Fast Facts
| Minimum Financial Resources | No statutory minimum |
| OPG Application Stamp Duty | PLN 616, approximately EUR 140, for domestic gas trading |
| OGZ Application Stamp Duty | PLN 4,244, approximately EUR 965, for cross-border gas trading |
| Annual Licence Fee | 0.05% of revenues, minimum PLN 1,000 (approx. EUR 230) and maximum PLN 2,500,000 (approx. EUR 580,000) |
| Main Import Infrastructure | Baltic Pipe 10 bcm/year and Świnoujście LNG 8.3 bcm/year following expansion, with a second LNG (FSRU) terminal in Gdańsk expected |
| Exchange Trading | Over 80% of Polish gas trading is done via TGE |
Poland Gas Market Fundamentals
Natural gas trading in Poland takes place in a liberalised market aligned with EU rules and regulated by the Energy Regulatory Office, URE.
Wholesale gas is traded over the Virtual Trading Point, with TGE operating a cleared gas market. Over 80% of trading in Poland is done via the exchange.
This liquidity stems largely from the gas release programme (Art. 49b Energy Law Act), which obliges entities holding at least 10% of import capacity to sell 55% of gas supplied to the network via TGE, in practice applying only to Orlen.
Following the 2022 shutdown of Russian transit via the Yamal pipeline, Poland depends on imports for the bulk of its gas, mainly through Baltic Pipe (from Denmark and Norway) and the Świnoujście LNG terminal, with secondary flows from Germany, Lithuania, Slovakia and Ukraine.
Natural gas accounts for just under 15% of primary energy consumption in Poland.
Gas-fired power generation is expected to drive a sharp increase in domestic demand as new plants connect to the national system.
When Is a Licence Required in Poland's Gas Market?
Polish law requires a separate OPG licence for domestic gas trading and supply, and an OGZ licence for cross-border gas trading, including import and export.
Pure transit activity may be excluded from licensing obligations. Sales of gas at the supply point of the Świnoujście LNG terminal are exempt from the OGZ requirement.
Cross-border licence holders must maintain storage capacity equal to 30-day average imports, deliverable into the Polish system within 40 days; an OGZ licence is revoked if this reserve is not maintained.
OGZ holders also face a diversification obligation capping imports from a single non-EU source at 33%, excluding LNG terminal imports, applying in practice only to the Ukrainian border.
What Are Poland's Gas Market Licence Requirements for EU and Non-EU Entities?
EU Gas Traders: Companies with a registered office in the EU, Switzerland, EFTA/EEA or Türkiye can apply directly for a Polish OPG and/or OGZ licence without establishing a local branch, submitting equivalent registration documents.
Non-EU Gas Traders: Entities without a registered office in one of those jurisdictions do not qualify for the direct-licensing route and must establish a qualifying presence within one of them (EU, Switzerland, EFTA/EEA or Türkiye) before they can be licensed.
All applicants must demonstrate sufficient financial resources (typically evidenced via corporate guarantee), technical capability, professionally qualified staff, and no outstanding tax arrears.
Balancing in the Poland Gas Market
Gaz-System is Poland's fully state-owned gas TSO and manages daily system balancing under the EU Balancing Network Code.
Network users must maintain a daily balance. The TSO balances the network exclusively via short-term standardised products traded on the exchange.
Poland's gas trading window closes earlier than on other European hubs, at 15:30 rather than 18:00.
Gaz-System collateral is generally required unless the applicant is registered in an EU/EFTA/EEA country and holds a Baa2/BBB or higher rating. Where required, collateral is set at 125% of the highest of: the user's obligations to Gaz-System, twice the monthly transmission fee, or PLN 150,000 (approx. EUR 34,000).
Transmission Capacity in the Poland Gas Market
Shippers must hold the relevant OGZ licence and sign a Transmission Service Agreement with Gaz-System before booking capacity.
Gaz-System uses its own GSA auction platform for cross-border capacity, with the Regional Booking Platform (RBP) used for the GCP Gaz-System/ONTRAS point on the German border, following an ACER decision.
Main supply corridors include Baltic Pipe, the Świnoujście LNG terminal and secondary interconnection points with Germany, Lithuania, Slovakia and Ukraine.
The Ukraine interconnection point (Hermanowice) is currently used mainly for exports, with import capability described by the TSO as temporary.
Poland Gas Market Exchange(s)
TGE operates the cleared gas market over the Polish VTP. Title transfer occurs at the VTP, covering all H-gas entries and exits except the Yamal transit pipeline.
Exchange access requires onboarding with IRGiT, either directly as a member or through an existing clearing member. TGE membership includes a PLN 2,000 (approx. EUR 460) application fee and verification of up to 20 days.
Companies may also trade via a brokerage house instead of direct membership.
5 Market Entry Steps for Poland Gas Market
- 01Obtain an OPG licence from URE, and an OGZ licence if importing or exporting gas.
- 02Sign the Transmission Service Agreement with Gaz-System, register in IES (Information Exchange System) and establish or join a balancing group.
- 03Provide the required financial collateral.
- 04Register for cross-border capacity through GSA, or RBP for the German border where applicable.
- 05Apply to TGE Gas Exchange and onboard with IRGiT clearing.
- Post-Market Entry Reporting Obligations.
CorreggioNET, Poland Gas Market Access Report
Market Access Reports: CorreggioNET offers Pre-Market Entry Reports (PMER) as part of the PMER Library, providing firms with an A-to-Z guide for market entry.
CorreggioNET Alert Service: Helps you never miss a reporting obligation. Note that Poland has multiple gas market reporting obligations, combined with high regulatory volatility - the Energy Law Act is amended several times per year, often with little notice.
CorreggioNET Hotline: For your time-sensitive queries, the Regulatory Hotline Service provides direct support through an online interaction with a qualified regulatory specialist.
Consulting Solutions: For those firms which require additional assistance, Correggio Consulting is on hand to assist with all your licensing needs:
- Obtaining an OPG / OGZ licence in Poland;
- Transmission Service Agreement with Gaz-System
- TGE Gas Exchange registration;
- Onboarding with IRGiT clearing;
- Storage & diversification compliance;
- Corporate structuring;
- EFET contract negotiation;
- Yearly compliance audits.
Market Info
Stay Compliant After Market Entry
Entering a new market is only the beginning.
Once trading activity starts, the real challenge is staying compliant with ongoing regulatory updates and reporting obligations. CorreggioNET supports this post-market entry stage through its regulatory platform and monitoring services.
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