The EU is designing its energy efficiency architecture for the decade after 2030. For Poland's electricity sector, the stakes are concrete — and they come with a price tag.
In a position paper on the EU's post-2030 energy efficiency regulatory framework, PKEE (Polskie Komitet Energii Elektrycznej — the Polish Electricity Committee, representing the country's electricity producers, distributors and suppliers) argues that modernising Poland's district heating infrastructure alone could cost up to €110 billion by 2050. That figure shapes the industry body's core demand: the post-2030 framework must prioritise flexibility and cost-effectiveness over prescriptive binding targets.
On renewable and waste heat integration in district heating, PKEE calls for a 15% threshold by 2035 — a target it considers achievable without requiring infrastructure investment at a pace Poland's sector cannot sustain. The position paper argues the target should escalate gradually rather than hitting a hard cliff, and that electrification should be the primary mechanism: heat pumps and electric boilers, with green hydrogen as a longer-term option as production costs fall.
To mobilise private capital for the transition, PKEE wants the EU framework to actively promote Energy Service Company (ESCO) models — where private firms fund efficiency upgrades upfront and recover their investment from the resulting energy savings. This Energy-as-a-Service approach, the paper argues, reduces the need for direct state spending and distributes financial risk more broadly across the market.
Beyond targets, the position paper contains two governance demands. First, PKEE calls for harmonised EU standards for energy audits across member states — so that efficiency assessments are comparable and national reporting rests on a common methodology. Second, it frames smart metering and data management infrastructure as a mandatory prerequisite, not an optional upgrade: without reliable, real-time energy data, efficiency policy becomes difficult to design, verify, or enforce.
PKEE's paper is a lobbying document and should be read as one — but it surfaces a real structural tension in EU efficiency policy. The member states with the oldest, most fossil-fuel-dependent heating infrastructure are disproportionately in Central and Eastern Europe, and they face modernisation costs that their western counterparts do not. How Brussels calibrates binding targets against flexible tools in the post-2030 framework will determine whether the energy transition is distributed equitably across the bloc, or concentrates financial strain in the member states least positioned to absorb it. Poland's €110 billion figure is the number Brussels will need to answer.
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