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URE issues guidelines on mandatory electricity hedging strategies

Managing Partner Correggio Consulting BV (Brussels) Founder-CEO CorreggioNET │ Managing Director, REMITREP Services BV (Amsterdam) │ Founder ZETA (Zero Emissions Traders Alliance) (Abu Dhabi)
Region: Poland | Commodity: Power | Topic: Risk Management, Compliance
On 30 July 2026, Poland's URE published Information No. 37/2026, setting out guidelines on the hedging strategies now required under Article 10e of the Polish Energy Law. The obligation hits all energy undertakings trading electricity, licensed or exempt.
First strategy due to URE by 30 January 2027; renewals every three years, submitted by 15 December of the preceding year.
The purpose is to shore up supply continuity and financial/operational resilience- scaled to the undertaking's size, market liquidity (especially short-term), transaction values, customer base and risk profile. URE isn't dictating commercial choices ; the undertaking picks its own risk-mitigation measures but must show they're proportionate.
The strategy must address price, profile, volume, concentration, FX, liquidity and counterparty credit risk, plus anything else threatening supply continuity via measures covering unprofitable-contract risk (REMIT Art. 2(6)), day-ahead/intraday liquidity, and supply continuity.
Seven mandatory sections are required: undertaking description & business plan; risk identification/assessment; strategy objectives; risk-mitigation measures; financial liquidity management (incl. immediate URE notification if supply is threatened); governance framework; review/update triggers.
No standard template, undertakings build the strategy around those seven sections, scaled to their own scale and risk profile. URE can require supplementation if it finds the measures insufficient, and the Guidelines themselves may still be revised.
For more information on how these changes may affect trading operations in Albania, please contact CorreggioNET at info@correggionet.eu