Changes to the White Certificates system and the role of CROEF
For years, the white certificates system has been one of the key instruments supporting improvements in energy efficiency in Poland. In the coming years, however, it will undergo a significant transformation - both organizational and systemic. One of the most important elements of this change is the launch and expansion of the Central Register of Final Energy Savings (CROEF), which will become the central hub for reporting and aggregating data on energy savings. For businesses, this means new rules, greater transparency, and the need for better preparation of energy efficiency projects.
What are White Certificates and why were they introduced?
White certificates, formally known as energy efficiency certificates, were introduced as a market-based mechanism designed to stimulate investments that reduce final energy consumption. The system is based on the assumption that energy savings constitute a legitimate “resource” that can be measured, verified, and traded.
Certificates are granted for implementing projects that improve energy efficiency, such as modernization of installations, technological processes, or infrastructure. The obtained certificates can then be sold on the Polish Power Exchange or used to meet the energy efficiency obligation imposed on obligated entities. The system combines environmental objectives with market and financial mechanisms.
Why is the White Certificates system changing?
The changes planned from 2026 onward are primarily driven by the need to align national regulations with EU energy efficiency targets and to increase the credibility of reported energy savings. The current model - based on dispersed data sources and audit documentation - has proven insufficient from the perspective of achieving Poland’s national final energy savings target by 2030. The new system aims to ensure full traceability of energy savings - from the support programme, through a specific project, to its contribution to the national energy balance. In this context, CROEF will play a crucial role.
What is the Central Register of Final Energy Savings (CROEF)?
The Central Register of Final Energy Savings (CROEF) is an IT system designed to aggregate information on final energy savings achieved by end users as a result of national and EU programmes supporting energy efficiency improvements.
CROEF covers energy savings achieved between 1 January 2021 and 31 December 2030, which are counted towards the national final energy savings target. The register is not used to grant white certificates; rather, it provides a coherent and centralized data source intended to prevent double counting of savings and to increase the transparency of the entire system.
Beyond the white certificates scheme, CROEF includes only those programmes and financial instruments explicitly listed in the Announcement of the Minister of Climate and Environment on the list of programmes and financial instruments supporting energy efficiency improvements at the end-user level.
Who is required to report to CROEF?
The obligation to report to the Central Register of Final Energy Savings (CROEF) does not apply to all market participants. Data is primarily submitted by institutions that implement support programmes aimed at improving energy efficiency among end users.
Entities required to report include in particular:
- institutions concluding funding agreements for projects improving energy efficiency at the end-user level (e.g., operators of support programmes),
- public authorities implementing instruments within the energy efficiency system, including the President of the Energy Regulatory Office (URE) with regard to projects covered by the energy efficiency certificate scheme (white certificates).
Importantly, the reporting obligation does not apply directly to companies or other entities implementing energy efficiency investments. Applicants receiving financial support for a project are not required to submit data to the register themselves - the obligation lies with the institutions providing the support.
Reporting applies only to projects implemented within programmes and financial instruments listed in the official announcement of the Minister of Climate and Environment. Programmes not included in this list are not subject to reporting requirements.
What types of projects are included in CROEF?
The catalogue of projects eligible for reporting has been defined in a regulation of the Minister of Climate and Environment and includes, among others:
- thermomodernization, renovation, and low-emission projects,
- modernization or replacement of lighting, equipment, installations, district heating networks, and drives,
- energy recovery in industrial processes,
- modernization of technological, production, and IT processes,
- reduction of energy losses in transformation processes,
- measures aimed at reducing reactive power losses,
- infrastructure projects related to public transport,
- initiatives aimed at changing end-user behaviour, including educational and information campaigns.
This scope demonstrates that CROEF includes both traditional technical investments and so-called soft measures, provided they lead to measurable energy savings.
How will the application process for white certificates change?
From 2026 onwards, the process of submitting and assessing applications for white certificates will rely more heavily on digital tools and be linked with central data registers. A key change will be the operation of a single, coherent information ecosystem in which data from audits, support programmes, and implemented projects will be verified for uniqueness and consistency.
For companies, this means a stronger emphasis on the quality of energy efficiency audits, the need to clearly demonstrate that reported energy savings have not already been counted under another programme, and a more predictable, but also more formalized, application assessment process. Although CROEF itself is not a platform for submitting white certificate applications, its data will indirectly influence decision-making by increasing the consistency and transparency of the entire system.
What do these changes mean for companies?
For companies, the changes to the white certificates system primarily mean the need for a more strategic approach to energy efficiency projects. Planning investments in the context of available support programmes, reporting requirements, and the methodologies used to determine energy consumption reductions - as well as the possibility of combining energy effects - will become increasingly important.
The system is becoming less discretionary and more data-driven, based on comparable indicators. For well-prepared projects, this means greater predictability and a faster assessment path. For projects implemented on an ad hoc basis, however, the risk of rejection or delays will increase.
Summary
It is worth emphasizing that the introduction of CROEF and the planned changes to the white certificates system are not merely procedural adjustments, but part of a broader transformation in the approach to energy efficiency in Poland. The government aims to create a coherent, measurable, and verifiable system for accounting energy savings that will allow real progress toward national and EU targets to be assessed by 2030. From the administration’s perspective, this means greater control over data quality, while from the market’s perspective it reduces the risk of double reporting of the same energy effects.
Companies planning energy efficiency improvements will need to address the challenges of earlier investment planning, better preparation of documentation, and a more conscious selection of the support pathway - both in terms of white certificates and financial programmes subject to CROEF reporting. At the same time, the increasing transparency of the system may benefit companies that treat energy efficiency as a long-term operational and emissions strategy rather than a one-off investment activity. In the new model, well-documented, consistent projects with clearly demonstrated energy effects will have a competitive advantage.
