Poland has not yet set a binding climate neutrality target. The other goals proposed in the NECP update are likewise misaligned with European Union climate policy objectives, a point the European Commission highlighted in its assessment of the submitted projection. The proposed ETS‑sector reduction would amount to 14.4%, below the Effort Sharing Regulation (ESR) requirement of 17.7% versus 2005 levels.
Poland has just recently started works on a national strategy for the development of carbon management technologies, barerly meeting the expectation oft he industry in terms of the quick implementation of respective regulations. Process is being supported by the outcomes of the CCUS.pl project, completed in 2024; that work produced an economic and fuel‑mix model comparing CCS deployment scenarios with a business‑as‑usual baseline, together with recommendations and potential strategy targets. Outputs were consolidated in three analytical reports and in a draft strategic document prepared by the Ministry of Development and Technology, a project partner, with funding from the National Centre for Research and Development’s state development fund. Because geological storage issues fall under the Ministry of Climate and Environment, the materials were to be handed to that ministry for further work. Currently, the dedicated expert group in Ministry, consisting of the representatives of industry, NGOs and academia, is working on the first version of the document which will be a subject to the further works (incl.
Consultations within the government as well as the public consultations). Therefore, despite some progress made, Poland is still rather at the begining of works.
The recent version oft he NECP update includes a commitment to adopt a carbon management strategy. The Ministry of Climate and Environment is conducting stakeholder dialogue via ministerial working groups and has signed a letter of intent with industry parties. Media reports quote Deputy Minister Krzysztof Bolesta referring to ministry work based on CCUS.pl research and announcing comprehensive legal changes covering CO2 transport and storage, plus a social campaign to build CCS public support. A ministerial communications working group has reportedly already drafted general terms of reference for that information campaign.
Carbon management appears in Polish strategic documents, but assigned ambitions are modest. The National Energy and Climate Plan 2021–2030 (KPEiK, adopted 2019) discusses CM most extensively. Dimension 2.5 (Research, Innovation, Competitiveness) identifies investment in CO2 transport and storage infrastructure as an important research area and links it to the 2019 Directions for Energy Innovation in hydrogen, synthetic gases and methanol production. Section 2.5.c.12 notes potential use of CO2 combined with hydrogen to produce methane for injection to the gas network. An NECP update was published in October 2024 (well after the June 2024 deadline) but has not been formally adopted. The update treats CCS and CCU more fully than the original NECP, recognising their role in reducing process emissions and potential use in gas‑ or biomass‑based power, while expressing preference for the latter and allowing CCS on new gas units. Planned actions include adopting Carbon Contracts for Difference and other supportive measures, and preparing a strategy for CO2 sequestration and utilisation. DACCS is only briefly noted.
However, the NECP update authors argue that CCS and CCU deployment depend on so many variables that it is currently impossible to specify capture volumes, transport modes or quantitative technology targets. The European Commission criticised this position, noting the update should identify capture and storage locations and volumes out to 2030 and that R&D declarations lacked assigned budgets or concrete funding commitments. No consultation notes clarifying stakeholder positions on proposed NECP changes have been published, though some stakeholder opinions are publicly available. The Employers and Entrepreneurs Association (ZPP) argued many market participants could benefit from support for emission‑reduction and CO2 capture/storage projects and called to remove legislative barriers and allow renewables and CCS projects to access CCfD support. The Instrat Foundation recommended removing DACCS references from the plan given current low feasibility and noted that the GO4ECOPLANET capture project at the Kujawy cement plant (near 1 Mt/year capture) was effectively omitted from NECP emission reduction calculations. Cement industry representatives also criticised the update for insufficient ambition and modelling assumptions that show rising sector emissions despite planned CCS at Kujawy.
The other principal strategic document is Poland’s Energy Policy to 2040 (PEP2040), structured around Fair Transition, Zero‑emission Energy System and Good Air Quality. CCS/CCUS technologies are explicitly named as important tools for PEP2040 strategic projects. Strategic Project No. 1, “Transformation of coal regions,” envisages low‑ and zero‑emission coal technologies (including CCS/CCUS) playing a key role in transforming fossil‑fuel‑dependent regions and foresees investment commitments in the social agreement on mining signed in May 2021. That agreement foresees building infrastructure to transport captured CO2 to underground storage and adapting underground formations for CO2 storage; proposed locations were to be indicated by mid‑2022 and relevant infrastructure commissioned in 2023–2029. The social agreement’s rationale, including prolonging some coal mining to 2049, is contested by NGOs but defended by the government.
PEP2040 also positions CCS as a means to allow continued partial low‑ or zero‑emission use of coal in CCS‑ready power plants, making R&D in these technologies relevant for the energy transition. CCS/CCUS is additionally referenced in the task “Development of electromobility and alternative fuels”: capturing CO2 from hydrogen production via steam methane reforming could support low‑ and zero‑emission hydrogen and facilitate a longer transition to fully green electrolytic hydrogen powered by renewables. DAC is not mentioned in PEP2040. Notably, despite multiple industry decarbonisation references, CM solutions are not presented as a core industrial decarbonisation method in the document.
In summary, Poland does not have a dedicated carbon management strategy, and other strategic documents for Polish energy and climate policy do not define the role that carbon management could play in decarbonising the economy nor set ambitions expressed as quantitative targets for planned capture or storage volumes. Moreover, strategic documents reveal a problematic linkage of CCS deployment with coal technologies—for example by declaring the possibility of installing capture infrastructure on coal‑fired power units. This is at odds with the spirit of EU climate policy and distracts attention from CCS applications with the greatest potential, such as decarbonising cement and lime production. Although strategic documents record intentions to take concrete steps to facilitate CM deployment, such as CCfD schemes or adoption of a strategy, several years after these commitments were made there is still a lack of concrete follow‑through, for example in the form of draft legislation.
