Under Poland’s new Balancing Market Conditions (WDB), effective from 1 January 2026 two key categories of generation units are defined:

• JWCD: Jednostka Wytwórcza Centralnie Dysponowana (Centrally Dispatched Generating Unit)
• JWCK: Jednostka Wytwórcza Centralnie Koordynowana (Centrally Coordinated Generating Unit)

A JWCD is legally defined as a generation unit connected to the transmission grid (or a coordinated 110 kV grid) that is fully dispatchable by the Transmission System Operator (TSO). These units are required to supply balancing energy (upward/downward regulation) and provide essential system services such as primary and secondary reserves, inertia, voltage regulation, and more. By law, JWCD units have a legal obligation to act as balancing-service providers and must offer balancing power for their full dispatchable capacity.

JWCK units, by contrast, are coordinated less strictly by the TSO and have no such obligation to provide balancing services.

Importance of JWCD units for grid stability

JWCD units are the cornerstone of Poland’s balancing market. Due to their predictability and controllability, the TSO uses them to balance real-time supply and demand, maintain system frequency, and stabilise voltage levels. They actively deliver primary and secondary reserves, and their mechanical inertia plays a key role in damping frequency fluctuations.

In short, JWCD units are the core dispatchable resources relied upon to ensure the safe and stable operation of the power system. Ensuring that all large generators connected to the transmission network comply with JWCD obligations is critical for maintaining system security and market functionality.

Who qualifies as JWCD? What about Renewable Energy Sources (RES)?

Historically, JWCD units in Poland have included fossil fuel-based power plants, gas-fired units, pumped-storage plants, and cogeneration facilities. However, according to the Regulation of the Minister of Climate and Environment (22 March 2023) on the detailed conditions for the functioning of the power system (the "System Regulation"), all generation modules that meet the definition of JWCD must comply with full availability and balancing obligations from 1 January 2026.

This includes RES units connected to the transmission grid – regardless of their installed capacity. Therefore, RES installations must adapt to participate in the balancing market, including being equipped with the necessary information and communications technology (ICT) infrastructure to enable communication with the TSO.

Challenges with the deadline

The deadline to complete the JWCD qualification process is the end of 2025. Many units may be unable to meet this deadline due to technical (e.g., time needed to implement the required systems) or economic (e.g., high ICT investment costs) reasons. Depending on the type of services provided, a decision must be made whether shared or local ICT systems are sufficient. FCR, aFRR or mFRR system services must be provided using local nodes, regardless of the JWCD status of the JGZ1 generation unit.

Can the deadline be extended?

It is highly likely that many generation units currently holding JWCD status but lacking sufficient progress will not complete the qualification process before the deadline. To manage this risk, a unit may request to be temporarily or permanently exempted from JWCD obligations by changing its status to JWCK.

This is possible under §14(1) of the System Regulation, which allows a generation unit owner to request a status change from JWCD to JWCK (or vice versa). Such a change may include exemptions from certain requirements, such as appointing a Balancing Service Provider or meeting full dispatchability standards.

JWCD qualification – technical requirements

To qualify as a JWCD, a generation unit must meet stringent technical and communication requirements. Specifically, it must have:

• telemetry and control interfaces to connect with the TSO’s dispatch systems (the legacy SOWE or the new LFC – Load Frequency Control system),
• a local control station (an LFC node) that can communicate with the TSO’s dispatch center,
• automatic responsiveness to TSO signals (governor control, SCADA links, etc.), and
• must comply with TSO standards (e.g., the TSO’s LFC Standards).

Additionally, the unit owner is obligated to appoint a Balancing Service Provider who will submit bids for balancing energy in the market.

Post-2026: failure to meet JWCD criteria and JWCK reclassification

The new rules set a firm deadline - end of 2025, any generation unit with JWCD status must complete the full qualification process. If a unit fails to qualify or loses compliance, it can no longer act as a JWCD.

Under §14(1) of the System Regulation, the unit owner may formally request reclassification to JWCK status and exemption from full dispatch requirements. This request may also be submitted during the initial connection process. The TSO will assess system needs and technical constraints before approving or denying the request.

If rejected, the TSO must justify its decision and notify both the applicant and the President of the Energy Regulatory Office (“URE”). A refusal typically means the unit must remain JWCD-compliant or it will be excluded from the balancing market.

Challenging TSO decisions – Article 8 of the Energy Law

The Energy Law (Article 8) offers legal remedies to generation unit owners who disagree with TSO decisions regarding JWCD/JWCK classification. Because the unit’s status is reflected in the grid connection contracts, an owner may formally appeal a TSO refusal to URE.

The System Regulation obliges the TSO to inform URE of any rejection of a status change or exemption. URE’s administrative decision can then be further challenged in court.

In summary, a formal legal and administrative pathway exists for energy generators to contest the TSO’s decisions related to JWCD/JWCK classification.