For what projects can you receive white certificates?

Who can obtain white certificates?

Applications for white certificates can be submitted by any entity planning to implement a project aimed at improving energy efficiency. In the case of industrial plants, the applicant is typically the infrastructure owner or operator responsible for the modernization. The key requirement is that the activities covered by the application must not have commenced before submitting the application for white certificates.

An exception to this rule is energy-intensive companies consuming at least 100 GWh of electricity per year – they can also apply for financial support for completed projects under Article 15 of the Energy Efficiency Act. This is a replacement mechanism for white certificates and can be used after the completion of an energy efficiency project, unlike white certificates, which must be applied for before the investment begins.

What conditions must be met to receive white certificates?

To receive white certificates, the investment must:

• lead to measurable final energy savings, confirmed by an energy efficiency audit,
• be notified to the President of the Energy Regulatory Office (URE) before its commencement,
• be implemented,
• be reported to the URE after its completion, and in the case of savings exceeding 100 toe, a post-construction energy efficiency audit is required.

The minimum savings threshold for applying for an energy efficiency certificate is currently 10 toe (tons of oil equivalent), which corresponds to approximately 116 MWh of final energy.

The administrative process from submitting an application to receiving white certificates typically takes from several months to approximately a year and a half, depending on the complexity of the project. Careful documentation preparation is essential, including an energy efficiency audit, which forms the basis for assessing potential savings.

We describe how to obtain white certificates in the DB Energy knowledge base.

What activities qualify for white certificates?

White certificates can be obtained for a wide range of modernization and optimization activities, the most common of which are:

Modernization of drive systems and motors

• replacing old electric motors with motors with a higher efficiency class (IE3, IE4),
• using frequency converters (inverters) in drive systems.

Compressed air system optimization

• modernization of leaky ducts and fittings,
• use of variable-speed compressors,
• heat recovery from compressors.

Building thermal modernization

• insulation of building envelopes (walls, roofs, ceilings),
• replacing windows and doors with energy-efficient ones,
• use of air curtains and insulating entrance gates.

Lighting system modernization

• replacing lighting with LED technology with motion and light intensity sensors,
• optimizing the placement of luminaires.

Technological system modernization

• changing technological processes to less energy-intensive ones,
• energy recovery from industrial processes,
• changing energy generation methods to higher-efficiency technologies.

HVAC and refrigeration system optimization

• replacing refrigeration units with higher energy efficiency units,
• use of free cooling and waste heat recovery,
• modernizing ventilation systems with heat recovery.

Energy Management Systems

• implementation of BMS or EMS systems that monitor and optimize energy consumption,
• automation of energy processes with the integration of data from meters and sensors.

A full list of eligible activities can be found in the Notice of the Minister of Climate and Environment of November 30, 2021, regarding a detailed list of projects aimed at improving energy efficiency.

What activities are ineligible for white certificates?

Despite the wide range of eligible activities, not every project can be covered by the white certificate system. The following are excluded:

• investments already underway before submitting an application to the Energy Regulatory Office (URE),
• investments involving maintenance or renovation,
• investments in installations covered by the ETS, unless they concern installations for own use,
• replacing equipment with newer ones if it does not lead to measurable energy savings,
• purchasing energy from renewable sources,
• planned activities not supported by an energy efficiency audit.

Energy efficiency audit and ex-post audit

An energy efficiency audit is a key element in the white certificate application process. It must include a description of the existing condition and planned changes, the estimated amount of energy savings, the calculation methodology, and a cost-effectiveness analysis.

Based on the audit, the President of the Energy Regulatory Office issues a decision to grant white certificates in the form of the appropriate number of toe. After the project is completed, in some cases, an energy efficiency audit must be performed again to verify whether the energy savings projected in the application have actually been achieved.

This audit is required for projects with projected savings exceeding 100 toe (tons of oil equivalent). In practice, however, the Energy Regulatory Office may also require a post-construction audit for projects with lower projected savings – for example, if the values change during implementation or if doubts arise regarding the data presented.

"The main goal of a post-construction audit, also known as an ex-post audit, is to confirm that the actual energy savings after the investment is completed match those declared in the white certificate application. In practice, it is based on this audit that the Energy Regulatory Office (URE) verifies whether the project has achieved the declared energy effect. This ensures that the system remains reliable and resistant to abuse. For us, as a company recommending the implementation of activities covered by the white certificate system, it is also the moment to assess whether the proposed solutions are working according to the design assumptions and whether the client is actually achieving the planned energy and financial benefits.

We know from experience that sometimes the URE commissions a post-construction audit even for investments with savings below 100 toe. At DB Energy, when we apply for white certificates for our clients, an ex-post audit is also included in the price. It is worth seeking a similar service to avoid surprises after the investment is completed." says Sebastian Jankowski, Director of Product Management at DB Energy.

If, after the investment is completed, it turns out that the actual savings are higher than expected, it is possible to submit a revised application along with a new energy efficiency audit.

What are the benefits of obtaining white certificates?

• reimbursement of part or all of the investment costs – certificates can be sold on the Polish Power Exchange, generating real income,
• incentives for efficiency investments, even in the absence of subsidy funds,
• better control over the actual impact of the investment thanks to audit requirements and monitoring,
• improved ESG indicators – measures that increase efficiency are beneficial from a sustainable development perspective,
• possibility of combining them with other support mechanisms (e.g., thermal modernization tax relief – while maintaining the principles of decoupling).

Summary

White certificates are an effective tool for supporting energy efficiency improvements in industrial plants. To benefit from them, it is necessary to properly plan the investment, conduct an audit, and submit an application to the Energy Regulatory Office (URE) before implementation begins. At the same time, it is worth remembering the exclusions that eliminate some investments from eligibility for certificates.