Warsaw, 12 March 2026

Dear Prime Minister,

We are writing to you in connection with the upcoming implementation of the ETS2 system and the delays in the work on Poland’s Social Climate Plan (SCP). We urge the government to urgently adopt the SCP and present clear rules for spending the revenues from ETS2.

The full entry into force of the new EU emissions trading system for the buildings and road transport sectors (the so-called ETS2) is planned in less than two years from now. This means higher heating and transport costs for households and businesses that rely on fossil fuels. At the same time, ETS2 revenues will constitute a significant source of income for the Polish state budget.

As of this year, the Social Climate Fund (SCF) has been available to EU Member States. Poland may receive the largest allocation from the SCF in the European Union - up to 48 billion PLN. However, access to these funds is conditional on the adoption and submission to the European Commission of a Social Climate Plan, which contains concrete solutions to energy and transport poverty and protects citizens most exposed to cost increases related to ETS2 introduction. 

According to a report by the Polish think tank - the Reform Institute, in the years 2026-2032 the total pool of funds from ETS2 and the SCF available to the Polish government may exceed 120 billion PLN. These funds should be returned to citizens in the form of investments in comprehensive building renovations and improved accessibility of transport. Financial support is also needed for citizens most vulnerable to these changes. Such spending will translate into improved quality of life and greater independence from rising prices of imported fossil fuels.

The need for these investments is urgent. The slowdown of the “Clean Air” programme and the persistent problems with air quality demonstrate the enormous scale of the challenges Poland faces. Energy renovation of buildings and spending on public transport are investments in lower living costs, clean air, economic development, and energy security.

Effective use of ETS2 revenues requires a transparent plan for spending these funds. Experience with managing revenues from the EU ETS - highlighted by the Polish Supreme Audit Office (NIK) - shows that the absence of clear allocation of funds to specific measures leads to their dispersion within the state budget.

For this reason, we recommend returning to the discussion on implementing an Energy Transformation Fund, which would be financed by revenues from both the EU ETS and ETS2.

Moreover, the government must plan instruments for using additional EU funds from the Social Climate Fund within the Social Climate Plan framework. Since the beginning of this year, Poland could already be benefiting from the SCF. Time that could have been used for investments protecting citizens from additional costs related to ETS2 is slipping away.

We appreciate the inclusive process so far in developing the Social Climate Plan at the Ministry of Funds and Regional Policy through a working group format. At the same time, for several months there has been no information about the further fate of the SCP project, and the version prepared after consultations has still not been published.

In light of the above, we call for:

• Urgent completion and adoption of the Social Climate Plan.
• Publication of clear rules for spending ETS2 revenues outside the Social Climate Fund allocation.
• Guarantees that the funds flowing to the Polish state budget from the SCF and ETS2 will serve as a modernization impulse for the Polish economy and will be used to reduce energy and transport poverty.

Transparency and predictability in managing ETS2 and SCF funds will be essential for building public trust in the ongoing changes. Citizens must be certain that their money will be spent wisely. A well-designed spending plan, developed through dialogue, will also strengthen the country’s resilience to political crises and macroeconomic shocks. It can become a tool for overcoming the state’s long-standing inability to address problems related to Polish households' heating and access to public transport services.

As representatives of non-governmental organizations and expert communities, we declare our readiness to cooperate with the government and public administration in developing effective and durable solutions.

Recipient:
Mr. Donald Tusk, Prime Minister

Cc:
Mr. Andrzej Domański, Minister of Finance and Economy
Ms. Paulina Hennig-Kloska, Minister of Climate and Environment
Ms. Katarzyna Pełczyńska-Nałęcz, Minister of Funds and Regional Policy

Signatories:
Clean Cities Campaign Poland
ClientEarth
Fala Renowacji
Federation of Social Organizations of the Warmian-Masurian Voivodeship (FOSa)
Greenpeace Poland Foundation
Mission Possible Foundation
Foundation for Energy Efficiency (FEWE)
Institute for Reform
Institute for Sustainable Development
IZG - Institute for Sustainable Economy
National Federation for Solving the Problem of Homelessness
Polish Ecological Club - Mazovian District
Polish Committee of the European Anti-Poverty Network (EAPN Poland)
T&E Poland
The Climate Reality Project
Society for Nature and People
WRZOS - Working Community of Associations of Social Organizations
WWF Poland
Polish Green Network Association