PGE Polska Grupa Energetyczna S.A.

In PGE's opinion, the following issues should be considered: THE EXEMPTION FOR THE ENERGY SECTOR The progress of the liberalization of energy markets, the unbundling of network operations from generation and supply, the introduction of market-based mechanisms enabling non-restricted choice of contractors, has led to a significant increase in the level of competition on the energy sector in the recent years.

PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the Industrial Accelerator Act. Please see our feedback attached. Key messages: 1. Flexibility for the Member States in applying non-price criteria: Since the non-price criteria and the new requirements for the renewables public auctions and public procurement have not been fully tested in practice, the new rules should allow for…

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the revision of the Directive on the promotion of the use of energy from renewable sources as a prerequisite to further streamlining green energy in the pursuit to achieve climate neutrality by 2050.

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the European Commissions initiative to evaluate Directive 2014/25/EU on procurement by entities operating in the water, energy, transport and postal services sectors. PGE would like to provide its views concerning the evaluation regarding the above-mentioned directive and propose several improvements in the area of public procurement.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

PGE Polska Grupa Energetyczna S.A. (hereinafter: "PGE S.A.") acknowledges revising the provisions on the energy performance of buildings (hereinafter: "EPBD") as another important element of climate and energy policy leading to the achievement of climate neutrality of the European Union by 2050.

Warsaw, 03.11.2025 PGE Polska Grupa Energetyczna position on the Multiannual Financial Framework (MFF) 2028-2034 Key recommendations: • The new Multiannual Financial Framework (MFF) 2028-2034 must support investments into the energy sector as these investments serve as EU public goods, strengthen the electricity market and exert a disinflationary effect.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Department for International Affairs PGE Polska Grupa Energetyczna S.A. Warsaw, 03.06.2026 PGE Polska Grupa Energetyczna’s response to the revised European sustainability reporting standards Please find below PGE Polska Grupa Energetyczna’s comments on the revised European sustainability reporting standards (ESRS): ESRS 1 Ad.12 The ESRS says: When developing its entity-specific disclosures, the undertaking shall…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PGE guarantees a safe and reliable power supply to over 5 million households, businesses and institutions. PGE is consequently reducing its CO2 exposure aiming at ca. 60 million of CO2 tonnes saved cumulatively within the 2016-2026 timeline. The total budget of PGE for low-carbon projects until 2030 amounts to ca.

PGE position on the European Climate Law The PGE Capital Group is Poland’s largest energy sector company. Thanks to the combination of its power generation and distribution networks, PGE guarantees a safe and reliable power supply to over 5 million households, businesses and institutions. PGE is consequently decreasing its CO2 exposure with the aim to reduce ca.

The PGE Group would like to highlight the following issues with regard to the proposed Directive on Corporate Sustainability Due Diligence (CSDD). 1. The obligations introduced by CSDD put an extensive administrative burden on companies especially if we take into account other legislative proposals which are currently being proceeded in the European Parliament and in the Council e.g.

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the opportunity to provide its feedback as part of the evaluation of the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MSR). Please find our detailed feedback attached. Our key messages: - The EU ETS managed to reduce emissions in the covered sectors by around 50% from 2005 to 2024, primarily driven by the power sectors efforts.

Summary of PGEs Position The heat benchmark is of particular importance for district heating, as it directly determines the level of free allocation for heat production. In the published Annex, the heat benchmark value for 20262030 is set at 31.2 allowances/TJ (equivalent to 31.2 kg CO/GJ), which corresponds to a 34.1% reduction compared to 20212025 and reaches the maximum reduction level under the current benchmark…

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the recast of the Directive 2012/27/EU of the European Parliament and of the Council on energy efficiency (hereinafter: “EED”) as an opportunity for a reasonable adaptation of the current regulations to the Union’s climate neutrality objective by 2050.

PGE Polska Grupa Energetyczna S.A. welcomes the revision of the Directive of the European Parliament and of the Council on establishing a system for greenhouse gas emission allowance trading within the Union as an opportunity to ensure just transition and help the European Union in reaching its climate targets in the most cost-efficient way.

Position of PGE Polska Grupa Energetyczna S.A. on the proposal for a recast of the Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity • The revision of Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity leads to a significant increase in the…

Filed in Polish · English published by the European Commission

PGE welcomes the opportunity to provide its feedback on the renewable energy legal framework post-2030. Please see our comments attached. Our key points: 1) Setting the binding targets for renewable energy in 2040 is not necessary.

Please find below PGE Polska Grupa Energetyczna's key messages on the review of the EU Taxonomy climate delegated act. For specific comments please see the attached document. Key recommendations: The transition of gas-fired installations, including in the district heating sector, to full use of renewable or low-emission gaseous fuels by the end of 2035 requires broad access to decarbonized fuels.

Please find attached PGE's feedback. Our key messages: 1) Europe needs to both maintain its competitiveness and boost its defence capabilities. Implementing the climate target into the EU ETS will increase the costs of carbon allowances and, in turn, the energy prices, further burdening the EUs industry.

Key messages: The existing solutions based on achieving emission limits falling within the ranges of BAT-AELs should be maintained, as they have enabled considerable and cost-effective success in the area of emission reductions adjusted to the technical specificity of installations.

The PGE Capital Group is the biggest Polish energy utility with a total 56,03 TWh of electricity and 50,33 PJ of heat generated in 2019, which guarantees a safe and reliable power supply to ca. 5.27 million of electricity consumers. Nearly all of our units need to hold a relevant permit within the meaning of the Article 4 of the Industrial Emissions Directive (“IED”).

The PGE Group would like to highlight the following issues with regard to the proposed revision of the Non-Financial Reporting Directive (NFRD). 1. We welcome the extension of the scope of the Corporate Sustainability Reporting Directive (CSRD) to all large companies, which in our opinion will allow for the creation of level-playing field. 2.

PGE Polska Grupa Energetyczna S.A. (hereinafter: "PGE S.A.") welcomes the ECs initiative to boost the European production of technologies for achieving net-zero emissions. While boosting EUs potential in this area remains one of the crucial challenges for a successful energy transition, we believe that ECs proposal needs to be improved and EUs policy should support and prioritize all technologies that could help to…

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the draft Regulation of the European Parliament and of the Council on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU (hereinafter: "AFIR proposal") as an important element of the “Fit for 55” legislative package and one of the key milestones to achieve climate neutrality by 2050.

Please find PGE's feedback attached. PGE's key messages: 1) The electrification will play a key role in achieving EUs climate goals. In order to ensure the affordable energy prices, the focus must shift to key enablers, like ensuring sufficient public funding, supporting dispatchable capacities and sector coupling, investments in grid and storage.

Please find below PGE Polska Grupa Energetyczna's key messages on the Guidance on applying the do no significant harm principle under the 2028-2034 multiannual financial framework. For specific comments please see the attached document. Key recommendations: The DNSH principle is currently applied in a fragmented, inconsistent, and overly detailed manner.

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the opportunity to provide feedback on the draft Regulation on guidelines for trans-European energy infrastructure (TEN-E Regulation). We perceive the proposal as an opening to a discussion on adjusting the current provisions to better reflect new EU energy policy.

Trans-European energy infrastructure – revision of guidelines Appropriate revision of TEN-E Regulation may become a cornerstone of the new energy system model. The PGE Capital Group finds the European Commission’s view on the possible future shape of TEN-E Regulation properly envisaged with energy infrastructure as a key enabler for the energy transition.

Taking action by the European Commission in the area of methane emissions reduction may allow to obtain valuable information on the emission of this greenhouse gas, however, the introduction of new regulations in this area must be carried out with caution and proportionality so as not to impose burdensome obligations that will not result in noticeable environmental benefits, while they will constitute another…

PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the possible use of international carbon credits. Please find our feedback attached. Key messages: 1) Climate change is a global challenge that requires coordinated international action. The European Union has demonstrated strong leadership in emission reduction.

Below I present a summary of PGEs position on the EED post2030 framework. The full position, including detailed explanations, is provided in the attached document. PGE supports ambitious EU energy efficiency objectives, but stresses that the post 2030 revision of the Energy Efficiency Directive must be coherent, predictable and technically achievable, particularly for district heating systems in Central and Eastern…

The PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the revision of the EU Energy Security Framework. Our full position is presented in the file enclosed. Key messages: Among the policy options presented by the Commission in the call for evidence, Policy option 2 targeted reinforcement appears to be the most appropriate from the perspective of subsidiarity, the allocation of…

PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide its feedback on the revision of national targets and flexibilities in the EU climate policy framework after 2030. The discussion on the post 2030 climate targets must be firmly anchored in the current geopolitical reality, including heightened security risks, volatility of global energy markets and the need to safeguard…

Warsaw, 03.11.2025 PGE Polska Grupa Energetyczna position on the Multiannual Financial Framework (MFF) 2028-2034 Key recommendations: • The new Multiannual Financial Framework (MFF) 2028-2034 must support investments into the energy sector as these investments serve as EU public goods, strengthen the electricity market and exert a disinflationary effect.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please see the feedback of PGE Polska Grupa Energetyczna S.A. below: 1) The resilience of solar technologies: The Article 2 lists the circumstances which PV modules should withstand. The current wording is directly referring to the heat (hot-spot heating effects) or weather event like hail, but only indirectly suggesting the impact of harsh winter and low-temperatures occurring in some Member States: outdoor…

The PGE Group would like to highlight the following issues with regard to the proposed changes in the Regulation on wholesale energy market integrity and transparency and the Regulation establishing a European Union Agency for the Cooperation of Energy Regulators: 1.

PGE S.A. would like to thank for the opportunity to provide its feedback on the Regulation of the European Parliament and of the Council amending Regulation (EU) 2021/241 as regards REPowerEU chapters in recovery and resilience plans and amending Regulation (EU) 2021/1060 , Regulation (EU) 2021/2115, Directive 2003/87/EC and Decision (EU) 2015/1814. Please find attached our response to the public consultations.

Position of PGE Polska Grupa Energetyczna S.A. on the draft Commission Implemented Regulation (EU) amending the Activity Level Changes Regulation PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide feedback on the draft Commission Implemented Regulation amending and correcting Implementing Regulation (EU) 2019/1842 laying down rules for the application of Directive 2003/87/EC of…

PGE Polska Grupa Energetyczna S.A. (“PGE S.A.”) believes that the revision of the Decision (EU) 2015/1814 on the functioning of the market stability reserve (“MSR Decision”) may be an opportunity for an adaptation of the current mechanism to enable a cost-effective achievement of the EU’s climate objectives.