GAZ-SYSTEM S.A.
GAZ-SYSTEM
GAZ-SYSTEM is a company of strategic importance for the economy and energy security responsible for the transmission of natural gas and the management of the high-pressure gas transmission system in Poland together with natural gas storage facilities.
ID: 441913146231-35
Lobbying Activity
Response to Revision of the EU’s energy security framework
10 Oct 2025
Gas Transmission System Operator GAZ-SYSTEM S.A. (hereafter GAZ-SYSTEM) welcomes the opportunity to express its views in the public consultation on the revision of EU energy security framework. The Polish electricity generation mix, although still dominated by solid fossil fuels, is gradually undergoing transformation, with a rising share of renewable and low-emission energy sources. Recently, GAZ-SYSTEM has recorded a substantial increase in market interest in the connection of gas-fired power plants to back-up the renewables. As a result, the demand for gas in Poland is set to increase in the short- and mid-term perspectives. This holds true especially to the gas demand levels during peak times during the period of low renewable generation. When amending the SoS regulation, it should be taken into account that the natural gas infrastructure will continue to be used in the foreseeable future. Market signals do not indicate a decline in gas demand, as suggested in the consultation document. The gas infrastructure has demonstrated its reliability. It must be maintained, modernised, and gradually adapted throughout the energy transition. The existing rules in the area of security of supply are largely fit for purpose, however there is a potential for further improvements to consider the system needs and evolving landscape. GAZ-SYSTEM believes that gas storages play essential role in securing gas supply in case of short- or long-term crisis. Close monitoring of storage filling levels is essential. Injection during summer is important to ensure an adequate filling of European storages at the end of winter. Additionally, the responsibility for ensuring an adequate filling of European gas storages should also be placed with market participants rather than only with Member States. GAZ-SYSTEM sees the need to clarify the solidarity mechanism, in particular the roles and responsibilities of individual entities, including TSOs, as well as to specify the rules for capacity allocation, reallocation, nominations, flow control and balancing in the event of applying this mechanism. TSOs must also understand how much gas will be provided as solidarity volumes and the timing for procedures, especially during stressful usage of capacities. TSOs often lack clarity on what data should be exchanged (e.g., consumption details of protected and non-protected customers) and with whom. Additionally, uncertainties remain regarding the transition between solidarity and market measures. Relying on sudden shifts between market systems and solidarity regimes poses risks, especially when actors must rapidly assume new roles in balancing gas supply during emergencies, which could destabilize the system. Roles and responsibilities (TSOs, DSOs, NRAs, network users, trading platforms etc.) during a crisis situation need clearer definition. The impact of declaring an EU emergency is unclear, and the rules for EU-wide crisis levels need improvement. Clear distinctions between regional and EU-wide levels are necessary. Increased interconnectivity among member states allows the EU system to be used flexibly, and limiting crisis levels to a region would restrict this potential. We propose strengthening cooperation between member states and clarifying the roles of those unable to provide support. Non-market measures in emergencies should not apply to countries not facing a national emergency. In our opinion a more flexible model of participation in GCG meetings should be adopted. The regulation should enable gas TSOs to take part on an ad hoc basis in the GCG meetings when an expertise on particular market/region SoS situation is required. GAZ-SYSTEM remains available to provide further assistance in relation to this matter and other measures undertaken by the European Commission.
Read full responseResponse to Commission Regulation on inside information platforms and registered reporting mechanisms under REMIT
16 Sept 2025
GAZ-SYSTEM is a gas transmission system operator in Poland. The company is also the owner of the LNG Terminal. In addition, the company operates the GSA Platform, which is used for the allocation of capacity on interconnectors and provides secondary market reporting. Consequently, it has been granted Organized Marketplace (OMP) status. GAZ-SYSTEM also acts as a Registered Reporting Mechanism (RRM), reporting fundamental and trading data to ACER Furthermore, GAZ-SYSTEM operates GIIP, a platform used for publishing inside information by market participants. In the context of the feedback process on the REMIT Delegated Regulation initiated by European Commission, GAZ-SYSTEM respectfully proposes that the Commission consider further clarifying specific provisions in order to streamline procedures, strengthen data security and transparency, and uphold the principle of proportionality in regulatory obligations. In particular, we would like to submit our observations and recommendations concerning the following aspects: the documentation and authorisation requirements applicable to Registered Reporting Mechanisms (RRMs) and Inside Information Platforms (IIPs); the allocation of responsibilities for data management and transmission procedures; the handling of data-related incidents and internal validation mechanisms; the technical and organisational requirements imposed on IIPs, including system availability and continuity of publication; the rules governing the substitution of RRMs/IIPs in cases of authorisation withdrawal; the simplification of data formats and the reduction of unnecessary reporting complexity, particularly with respect to the UMM format. Specific proposals for legislative changes can be found in the attached file.
Read full responseResponse to Revision of the REMIT Implementing Regulation on data reporting
16 Sept 2025
GAZ-SYSTEM is a gas transmission system operator in Poland. The company is also the owner of the LNG Terminal. In addition, the company operates the GSA Platform, which is used for the allocation of capacity on interconnectors and provides secondary market reporting. Consequently, it has been granted Organized Marketplace (OMP) status. GAZ-SYSTEM also acts as a Registered Reporting Mechanism (RRM), reporting fundamental and trading data to ACER Furthermore, GAZ-SYSTEM operates GIIP, a platform used for publishing inside information by market participants. In the context of the feedback process on the REMIT Implementing Regulation initiated by European Commission, GAZ-SYSTEM hereby submits the following key observations for consideration: 1. In principle we support the overarching objectives of REMIT which are to ensure transparency of the wholesale energy market and enhance monitoring capacities, as well as the stabilisation of energy prices and consumer protection. Based on that we strongly appeal for consideration the proposal of reporting details of the procedures for primary gas capacity allocations where no capacity has been allocated as a result of the allocation process, more specifically, details of auction with no bids and where no capacity was allocated. Reporting this data which do not present values supporting above mentioned principles. Sending data related to unsuccessful auctions would result in raising the reporting volume, generating an excessive administrative burden, and offering no meaningful analytical insight, as such data do not reflect actual market interest, price signals, or trading behavior. We believe that reporting would be in contrary to the assumptions of the REMIT Regulation itself, in which the legislator declares to minimise the expenses incurred, which indicates in the preamble to this regulation, quoted in () Reporting obligations should be kept to a minimum and not create unnecessary costs or administrative burdens for market participants (..). 2. The previous Implementing Regulation (EU) No 1348/2014 9 clearly assigned the responsibility for reporting transactions related to primary transportation contracts for electricity or gas to Transmission System Operators (TSOs), as specified in Article 6(3). However, this explicit allocation of reporting obligations is absent in the current draft of the revised Implementing Regulation. 3. We express our concerns regarding the scope and exemptions related to exposure reporting (Article 6). Market participants acquiring energy exclusively for internal or operational purposes (including TSOs, SSOs, and LSOs) should be exempt from this obligation, as system operators their positions are already adequately covered by other reporting requirements set out in Article 3. 4. We would like to highlight the need for a more flexible approach to reporting channels, the avoidance of double reporting, and longer implementation timelines for certain provisions that require adequate organizational and financial preparation. Specific proposals for legislative changes can be found in the attached file.
Read full responseResponse to Legislative initiative on CO2 transportation infrastructure and markets
11 Sept 2025
CCUS technology can play a pivotal role in the energy transition and the decarbonisation of European industry, while making a significant contribution to the overarching objectives of EU climate policy. The establishment of coherent, transparent and EU-wide regulatory frameworks should enable the dynamic development of this technology which is particularly relevant for the decarbonisation of hard-to-abate sectors. In order to enable the development of CCUS, it is essential to establish regulatory frameworks that cover the entire value chain capture, transport, storage, and utilisation of CO. Focusing on CO transport, the following key issues require regulatory attention: 1. Financing and de-risking mechanisms. The development of CCUS requires stable and predictable support mechanisms. Investment grants alone are insufficient to ensure economic viability throughout the project lifecycle. Additional instruments are needed to bridge the gap between the high costs of capture, transport, storage and the market price of avoided CO emissions. Furthermore, to enable TSOs to invest in CO2 grids (which will need to be amortised over a long period and require many years to be in place, especially in case of new pipelines) they will need an appropriate level of financial certainty to raise and invest the necessary funds. Transport and storage infrastructure investors need long-term offtake commitments or other forms of guarantees. 2. CO2 sequestration. Confirming suitable sites for CO2 sequestration, whether onshore or offshore (e.g. the Baltic Sea), is a critical prerequisite for implementing carbon management strategies. Without clear confirmation of viable storage capacities in accordance with existing international regulatory requirements, the development of CO2 transport networks cannot progress in a coordinated or efficient manner. Establishing such clarity is therefore indispensable to enable investment decisions and create realistic pathways for reducing emissions in hard-to-abate industries. 3. Standardisation particularly regarding the qualitative composition of the transported medium. The share of specific impurities in the CO stream affects its phase-change diagram and thus the safe operating parameters of transmission. A harmonised CO purity standard would facilitate international projects, but defining it poses challenges. Overly stringent purity requirements may create an investment barrier for companies planning to deploy capture technology, while permitting higher levels of impurities may increase transport costs. Other aspects requiring harmonisation include, among others, measurement and reporting methodologies, safety standards and CO utilisation certificates/standards. 4. Ownership and liability rules principles developed for natural gas networks are not directly applicable to CO transport due to the specific characteristics of the medium. There is a lack of harmonised rules defining the point at which ownership and liability for the transported medium are transferred across the different segments of the CCUS value chain. 5. Third-Party Access rules the adoption of transparent and non-discriminatory access principles, analogous to those applied to other transmission networks, is necessary to guarantee fair access to infrastructure. Without harmonised EU regulatory frameworks, the integration of national transport systems into an effective cross-border network will be significantly hindered. The establishment of consistent support mechanisms is essential to reduce investment risk, which will directly impact the number of projects implemented.
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
26 Mar 2025
Gas Transmission System Operator GAZ-SYSTEM S.A. welcomes the opportunity to express its views in the public consultation on the Taxonomy delegated acts. GAZ-SYSTEM supports the objectives set out in the Omnibus package and shares the view of the Commission that there is a need to foster transparency, effectiveness and long-term usability of the EU Taxonomy. This may well be achieved by reducing sustainability reporting requirements as provided for in the Taxonomy delegated acts. Please find attached the position of GAZ-SYSTEM S.A.
Read full responseMeeting with Andrzej Buła (Member of the European Parliament)
4 Mar 2025 · introductory meeting
Meeting with Mirosława Nykiel (Member of the European Parliament)
2 Oct 2024 · Introduction to the activities of the company
Meeting with Michał Kobosko (Member of the European Parliament)
23 Sept 2024 · Future of Energy in Poland and EU
Meeting with Michał Szczerba (Member of the European Parliament) and PGE Polska Grupa Energetyczna SA and Polish Electricity Association
11 Sept 2024 · Staff meeting with the representatives of the polish energy sector
Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)
19 Sept 2023 · EU Energy Platform
Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)
8 Feb 2023 · Gas and Hydrogen Package
Meeting with Ditte Juul-Joergensen (Director-General Energy)
8 Nov 2022 · Hydrogen and infrastructure
Meeting with Seán Kelly (Member of the European Parliament) and European Energy Forum and NaTran
18 Oct 2022 · Dinner debate: Biomethane: how to scale up production and foster integration into the network?
Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)
18 Oct 2022 · Gas and Hydrogen Package