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Poland: New technical requirements for energy storage systems to be delayed; insurers already applying their own standards

5 min read
Poland: New technical requirements for energy storage systems to be delayed; insurers already applying their own standards

Key facts

  • The decree specifying energy storage installation methods, originally scheduled for September 20, 2026, was not signed by the minister
  • The Ministry of Development and Technology announced that work on the technical requirements for energy storage systems will continue
  • Investors are permitted to design projects according to 2002 regulations for a period of 18 months under the Construction Law amendment
  • Medium-sized energy storage capacity in Poland increased from 12 MWh to 165 MWh over the past year, according to the Energy Market Agency
  • PGE Renewable Energy concluded tenders for four co-located storage systems at sites adjacent to the Lotnisko wind farm

The new technical requirements for buildings, which were scheduled to take effect on September 20, 2026, and would have specified the location and method for installing energy storage systems, have not been finalized. The minister did not sign the decree, and the Ministry of Development and Technology has announced that work on its content will continue. Under the amendment to the Construction Law, investors are permitted to design projects according to the 2002 regulations for a period of 18 months.

Meanwhile, the number of medium-sized energy storage facilities is increasing. Data from the Energy Market Agency shows that their capacity rose from just under 12 MWh to 165 MWh over the past year. This compilation does not yet include the first large-scale battery storage systems, which are being connected to the grid this year.

Current regulations still lack a unified set of detailed requirements for energy storage systems, particularly those installed inside buildings. Designers and fire safety experts are left to independently assess what measures are sufficient. Insurers, however, evaluate the same installations from the perspective of the worst-case scenario. The question arises as to what happens when an uncontrolled temperature increase, known as thermal runaway, begins in a single cell. Such fires are difficult to extinguish, and the flames can reignite after many hours. A storage unit located next to a production hall could spread the fire to the entire facility, according to Grzegorz Templin, head of the Engineering Risk Assessment Team at SALTUS Ubezpieczenia.

Checklist in place of regulation

Insurance providers apply similar criteria when underwriting lithium-ion battery energy storage systems with capacities exceeding 20 kWh. Their assessments rely on standards such as the American NFPA 855, FM Global guidelines, and German VdS recommendations. Grzegorz Templin outlines the key requirements that risk engineers most frequently verify:

Additional mandatory features include fixed fire suppression systems, an emergency response plan with practical training, and a firewater retention tank to prevent contaminated runoff from reaching the soil. A manufacturer’s warranty and a signed service agreement also improve the risk profile. For large-scale installations, insurers further require that facilities be divided into complexes of no more than 500 square meters, with a minimum separation distance of 10 meters between them.

SALTUS Ubezpieczenia has adopted these guidelines as standard industry practices. While the volume of inquiries regarding energy storage systems and battery-equipped warehouses is increasing, the growth remains gradual rather than exponential. Energy storage units with a capacity of up to 250 kWh, when integrated as part of a photovoltaic installation, can be included in the coverage for damage to the photovoltaic system. Larger installations are assessed on a case-by-case basis upon request from insurance brokers. Following a risk assessment, the company may assume the risk independently or share it with other insurers through co-insurance, a structure where multiple insurers jointly cover a single risk, each responsible for their allocated portion, according to Grzegorz Templin of SALTUS Ubezpieczenia.

The most challenging scenario involves energy storage facilities located inside industrial halls.

The draft regulation was submitted to the European Commission for notification in August. It proposes, among other measures, a cap of 600 kWh on the total capacity of energy storage systems within a single fire compartment of a building that does not serve exclusively as an energy storage facility. Insurers are moving in the same direction, requiring that any storage system installed inside a building be housed in a fire-rated room with access for the fire brigade.

The energy storage industry, however, argues that new regulations should account for the specific characteristics of battery technology. The Polish Energy Storage Association has also established an Expert Commission on Fire Protection Requirements for Energy Storage Systems.

The documents determine the pace of the coordination process.

The risk assessment for energy storage facilities relies heavily on documentation. Insurers request cell and system-level certifications, safety data sheets for extinguishing agents, and detailed descriptions of how detection systems trigger suppression. If any of these documents are missing, the insurer is forced to assume the worst-case scenario. The same aerosol fire suppression generators can be classified either as standalone devices or as components of an integrated detection and suppression system. The specific classification seen by the insurer depends entirely on the descriptions provided in the technical documentation.

Regulations will eventually be introduced, but energy storage facilities are being built right now. Until those rules are in place, the safety of installations is determined by the quality of the design and the risk assessment. Experience shows that projects most often stall due to incomplete documentation rather than technological issues. Therefore, it is best to engage with insurers or brokers during the design phase, not after equipment has been purchased. Modifying plans on paper is significantly less costly than retrofitting a completed room, according to Grzegorz Templin.

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Pvola take

The delay in finalizing technical standards creates regulatory uncertainty for developers and installers, forcing them to rely on outdated 2002 regulations for the next 18 months. This gap complicates project planning because insurers are already applying their own worst-case scenario standards, which may conflict with future official requirements. Developers must navigate this ambiguity by engaging early with insurers to ensure their designs meet current underwriting criteria while awaiting the final decree.

Frequently asked questions

Why are the new technical requirements for energy storage systems in Poland being delayed?

The minister did not sign the decree scheduled for September 2026, so the Ministry of Development and Technology will continue working on its content. Investors can currently design projects according to 2002 regulations for an 18-month transition period.

How has the capacity of medium-sized energy storage facilities in Poland changed over the past year?

Capacity rose from just under 12 MWh to 165 MWh over the past year, according to Energy Market Agency data. This figure excludes large-scale battery storage systems currently being connected to the grid.

How are insurers currently handling risk for energy storage systems installed inside buildings in Poland?

Insurers evaluate installations from a worst-case scenario perspective because unified detailed requirements are lacking. They may assume risk independently or use co-insurance structures where multiple insurers jointly cover a single risk.