Poland

This national factsheet was developed in cooperation with CAN Europe and the European Environmental Bureau (EEB), based on the expertise and inputs of their Polish member organisations and partners. It draws on responses to a dedicated questionnaire circulated across the Polish environmental and renewable energy NGO network, with the aim of assessing the state of play of the implementation of Renewable Acceleration Areas (RAAs) under Article 15c of the Renewable Energy Directive (RED III).
The factsheet provides a concise overview of governance arrangements, the scope and characteristics of RAAs, environmental safeguards, and public participation in Poland. It concludes by identifying key gaps and formulating targeted recommendations at national level.

Co-authors: Flore Belin (CAN Europe), Maya Perera (EEB) with the support of Marta Anczewska and Maria Niewitała-Rej (Ireform) and Wojciech Szymalski (Institute for Sustainable Development Foundation)

Last updated: April 2026

Overall assessment

Poland has initiated the legal transposition of RAAs under RED III through amendments adopted in October 2025. The current approach builds on the existing, highly decentralised spatial planning system and assigns a central role to regional authorities (voivodeships) in the designation of RAAs.

While the legislative framework introduces procedural simplifications and clarifies the legal status of RAAs, implementation is still at an early stage. The designation of the first RAAs is not expected before the end of 2026, which goes beyond the February 2026 deadline set by RED III. At this stage, the effectiveness of RAAs in significantly accelerating renewable energy deployment remains uncertain and will largely depend on the capacity of regional authorities, the timely completion of sensitivity mapping (as of April 2026, these have already been published and are linked at the end of the factsheet), the quality of coordination between national, regional and local levels, and investor take-up once RAAs are ready. On the final point, some Polish energy developers and investors have expressed informally that they’re daunted by RAA processes.

At the same time, the RAA process has triggered useful discussions on longstanding structural challenges, including permitting capacity, staffing constraints and the need for better spatial data, which could support system-wide improvements in the medium term.

Transposition and governance

Status: PARTIALLY TRANSPOSED

Poland has partially transposed RED III Article 15c through the Act of 9 October 2025 ^[1] amending the Act on the Promotion of Electricity Generation in Offshore Wind Farms. The law entered into force in November 2025. The amendments introduce the concept of RAAs for the first time, on the basis of existing renewable energy potential maps (as in RED III Article 15b) and local spatial development plans that permit the construction of a given type of renewable energy installation. While the amended law explicitly mentions that renewables and the necessary grid or other installations are to be included in RAA (Article 160n), additional legislation covering remaining RED III provisions, including grids and storage under Article 15e, is expected in the first quarter of 2026 via the draft law UC-118 ^[2].

RAA designation is entrusted to regional self-government bodies (voivodeship assemblies), acting in coordination with municipalities. RAAs constitute a new planning instrument under Polish law and must be embedded within existing local spatial development plans. As a result, RAA designation is closely linked to the pace and priorities of local planning procedures.

This governance model reflects the subsidiarity principle and established administrative practice in Poland. However, it also introduces a risk of uneven implementation across regions and delays linked to local political dynamics and administrative capacity.

As of April 2026, at least four of Poland’s 16 voivodships have started the process of preparing RAA plans: Województwo wielkopolskie ^[3], Województwo mazowieckie ^[4], Województwo łódzkie ^[5] Województwo dolnośląskie ^[6].

Scope and characteristic of the RAAs

Polish legislation does not define a minimum or maximum size for RAAs. Instead, RAAs must overlap with:

renewable energy potential mapping developed under Article 15b RED III, and
local spatial development plans permitting the relevant technology.

RAAs may be designated for specific renewable energy technologies, including onshore wind, solar, and potentially other renewable technologies such as biogas, geothermal and hydropower. A single voivodeship may adopt several RAA plans, for one or several technologies.

Priority is given to areas such as industrial and post-industrial zones, degraded land unsuitable for agricultural use, built-up areas, artificial water reservoirs and transport or technical infrastructure corridors. RAAs may be based on existing planning instruments or newly designated areas, provided local spatial plans are adopted or amended accordingly.

Inclusion of grids and storage: The Polish definition of RAAs explicitly includes the installations and infrastructure necessary to connect renewable projects to the grid, as well as storage facilities connected to renewable energy installations.

Environmental safeguards

Exclusion of environmentally sensitive areas: Environmental safeguards are embedded in the RAA framework through explicit exclusions and planned strategic assessments. The law explicitly excludes RAAs from being designated in:

National Parks, Nature Reserves and Landscape Parks,
Natura 2000 sites,
priority landscapes,
main migratory routes of birds and mammals, and
other sensitive areas identified through nature sensitivity mapping, with limited exceptions for artificial surfaces.

Sensitivity mapping and data use: Regional Directors for Environmental Protection have now published environmental sensitivity maps within three months of the law entering into force (by early 2026). These maps are expected to play a central role in guiding RAA designation and avoiding biodiversity conflicts.

Strategic Environmental Assessments (SEAs): SEA are required for RAA plans. At project level, investments located within RAAs are generally exempt from individual environmental impact assessments, unless cross-border impacts are identified. While this approach aims to accelerate permitting, the practical application of mitigation measures and safeguards remains to be clarified.

Mitigation measures: The legislation refers broadly to mitigation measures to avoid or significantly reduce environmental impacts, including technical measures to limit disturbance to protected species. However, detailed, binding mitigation standards at RAA level have not yet been specified.

Public participation and engagement

Public participation is foreseen during the preparation of RAA plans, with consultations expected to take place at regional level once the planning phase begins. At the time of writing, no public consultations on concrete RAAs have yet been conducted.

Stakeholder engagement to date has focused primarily on the legislative process, including civil society input on the draft law. Future implementation will likely involve multiple parallel or sequential consultation processes across different regions, which could pose challenges in terms of accessibility, capacity and balanced representation of views.

Designating an RAA requires a Strategic Environmental Assessment (SEA). However, Poland’s SEA regulations set only a minimum standard of public participation: an online announcement, a public notice, and the option to submit written comments. This often leads to ‘invisible’ consultation processes that go unnoticed by the public. However, beyond the SEA, RAA designation also requires the development of an on-the-spot local spatial plan. The consultation requirements for spatial plans are more robust, and can be found here ^[7]. It’s likely that most meaningful public deliberation on RAAs will occur during this spatial planning process.

Ensuring transparency, early information and meaningful participation will be key to building public trust and preventing local opposition, particularly in regions with limited experience of large-scale renewable energy deployment.

Recommendations at national level

Based on inputs from Polish NGOs and experts, the following priority recommendations emerge:

Provide clearer national guidance to regional authorities on RAA designation criteria, timelines and minimum standards, in order to reduce fragmentation and ensure more consistent implementation across voivodeships.
Clarify environmental mitigation requirements at RAA level, including common benchmarks and good practice guidelines, to strengthen legal certainty and biodiversity protection while maintaining accelerated procedures.
Strengthen public participation frameworks, including early information, accessible consultation formats and adequate resourcing for both authorities and civil society engagement at regional level.
Address systemic capacity constraints by maintaining and operationalising the proposed increases in staffing and funding for permitting and environmental authorities, beyond the RAA framework itself.

Poland

Poland

Overall assessment

Transposition and governance

Scope and characteristic of the RAAs

Environmental safeguards

Public participation and engagement

Recommendations at national level

Reference list