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

Assist CleanTechnica’s work by way of a Substack subscription or on Stripe.

Improvement of EV charging infrastructure in Central-Japanese Europe — is it speedy sufficient? 

With a view to reply this query, let’s have an in depth take a look at the largest market of Central-Japanese Europe. As of spring 2025, Poland has about 9,300 publicly accessible charging factors, almost 3,000 of that are quick DC chargers, making up 31% of the entire. This represents a 44% year-over-year improve, with the DC section experiencing significantly speedy progress — up 66% y/y — outpacing the growth of slower AC gadgets. Business information confirms this pattern: within the first 11 months of 2024 alone, almost 1,000 new fast-charging factors have been launched — greater than twice as many because the earlier 12 months — and the entire energy capability of the infrastructure elevated by one-third in simply six months, reaching roughly 300 MW.

This progress is primarily pushed by personal capital, as operators are growing investments regardless of weak demand; EVs accounted for under 3% of latest automotive 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 durations. 

The first impediment to additional BEVs growth and assembly AFIR targets

Regardless of the spectacular tempo of DC infrastructure progress in 2024, the first impediment to additional growth stays the small and unstable BEV fleet, worsened by inconsistent help applications. With no coordinated bundle of demand- and supply-side incentives, Poland dangers not solely failing to fulfill AFIR targets but in addition widening its aggressive hole with main e-mobility markets within the EU. Latest months have demonstrated that the elimination or sudden suspension of important help instruments ends in an instantaneous decline in BEV gross sales. When entry to a preferred financing choice underneath 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, at this time, the system of subsidies and financial incentives will not 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 help 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 points which influence EV charging infrastructure investments

As the expansion of the EV person base turns into tougher to foretell, operators more and more delay funding choices or scale down deliberate installations — resembling abandoning higher-powered chargers or areas outdoors main cities with decrease person turnover. The event of publicly accessible charging stations in Poland faces a barrier that hardly ever surfaces in public debate however is crucial for funding dynamics: advanced and sluggish grid connection procedures. Though power legislation 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 closing dates. Within the case of quick chargers requiring increased capability, all the administrative and development 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 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 categorised within the third connection group, which is usually used for medium-voltage amenities. This classification offers DSOs extra time to arrange the circumstances, nevertheless it additionally extends the method and will increase prices. Furthermore, communication channels with DSO technical groups are restricted, and suggestions is barely supplied with the formal connection circumstances bundle. If it emerges throughout the course of that solely a portion of the requested capability is offered, the investor doesn’t be taught this till the process is full.

There isn’t a mechanism for “gentle” consultations that may enable for early-stage undertaking rescaling primarily based on precise grid capability. Furthermore, Polish authorized laws don’t differentiate charging stations as they do for renewable power sources or public transport. As a substitute, charging infrastructure is thought to be another power client, regardless of its function in serving to to fulfill local weather targets and fulfill obligations underneath the AFIR regulation.

It’s additionally necessary to notice that establishing the facility infrastructure for public EV charging stations requires not solely out there capability within the grid but in addition appropriate land circumstances for linear investments. This primarily includes securing land corridors for cable routes, setting up transformer stations, or putting in metering gear. In follow, securing property entry has turn into probably the most time-consuming and unpredictable points of all the funding cycle, considerably complicating DSO operations. In city areas, almost 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 all the undertaking, resulting in months of delays or full abandonment. The valuation of easements for energy strains usually includes prolonged negotiations. Property house owners, recognizing the shortage of actual alternate options, continuously leverage their place to maximise monetary expectations. In excessive circumstances, the price of securing land rights can exceed the worth of the connection funding itself. Not like telecommunications operators — who, underneath the Act on Supporting the Improvement of Telecommunications Companies and Networks, have a statutory proper of entry to properties — electrical energy system operators lack the same instrument for the infrastructure that powers charging stations.

Consequently, every case requires a person civil legislation settlement, which considerably extends timelines and will increase funding uncertainty. As of now, charging infrastructure amenities and gear haven’t been explicitly acknowledged as tasks of public curiosity underneath Polish legislation. In follow, because of this setting up energy connections to charging stations can not make the most of simplified procedures — resembling choices that restrict property use or apply particular acts used for highway or rail investments.

Power legislation laws for the V2X (automobile to grid / residence/workplace/constructing)

One other barrier encountered arises from the failure to adapt power legislation laws to the V2X mannequin. Within the context of power legislation and using the V2X service, an electrical automobile inputs power 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 facility grid necessitates acquiring varied consents or permissions, whether or not from the distribution system operator or the entity performing because the power 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 stream of electrical energy in the wrong way in comparison with the V2X service). 

Earlier than detailed laws have been launched concerning the availability of charging providers, charging an electrical automobile was handled — so far as power legislation is anxious — because the sale and distribution of electrical energy. This signified the necessity to receive quite a few consents and concessions, which in follow was not possible to implement and reconcile with a monetary mannequin acceptable to traders. However, a comparatively easy statutory regulation sufficed, which excluded the stream 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 stream of electrical energy as a separate statutory class within the type of offering charging providers through electrical automobile charging stations. Presently, we face the same difficulty concerning the regulation of electrical energy stream from electrical automotive batteries to the facility grid. Given the present laws, it stays unclear methods to classify the introduction of electrical energy from electrical automotive batteries to the grid — whether or not as electrical energy coming from an power storage facility or a producing set up. No matter how we classify this stream, it’ll contain fulfilling quite a few formalities, which can seemingly hinder the event of those providers. 

Due to this fact, it’s important to control — ideally on the degree of European Union laws — the transmission of electrical energy as a part of the V2X service as a separate class underneath power legislation, which can remove pointless formalities. The subsequent step might be to control (or maybe enable V2X service customers the liberty to decide on) the introduction of electrical energy through the V2G service to the interior networks of amenities — properties, workplaces, and many others. (i.e., behind the meter). Nonetheless, an issue then arises within the settlement between the EV person offering the V2X service and introducing power to the power’s inner community and the power’s proprietor who makes use of this electrical energy.

Abstract

The instance of the Polish market and laws demonstrates that sheer progress within the variety of charging stations, nonetheless spectacular, will not be adequate for sustainable electromobility growth in Central-Japanese Europe. With out secure regulatory frameworks, predictable help techniques, and streamlined funding procedures, even essentially 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 strategy is important — one that mixes demand-side and supply-side actions and acknowledges charging infrastructure as a strategic pillar of local weather and power coverage.

It’s value noting that quite a lot of initiatives are rising in Poland geared toward unlocking the potential of electromobility. One such initiative is the undertaking “The Visegrad Group for Car to X,” carried out underneath the Interreg program and supported by our legislation agency. Within the subsequent phases of the undertaking, actions and analyses are deliberate to additional unleash the potential of electromobility. It needs to be emphasised that the undertaking doesn’t solely give attention to introducing further market laws but in addition takes under consideration the chance of overregulation within the power sector. Accordingly, the undertaking will discover balanced options designed to facilitate the implementation of measures supporting electromobility whereas sustaining regulatory stability throughout the electrical energy market.

Authors:

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

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