Summary

  • The draft assigns six hours of backup to mobile base stations that operators classify through their own risk analysis as most important to continuity; other mobile base stations receive two hours.
  • That distinction, the construction and power-installation trigger, and an unquantified private cost base make this a classification and implementation proposal—not a current nationwide service guarantee or blanket retrofit order.

A six-hour rule begins with a label

Poland’s proposed electricity-supply regulation appears, at first, to offer a simple resilience benchmark: six hours of reserve power for critical mobile sites. The annex is more conditional. It puts “coverage” mobile base stations in Group B, where the table specifies six hours, but places other mobile base stations in Group C, with two hours. A footnote defines the first group by the operator’s own risk analysis: the installations it considers most significant to continuity of telephone service and data transmission, across frequencies and technologies.

That makes the classification method the operational hinge. The text does not identify a national list of protected sites, publish a common scoring formula, or say that every site contributing to coverage qualifies. The operator’s analysis determines which locations enter the longer-duration category. The draft therefore sets a technical consequence for a classification decision while leaving the decision’s underlying evidence and reviewability central to implementation.

The distinction is material, but it should not be mistaken for an end-to-end service promise. A six-hour equipment reserve is a design requirement for the specified installation category. It does not by itself guarantee six hours of service to every customer during a blackout. The outcome also depends on what equipment the reserve supports, whether transmission and core-network dependencies remain available, the condition and loading of batteries, fuel logistics where generators are used, and the scope of the outage.

The draft says reserve, emergency and uninterruptible supplies must cover at least the equipment needed for basic operation; “basic operation” is not the same as every service under every failure scenario.

The proposed framework has four reliability groups, A through D, and assigns different equipment and supply conditions. The mobile distinction sits inside a wider architecture: listed mobile exchanges in Group A receive 24 hours, while certain nationwide radio and television transmission above 25 kW ERP receives 36 hours. Those figures concern different infrastructure classes and should not be collapsed into a single scale for all communications. The general rule calls for at least six hours of emergency storage unless the annex sets another duration.

Primary supply comes from the electricity network; renewable generation can supplement it and can substitute for primary or reserve supply only when sufficient stored energy covers the required interruption period. Switching is automatic, and guaranteed supply follows an n+1 principle subject to specified exceptions.

The proposal also reaches physical safety. Lithium-ion battery installations above 2 kWh face installation and fire-safety conditions, and some facilities require gas detection, ventilation and pressure relief depending on capacity and risk. These provisions connect resilience to the hazards of the reserve system itself: adding stored energy can extend operation while increasing the need to manage heat, gas and fire risks.

The scope is tied to building work. The draft applies to design, construction and reconstruction; specified reconstruction, extension or superstructure work triggers the requirements when it concerns the power-supply installation. A transitional clause preserves older rules for certain permit or design applications and works notified before the new measure enters into force. This is not written as an instruction to replace every battery at every existing site immediately. It is closer to a rule for projects and electrical work, with legacy treatment that can make the compliance boundary depend on project history.

The measure is still a proposal in the official record checked on 17 October 2026. The draft text contains a proposed 20 September 2026 commencement date, now in the past, but the Polish ministry project page and European Commission TRIS notification continued to label it a draft. No final instrument was identified in the official-journal check. The date in a draft cannot establish that the rule took effect. Poland invoked an accelerated EU notification procedure and cited blackout, natural-disaster, technical-failure, sabotage and hybrid-activity risks, as well as continuity of public and state services.

That urgency explains the policy rationale; it does not remove the need to verify adoption and commencement.

The impact assessment estimates about 3,895 telecommunications undertakings in scope and reports no public-finance effect. It says the number of building owners and some other affected parties is difficult to estimate, and its table does not quantify private compliance costs. That leaves an important implementation question open: what proportion of sites will be classified into each group, and how much work will be required when power installations are renewed? The published estimate counts undertakings, not the number of qualifying sites, the cost per site, or the resulting availability improvement.

For network operators, the proposal’s distinctive feature is thus not simply a six-hour battery. It is the chain from service-continuity risk analysis, through site classification and facility design, to the evidence that would show whether the higher standard is being applied to the right places. The public documents establish the planned categories and thresholds. They do not yet show how operators will document classifications, how consistently they will do so, or what regulator oversight would look like.

Primary sources