Poland has a large biogas feedstock base — its state-owned gas distribution operator, Polska Spółka Gazownictwa (PSG), ranks it fifth in the European Union (EU) for biogas substrate potential (PSG, September 2025) — yet almost no biomethane reaches its gas grid. The question for investors in 2026 is which projects can turn that resource into dependable cash flows. Our short answer: a project is investable when feedstock is contracted for most of the support period, a gas-grid connection or offtake is signed, revenue support is enacted law rather than a proposal, and the operator has a verifiable record in anaerobic digestion (AD). The legal piece moved in September 2026 but is not yet complete.
Europe: a 2030 target well ahead of delivery
The European Commission's REPowerEU plan of May 2022, designed to end reliance on Russian fossil fuels, set an ambition of 35 billion cubic metres (bcm) of biomethane a year by 2030, with an estimated investment need of €37 billion (European Commission). The European Biogas Association (EBA) reported that Europe produced 5.2 bcm of biomethane in 2024, 4.3 bcm of it in the 27 EU member states, from 1,620 facilities (EBA, December 2025). Installed capacity was about 7 bcm a year in early 2025 (EBA, June 2025).
EU gas legislation adopted in 2024 prioritises grid connection of renewable gases and allows tariff discounts (Osborne Clarke, October 2024). Connection costs remain a national matter: grid operators pay 60% in France and 75% in Germany, while some markets charge producers in full (EBA, February 2024).
Poland: a biogas base with almost no biomethane
The National Agricultural Support Centre (KOWR) listed 209 agricultural biogas plants with 188.8 megawatts of electrical capacity (MWe) at 28 May 2026. Only two produced biomethane. In 2025 the registered plants produced 515.2 million cubic metres of biogas, mostly burned for power and heat, and 2,500 cubic metres of biomethane (WysokieNapiecie.pl, June 2026; Magazyn Biomasa, June 2026). Non-agricultural biogas is registered separately with the Energy Regulatory Office (URE) (URE, November 2023).
PSG connected the first biomethane plant, at a sugar factory in Strzelin, in September 2025 (PSG). By December 2025 it held 1,088 active connection decisions but only 14 signed connection agreements, and expected four to five connections in 2026 (Magazyn Biomasa, December 2025). That gap is the first filter we apply.
Support schemes: what is law and what is pending
Poland's Renewable Energy Sources Act (RES Act) already supports small plants. The scheme for larger biomethane plants passed the Senate without amendments on 24 September 2026 and awaits the President (Gramwzielone.pl, September 2026).
| Instrument | Scope | Status | Key terms |
|---|---|---|---|
| Feed-in tariff (FIT), electricity | Biogas below 500 kilowatts (kW) | In force | Guaranteed purchase at a fixed price |
| Feed-in premium (FIP), electricity | Biogas, 500 kW to 1 megawatt (MW) | In force | Premium on top of market sales |
| FIP, biomethane | Plants up to 1 MW | In force since October 2023 | Reference price of 538 Polish złoty (PLN) per megawatt-hour (MWh) for biogas or PLN 545/MWh for agricultural biogas; 20 years, ending by 30 June 2048 |
| URE electricity auctions | Biogas and biomass baskets | In force; 2025 biogas baskets not held for lack of bids | Pending amendment cuts the minimum delivery obligation from 85% to 65% |
| Biomethane auctions (contract for difference, CfD) | Plants above 1 MW | Passed Sejm (lower house) 4 September and Senate 24 September 2026; awaiting President and EU state-aid clearance | Up to 20 years; production within four years; two baskets split at 2 MW |
| Direct pipelines | Gas delivered to end users off the public grid | Same pending amendment | Notice to URE within 30 days of first delivery replaces prior consent |
| National Fund for Environmental Protection and Water Management (NFOŚiGW) grant | New grid-connected biomethane plants | Call ran 18 May to 18 August 2026 | PLN 300 million call; grants up to 45% of eligible costs |
Two cautions follow. First, similar provisions were part of a 2025 amendment that President Karol Nawrocki vetoed on 21 August 2025 over its wind-power content, while saying renewables must leave room for biogas (Gramwzielone.pl, August 2025). He has 21 days from submission to sign, and a veto needs a three-fifths Sejm majority to override (Constitution, Article 122). Second, the auctions cannot run until the European Commission clears them as state aid and reference prices are set by regulation (Farmer.pl, September 2026). The government estimated about 300 million cubic metres a year from roughly 50 plants averaging 2.8 MW (Magazyn Biomasa, July 2026).
Revenue depends heavily on support. A December 2025 analysis set the biomethane reference prices of PLN 538–545/MWh against a gas market price of about PLN 156/MWh (WysokieNapiecie.pl, December 2025). Most revenue therefore comes from the scheme, not the gas market.
The investability checklist
The support scheme sets the revenue framework; the project determines whether it can be earned.
| Area | What to verify | Warning signs |
|---|---|---|
| Feedstock | Contracted volumes and prices; tenor matched to debt and support periods; transport radius | Spot purchasing; single-supplier dependence; short contracts |
| Digestate | Legal route (digestate product, by-product or waste); storage; land or buyers | No contracted outlet; storage sized for average volumes |
| Permits and local acceptance | Zoning basis, environmental decision, building permit, council resolution where required | Active protests or pending appeals |
| Technology and operator | Reference plants of similar scale and feedstock; upgrading guarantees; operation and maintenance (O&M) contract | First-of-a-kind design; operator without AD track record |
| Revenue certainty | Eligibility under enacted law; URE certificate; grant interaction | Business case built on unenacted terms |
| Grid or offtake | Signed PSG connection agreement; capacity at the connection point; or a direct-pipeline offtaker | Only a statement of connection possibility |
| Capital and operating costs | Fixed-price engineering, procurement and construction (EPC) contract; feedstock, energy and maintenance budgets | Open-ended construction pricing; free feedstock assumed |
Feedstock. In 2025 about 91% of the 7.7 million tonnes fed to agricultural plants was waste or residues, led by distillery residue, slurry and fruit and vegetable waste (Magazyn Biomasa, June 2026). As new plants compete for these streams, price and tenor matter as much as volume.
Digestate. The same plants produced 6.1 million tonnes of digestate. Digestate can be marketed as a digestate product without an individual permit if it meets regulated standards (Strefa Agro, November 2023); an August 2024 regulation sets contaminant limits such as 5 mg of cadmium per kg of dry matter (Journal of Laws 2024 item 1261).
Permits. The agricultural biogas act of 13 July 2023 eased siting on farms, set 90 days for grid connection conditions for plants up to 2 MW, and lets plants above 1 MW be sited by municipal council resolution (KOWR; Agroprawnik, November 2024). Local politics is thus part of permitting: June 2026 coverage described concerns over odour, truck traffic and noise as a leading obstacle (Portal Samorządowy).
Grid and costs. PSG issues connection conditions within 90 days, charges a fee based on actual connection expenditure, and treats about 250 normal cubic metres an hour of biomethane as equivalent to 1 MWe (PSG). The ministry's reference-price method weighs investment, feedstock and operating costs, inflation and the discount rate (Ministry of Climate and Environment, November 2023) — the variables that drive project economics.
Capital structures: who carries which risk
- Project finance. Limited-recourse debt typically requires enacted revenue support, long-dated feedstock contracts, a fixed-price EPC contract and an experienced operator. Until the auctions are live, that is easiest to assemble for FIP plants up to 1 MW.
- Corporate balance sheet. Food processors, distillers and utilities with their own residues can fund plants internally; Poland's first grid-injecting plant sits at a sugar factory.
- Strategic co-investment. ORLEN signed a memorandum with the state food group Krajowa Grupa Spożywcza (KGS) in July 2025 and a partnership with KOWR in February 2026, targeting 0.24 bcm of biomethane a year by 2035 (ORLEN; KOWR).
- Grant stacking. NFOŚiGW grants can be combined with auction support, but the contract value is reduced accordingly (Gramwzielone.pl, January 2026).
For financial co-investors the question is where they enter: development risk before permits and connection agreements, or operating risk after commissioning. The pending law reduces revenue uncertainty for larger plants only once the first auction has been held.
What we watch next
- The President's decision on the RES Act amendment and its promulgation.
- European Commission state-aid clearance, the reference-price regulation and URE's first biomethane auction timetable.
- Conversion of PSG's signed connection agreements into operating plants.
- Results of the NFOŚiGW biomethane grant call that ran until 18 August 2026.
- KOWR data for 2026 and the EBA's next statistical report, to see whether Polish output moves beyond pilot scale.
Figures are the latest available at 26 September 2026; KOWR data cover agricultural biogas only. Legislative status may change after the date of writing.
OKETO evaluates biogas and biomethane opportunities with a focus on feedstock contracts, connection certainty and whether revenue support is enacted law, subject to structure, jurisdiction and eligibility.
Sources
- European Commission — Biomethane (REPowerEU target and Biomethane Action Plan), accessed 26 September 2026
- European Biogas Association — 15th Statistical Report unveiled, 10 December 2025
- European Biogas Association — European biomethane capacity hits 7 bcm, 26 June 2025
- European Biogas Association — From plant to grid: navigating biomethane injection, 23 February 2024
- Osborne Clarke — Regulation (EU) 2024/1789 and its impact on renewable, natural gas and hydrogen markets, 10 October 2024
- WysokieNapiecie.pl — KOWR: 515.2 mln m3 of biogas and 2.5 thousand m3 of biomethane produced in 2025, June 2026
- Magazyn Biomasa — KOWR publishes new data: 209 agricultural biogas plants, 10 June 2026
- Energy Regulatory Office (URE) — Templates for the biomethane support mechanism, 24 November 2023
- Energy Regulatory Office (URE) — Amendment to the RES Act: new support systems, 29 September 2023
- Ministry of Climate and Environment — Regulation on the biomethane reference price, 14 November 2023
- Kochański & Partners — New biomethane law, 25 September 2023
- Polska Spółka Gazownictwa — First biomethane plant connected to the gas grid, September 2025
- Magazyn Biomasa — PSG: we are ready to connect further biomethane plants, 4 December 2025
- Polska Spółka Gazownictwa — Ready for biomethane (connection terms and capacity map), accessed 26 September 2026
- Energy Regulatory Office (URE) — RES auctions 2025 results, 11 July 2025
- KPMG Poland — Amendment to the RES Act: biomethane and biogas measures before the Sejm, 31 July 2026
- Magazyn Biomasa — Government adopts RES Act amendment with biomethane support, 15 July 2026
- Farmer.pl — Sejm passes new RES Act amendment, 4 September 2026
- Farmer.pl — Senate backs RES changes for biomethane, 24 September 2026
- Gramwzielone.pl — New RES rules go to the President without Senate amendments, 24 September 2026
- Gramwzielone.pl — President vetoes wind law, 21 August 2025
- Constitution of the Republic of Poland (English text, Refworld), Article 122
- Gramwzielone.pl — RES Act amendment: changes for biomethane and biogas producers, 14 January 2026
- KOWR (gov.pl) — Facilitations for agricultural biogas plant investments (Act of 13 July 2023)
- Agroprawnik — Investment facilitations for agricultural biogas plants, 20 November 2024
- Strefa Agro — Changes to fertiliser rules: digestate products, 16 November 2023
- Inforlex — Regulation of the Minister of Agriculture of 9 August 2024 (Journal of Laws 2024 item 1261)
- Portal Samorządowy — Protests block biogas plant development in Poland, 14 June 2026
- NFOŚiGW (gov.pl) — Call supporting the biomethane sector, 18 May 2026
- ORLEN — ORLEN and Krajowa Grupa Spożywcza to increase biomethane production, 14 July 2025
- KOWR (gov.pl) — Biogas and biomethane at the core of ORLEN–KOWR cooperation, 12 February 2026
- WysokieNapiecie.pl — Polish biomethane will not be cheap, 16 December 2025