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Analytical Review: The Polish Energy Regulatory Model (URE)

27.01.2026

Energy Club Launches Series of Analytical Reports on EU Energy Regulators

We are analyzing the practical side of the industry: how institutions in neighboring countries are structured, who bears responsibility for decisions, and how judicial oversight functions.

The first review focuses on Poland. The Polish model (URE) differs significantly from the Ukrainian one, operating on the principle of the personal responsibility of the head, with disputes handled by a specialized court.

Find a detailed breakdown of the Polish experience below.

The Polish energy regulation system serves as a prime example of a model where market predictability is ensured through a clearly defined mandate, formalized procedures, and the personal accountability of leadership.

The key institution in this system is the Urząd Regulacji Energetyki (URE) — the Energy Regulatory Office. Its status, powers, and control mechanisms are defined by the “Energy Law” Act (Prawo energetyczne). Below is a concise description of how this model is structured and operated.

  1. Institutional Model: Personal Accountability

Unlike many European regulators that operate as collegiate bodies (commissions), the Polish URE is built on the principle of sole leadership.

The central figure is the President of the URE (Prezes URE), who acts as a central body of the state administration. It is the President of the URE who signs decisions and bears personal responsibility for them. This “monocratic” structure simplifies management logic: instead of diffusing responsibility among commission members, there is a clearly defined decision-maker.

  1. Appointment and Independence Guarantees

The procedure for appointing the regulator’s head is designed to mitigate the risks of situational political influence on daily operations:

  • Appointment: The President of the URE is appointed by the Chairman of the Council of Ministers (the Prime Minister).
  • Selection: The appointment follows an open, competitive recruitment process.
  • Term: A fixed 5-year term.
  • Rotation: An individual may hold the office for no more than two terms.

A fixed term provides foundational institutional stability and allows for medium-term planning, reducing dependence on the political calendar.

  1. Powers: A Clear Mandate under Article 23

The regulator’s activities are governed by Article 23 of the “Energy Law” Act. The URE operates strictly within the competencies expressly established by law. Key functions include:

  • Licensing (koncesje): Issuing, amending, and revoking licenses/concessions for activities in the fuel and energy sectors.
  • Tariff Regulation: Approving tariffs in legally defined regulated market segments, particularly concerning network activities.
  • Supervision and Control: Monitoring compliance with operational requirements and conditions, and applying enforcement measures or sanctions as prescribed by law.
  • Dispute Resolution/Access Issues: Settling disputes regarding network access and connection conditions within the scope defined by law.
  1. Decision-Making Procedure

A significant feature of the Polish model is the rigorous requirement for the quality of administrative decisions. Decisions by the President of the URE are issued as formal administrative acts (decyzja).

Such documents must contain not only the final ruling but also a proper justification: a description of the facts, an analysis of evidence, and legal arguments. This fosters a predictable environment for business: companies can understand the regulator’s logic and, if necessary, prepare a legally sound position for appeal.

  1. Judicial Control: The Specialized Court (SOKiK)

The system of checks and balances in Poland is largely maintained through specialized judicial oversight. Regulatory decisions are not appealed through general courts but via a specific instance: the Court of Competition and Consumer Protection (SOKiK), which operates within the District Court in Warsaw.

The appeal procedure (per Article 30 of the Act) includes:

  • Submission via URE: An appeal is filed with the court through the URE office — a procedural form required by law.
  • Expert Review: SOKiK specializes in competition and consumer protection cases, ensuring professional adjudication of economically and regulatorily complex disputes.
  • Strict Deadlines: Appeals must be filed within 14 days of the decision being served.
  1. Funding and Accountability

Independence is also tied to the “wallet.” The Polish funding model for the URE is budget-based. The regulator is funded by the state budget, while fees paid by market participants (license fees, fines) are credited to state revenue rather than staying in URE accounts. While this creates some dependence on the budgetary process, it is balanced by transparent reporting: the President of the URE is required to submit an annual public report, which is a detailed analysis of market conditions and the execution of regulatory functions.

Summary

The Polish energy regulation model rests on three pillars:

  1. Personal accountability of the leader (President of the URE).
  2. A clear regulatory framework and procedural rigor in decision-making.
  3. Effective judicial oversight via a specialized court (SOKiK).

Together, this structure provides a more predictable regulatory environment for market participants and investors, alongside a transparent mechanism for reviewing regulatory decisions.

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