BEV Charging Infrastructure in CEE — Potential for Overcoming Authorized & Administrative Limitations

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Growth of EV charging infrastructure in Central-Jap Europe — is it fast sufficient? 

In an effort to reply this query, let’s have an in depth have a look at the largest market of Central-Jap Europe. As of spring 2025, Poland has about 9,300 publicly accessible charging factors, practically 3,000 of that are quick DC chargers, making up 31% of the whole. This represents a 44% year-over-year improve, with the DC section experiencing notably fast development — up 66% y/y — outpacing the growth of slower AC units. Trade information confirms this development: within the first 11 months of 2024 alone, practically 1,000 new fast-charging factors had been launched — greater than twice as many because the earlier yr — and the whole energy capability of the infrastructure elevated by one-third in simply six months, reaching roughly 300 MW.

This development is primarily pushed by personal capital, as operators are rising investments regardless of weak demand; EVs accounted for under 3% of recent automobile registrations in 2024. Concurrently, Poland continues to lag behind the EU in BEV fleet penetration, leading to comparatively low infrastructure utilization and extended funding payback intervals. 

The first impediment to additional BEVs growth and assembly AFIR targets

Regardless of the spectacular tempo of DC infrastructure development in 2024, the first impediment to additional growth stays the small and unstable BEV fleet, worsened by inconsistent assist packages. And not using a coordinated package deal of demand- and supply-side incentives, Poland dangers not solely failing to fulfill AFIR targets but additionally widening its aggressive hole with main e-mobility markets within the EU. Latest months have demonstrated that the elimination or sudden suspension of important assist instruments ends in a direct decline in BEV gross sales. When entry to a well-liked financing possibility beneath the federal government’s “Mój elektryk” program was halted, the market responded sharply — new EV registrations dropped by as a lot as 37% year-over-year in November 2024. This quick response illustrates that, as we speak, the system of subsidies and financial incentives shouldn’t be merely a stimulus however a key requirement for the event of the EV market in Poland. Uncertainty in regards to the continuity and availability of such assist additionally makes infrastructure traders extra cautious. With such low BEV market share, any demand fluctuation can threaten the profitability of charging station tasks.

Authorized and administrative features which impression EV charging infrastructure investments

As the expansion of the EV person base turns into tougher to foretell, operators more and more delay funding selections or scale down deliberate installations — akin to abandoning higher-powered chargers or places exterior main cities with decrease person turnover. The event of publicly accessible charging stations in Poland faces a barrier that not often surfaces in public debate however is crucial for funding dynamics: advanced and sluggish grid connection procedures. Though vitality regulation units most deadlines of 30 days for low-voltage connections (as much as 1 kV) and 150 days for medium voltage (above 1 kV), distribution system operators (“DSOs”) usually make the most of the complete cut-off dates. Within the case of quick chargers requiring larger capability, your complete administrative and building course of can lengthen considerably. Poland is among the many slowest markets in Europe on this regard.

Challenges in acquiring electrical energy connection for brand spanking new EV charging infrastructure in Poland

Regardless of their comparatively modest energy (the commonest DC chargers vary from 150 to 200 kW), connection requests are routinely categorized within the third connection group, which is often used for medium-voltage services. This classification offers DSOs extra time to arrange the situations, nevertheless it additionally extends the method and will increase prices. Furthermore, communication channels with DSO technical groups are restricted, and suggestions is just supplied with the formal connection situations package deal. If it emerges through the course of that solely a portion of the requested capability is out there, the investor doesn’t be taught this till the process is full.

There is no such thing as a mechanism for “gentle” consultations that may permit for early-stage mission rescaling based mostly on precise grid capability. Furthermore, Polish authorized rules don’t differentiate charging stations as they do for renewable vitality sources or public transport. As an alternative, charging infrastructure is considered some other vitality shopper, regardless of its function in serving to to fulfill local weather targets and fulfill obligations beneath the AFIR regulation.

It’s additionally vital to notice that establishing the ability infrastructure for public EV charging stations requires not solely out there capability within the grid but additionally appropriate land situations for linear investments. This primarily includes securing land corridors for cable routes, establishing transformer stations, or putting in metering tools. In apply, securing property entry has develop into one of the vital time-consuming and unpredictable features of your complete funding cycle, considerably complicating DSO operations. In city areas, practically each plot has a definite proprietor, whereas in suburban and rural areas, designated cable routes continuously battle with agricultural or forest land. The absence of consent from even a single proprietor can necessitate a redesign of your complete mission, resulting in months of delays or full abandonment. The valuation of easements for energy strains usually includes prolonged negotiations. Property homeowners, recognizing the shortage of actual options, continuously leverage their place to maximise monetary expectations. In excessive instances, the price of securing land rights can exceed the worth of the connection funding itself. Not like telecommunications operators — who, beneath the Act on Supporting the Growth of Telecommunications Providers and Networks, have a statutory proper of entry to properties — electrical energy system operators lack an identical instrument for the infrastructure that powers charging stations.

In consequence, every case requires a person civil regulation settlement, which considerably extends timelines and will increase funding uncertainty. As of now, charging infrastructure services and tools haven’t been explicitly acknowledged as tasks of public curiosity beneath Polish regulation. In apply, which means establishing energy connections to charging stations can’t make the most of simplified procedures — akin to selections that restrict property use or apply particular acts used for highway or rail investments.

Vitality regulation rules for the V2X (automobile to grid / residence/workplace/constructing)

One other barrier encountered arises from the failure to adapt vitality regulation rules to the V2X mannequin. Within the context of vitality regulation and using the V2X service, an electrical automobile inputs vitality into the grid. The illegal introduction of electrical energy into the grid is topic to penalties, together with fines. Moreover, introducing any kWh into the ability grid necessitates acquiring numerous consents or permissions, whether or not from the distribution system operator or the entity performing because the vitality market operator. At this juncture, it’s important to revisit 2017, when the e-mobility sector in Poland confronted the problem of legally regulating electrical automobile charging providers (i.e., the movement of electrical energy in the wrong way in comparison with the V2X service). 

Earlier than detailed rules had been launched concerning the supply of charging providers, charging an electrical automobile was handled — so far as vitality regulation is anxious — because the sale and distribution of electrical energy. This signified the necessity to acquire quite a few consents and concessions, which in apply was not possible to implement and reconcile with a monetary mannequin acceptable to traders. Nonetheless, a comparatively easy statutory regulation sufficed, which excluded the movement of electrical energy from the charging station to the electrical automobile battery from the definition of the sale and distribution of electrical energy, recognizing this movement of electrical energy as a separate statutory class within the type of offering charging providers by way of electrical automobile charging stations. At the moment, we face an identical difficulty concerning the regulation of electrical energy movement from electrical automobile batteries to the ability grid. Given the present rules, it stays unclear tips on how to classify the introduction of electrical energy from electrical automobile batteries to the grid — whether or not as electrical energy coming from an vitality storage facility or a producing set up. No matter how we classify this movement, it can contain fulfilling quite a few formalities, which is able to doubtless hinder the event of those providers. 

Due to this fact, it’s important to manage — ideally on the degree of European Union rules — the transmission of electrical energy as a part of the V2X service as a separate class beneath vitality regulation, which is able to get rid of pointless formalities. The following step can be to manage (or maybe permit V2X service customers the liberty to decide on) the introduction of electrical energy by way of the V2G service to the inner networks of services — properties, places of work, and so forth. (i.e., behind the meter). Nonetheless, an issue then arises within the settlement between the EV person offering the V2X service and introducing vitality to the power’s inside community and the power’s proprietor who makes use of this electrical energy.

Abstract

The instance of the Polish market and rules demonstrates that sheer development within the variety of charging stations, nonetheless spectacular, shouldn’t be ample for sustainable electromobility growth in Central-Jap Europe. With out steady regulatory frameworks, predictable assist programs, and streamlined funding procedures, even probably the most dynamic infrastructure growth could face bottlenecks that impede its real-world utility. The Polish expertise presents a transparent takeaway for all rising markets: to make sure an enduring transport transition, a coordinated method is crucial — one that mixes demand-side and supply-side actions and acknowledges charging infrastructure as a strategic pillar of local weather and vitality coverage.

It’s price noting that numerous initiatives are rising in Poland aimed toward unlocking the potential of electromobility. One such initiative is the mission “The Visegrad Group for Car to X,” applied beneath the Interreg program and supported by our regulation agency. Within the subsequent phases of the mission, actions and analyses are deliberate to additional unleash the potential of electromobility. It ought to be emphasised that the mission doesn’t solely deal with introducing extra market rules but additionally takes under consideration the chance of overregulation within the vitality sector. Accordingly, the mission will discover balanced options designed to facilitate the implementation of measures supporting electromobility whereas sustaining regulatory stability inside the electrical energy market.

Authors:

Witold Chmarzyński, Lawyer-at-law/Accomplice
&
Zuzanna Rosnowska, Lawyer

CCLaw Artistic Consultants Legislation Agency
www.cclaw.com.pl