation of revenues from the sale of emission allowances (EUAs).
According to estimates, Poland will need investments amounting to approximately 10% of its GDP to achieve a climate-neutral economy. One of the key sources of financing for this transformation is currently the revenue from EUA sales. Between 2013 and 2024, Poland generated nearly PLN 110 billion from such sales. It is worth noting that for most of that period, the EUA price remained relatively low. This implies that the amount of funds available for climate-related investments in the coming years will likely be significantly higher. First, EUA prices currently stand at around €80 per tonne, resulting in substantially higher revenues in recent years compared to the earlier period [1]. Second, the proposed legislation will increase the availability of these funds by requiring the state to allocate 100% of EUA revenues to climate objectives.
The CCUS Poland Association supports the direction of the proposed amendment. While it follows from changes in EU legislation, it also aligns with long-standing calls from Polish industry since the European Commission announced the European Green Deal in 2020. At the same time, we stress that this substantial increase in climate funding must be accompanied by careful planning and transparent allocation mechanisms. According to a statement from the Ministry of Climate and Environment, only 5.45% of EUA revenues between 2013 and 2023 were allocated to industrial decarbonisation [2], which does not reflect the scale of the challenge facing Polish industry. Much of the spending to date has been directed towards mitigating price shocks in energy-intensive industries—which has been and remains crucial to maintaining their competitiveness at the European and global levels. However, as EUA revenues increase, it is essential that a significant portion be directed toward the development of decarbonisation technologies for Polish industry.
In this context, it is important to refer to the provisions of the aforementioned directive, which lists carbon capture and storage (CCS) as one of the eligible uses of climate funds. When deciding how to distribute these funds, Poland must also take into account its other obligations under EU legislation—particularly the requirement to ensure sufficient CO₂ storage capacity on its territory by 2030.
While the development of renewable energy and improvements in energy efficiency (in both enterprises and buildings) remain central elements of climate policy, it is important to recognise that these measures alone will not achieve full decarbonisation of Polish industry. Moreover, many renewable technologies—thanks in part to public support and favourable regulation—are already able to compete with conventional energy sources. Therefore, when allocating EUA revenues, the scope of supported technologies should be expanded to include those that are not yet fully market-ready but are critical to the decarbonisation of the Polish economy—such as CCS technologies.
Recommendations
As an organisation that brings together key CCUS stakeholders across industrial sectors, the CCUS Poland Association supports the direction set by the amendment, which aims to allocate the entirety of EUA revenues to climate-related objectives. Drawing on our industry experience and our commitment to the effective allocation of these funds, we recommend the following:
1. Establishing a Catalogue of Eligible Technologies and Solutions
To date, Polish public institutions have not adopted any guidelines or lists of technologies officially recognised as climate-positive and thus eligible for EUA funding. In order to foster a more strategic approach and provide legal certainty to market participants, we call for the creation of such a catalogue and for the inclusion of CCUS technologies within it.
2. Stronger Link Between Spending and Specific Measures (Earmarking)
One of the concerns raised by the Supreme Audit Office (NIK) during its review of EUA spending in 2013–2023 was the lack of clear mechanisms linking expenditure to its revenue source. This created transparency issues and made it difficult to determine which funds were truly used for climate action.
To avoid similar concerns in the future and strengthen legal certainty for all market actors, we recommend that EUA revenues be directed to a dedicated fund for Poland’s climate transition. Establishing and legally anchoring such a fund, along with a defined list of eligible technologies, would mark a qualitative improvement in transparency, while also providing business certainty to Poland’s key industrial stakeholders.
[1] According to the 2024 report of the Supreme Audit Office (NIK), nearly 90% of EUA revenue spent between 2013 and 2023 came from the 2019–2023 period.
[2] https://www.gov.pl/web/klimat/komunikat-dot-wydatkowania-przez-polske-srodkow-z-systemu-ets?utm_source
