PKP Polskie Linie Kolejowe S.A.
PLK SA
Zarządzanie infrastrukturą kolejową: - udostępnianie linii kolejowych przewoźnikom pasażerskim i towarowym, zgodnie z zasadą równego ich traktowania, - modernizacja i rewitalizacja linii kolejowych dostosowująca je do standardów Unii Europejskiej, - opracowywanie rozkładów jazdy pociągów, - prowadzenie ruchu pociągów na liniach kolejowych, - utrzymanie infrastruktury kolejowej w stanie zapewniającym bezpieczne prowadzenie ruchu kolejowego, - współpraca z sąsiednimi zarządcami infrastruktury kolejowej.
ID: 237300824908-30
Lobbying Activity
Meeting with Adam Jarubas (Member of the European Parliament)
3 Dec 2025 · Rola kolei w budowaniu konkurencyjności UE
Response to EU taxonomy - Review of the environmental delegated act
1 Dec 2025
In response to the call for feedback, PLK welcomes the opportunity to present its comments on the revision of the DA for the EU taxonomy. In our view, the current wording of the legal acts requires updating and simplification in several aspects, in order to ease the burden and adapt the regulations to the actual realities of businesses. Currently, the 'do no significant harm' (DNSH) rule imposes a number of obligations on businesses aimed at ensuring that their activities do not cause significant environmental harm. Demonstrating compliance with DNSH, however, requires extensive analysis and the presentation of specific documents, which from a business perspective can sometimes be very difficult, or even impossible. For this reason, in our view, the requirements for providing evidence should be softened or at least the required evidence should be explicitly specified by EU legislators. For example, while in the case of activity 6.14. Infrastructure for railway transport, our Company is able to gather the evidence required for DNSH in terms of CAPEX including environmental decisions or water permits, collecting evidence in terms of OPEX is already a significantly more complicated aspect. Furthermore, regarding the aforementioned activity 6.14, there is also uncertainty about the lack of a clear distinction as to whether the additional description of the activity "Production, installation, technical consulting, modernization" introduced in the Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 imposes an obligation to apply Annex C, added to the DNSH criteria. In this respect, the uncertainty concerns whether, in cases where railway track equipment is only used, and not produced by the entity, the entity is required to take Annex C into account in the DNSH analyses conducted. Additionally, in the taxonomy proces, a company should be allowed to focus solely on its main activity, which constitutes the most important pillar of the services provided without the necessity of examining additional and less important activities. The procedure should also be simplified in such a way that only qualifying activities are examined, without a detailed assessment of their compliance. In practice, this would mean a significant simplification for the company to conduct only one examination instead of two. Furthermore, PLK also raises its concerns regarding the functioning of the Minimum safeguards. This process constitutes one of the criteria determining whether a given activity is in line with the EU Taxonomy or not. We are critical of the aspect that failure to meet even one of the minimum safeguards unequivocally nullifies a company's chance of qualifying its activity as taxonomy-aligned. For this reason, we believe that the most appropriate approach, especially from the perspective of large companies and theircorporate groups, is to separate the Minimum safeguards from the taxonomy process conducted by the companies. Another key aspect are issues related to auditing. In our view, currently the procedures regarding audits may make them very discretionary, which is unfavorable from the perspective of business. A good solution could be to create uniform and binding criteria for a simplified audit. In addition, in our view, the Commission should also consider including some of the guidelines indicated in Commission Notices (ex. C/2023/267 of 20 October 2023) on the interpretation and application of certain legal provisions of the delegated act on the EU Taxonomy. Incorporating certain provisions of the guidelines into the content of the regulation will allow companies to interpret them consistently. From PLK's perspective, the Guidelines contain important interpretative pointersfor example, the understanding of lines dedicated to the transport of fossil fuels in the document, may be consistent with EIB guidelines. However, relying on guidelines without official legal force can be problematic from an audit perspective.
Read full responseResponse to EU’s next long-term budget (MFF) – implementing EU funding with Member States and regions
24 Sept 2025
We are glad to see that the Commission has decided to continue the CEF Programme in the new MFF (2028 2034). For rail, the CEF is the key financing instrument through which the Commission allocates funds needed for the completion of the TEN-T network including major on-going and new rail projects, as well as to support the digital transformation of rail operations, especially ERTMS on board and on track. Considering that the calls for both CEF1 and CEF2 have been continuously oversubscribed, we are pleased with a substantial increase in funding. The transport envelope under the new CEF amounts to EUR 51.51 billion (2.4 higher than in the case of CEF2), out of which ERU 17. 65 billion is reserved for dual-use civilian-military transport infrastructure projects - a much-needed increase in funding dedicated to military mobility when compared to CEF2. Without diminishing the importance of the CEF Programme, we believe that the cancellation of national envelopes financed from the Cohesion Fund is not a right direction. Allocation of funds through national envelopes has proven to be the optimal solution which has been positively verified in over a decade of practice. Countries that have had allocated envelopes often faced larger investment backlogs, and now, without the national envelopes, it will be more challenging for them to eliminate the backlogs in the process of stricter competition for funds. Also, the maximum financing threshold was higher (85%) for the cohesion pool. Our experience shows that securing adequate funding for projects under the call for proposals is crucial. Under the new MFF, CINEA should guarantee funding for the entire scope of the selected project, as this is the only way to ensure its full implementation and the achievement of its intended objectives. Splitting a project prolongs its implementation and may even result in the part of the project that does not have secured financing not being completed. Also, delays in the adoption of the previous MFF have caused downtime in the implementation of ongoing and mature projects on the TEN-T network. To prevent this from recurring in the event of delays in the adoption of the new MFF, the Commission should propose appropriate safeguards to ensure the timely implementation of the Programme and disbursement of funds. The other key issue is to ensure a better project transition between the current and the next MFF. Projects successfully prepared in an earlier budgetary period must be enabled to proceed to the implementation in the next period even if rules and guidelines are changed in the meantime. To avoid losing valuable resources, where appropriate, the Commission should consider the extension of costs eligibility between MFFs. Regarding the indicative list of projects of common interest with a cross-border dimension (Annex to the CEF Regulation) for railway projects, we would like to propose the following changes: - in reference to the North Sea Baltic Corridor to complete the Poznan (PL) Berlin (DE) connection by routing it via Gorzow Wlkp./Kostrzyn (PL) as an alternative/additional route to the route via Frankfurt-an-der-Oder (DE). The reason for this change is to better utilize the infrastructure capacity of the metropolitan sections of Berlin and Poznan. The additional/alternative route will support the growth of transport in the metropolitan and freight segments, while at the same will provide the technical conditions for a fast connection between Warsaw/Poznan and Berlin by incorporating Gorzow Wlkp./Kostrzyn.
Read full responseMeeting with Magda Kopczynska (Director-General Mobility and Transport)
9 Apr 2025 · Exchange of views on developing TEN-T rail network in Poland
Meeting with Apostolos Tzitzikostas (Commissioner) and
17 Feb 2025 · Exchange of views with CER CEOs on the margins of the 18th European Railway award event.
Response to Interim evaluation of the Connecting Europe Facility 2021-2027
24 Sept 2024
We, as PLK (Polish railway infrastrtucture manager), accept with satisfaction the aforementioned initiative and submit our position to the Commission in order to include the below mentioned requests, which present the interests of our Company and the sector during the work on the draft of the new financial instrument (CEF3). 1. We believe that the CEF financial instrument should be present in the future MFF financial perspective (2028-2034) on similar principles as before, especially with regard to the allocation of funds through national envelopes. This has proven to be an optimal solution, which has been positively verified in over a decade of practice. The management and implementation of CEF3 should continue to be centralized and led by the European Commission, while ensuring flexible implementation periods. 2. We share the opinion of the rail sector that the funds allocated for rail investments under CEF1 and CEF2 are insufficient, as evidenced by the fact that the number of applications submitted is constantly exceeded, sometimes even five times. In this case, every fourth application for funding was rejected due to lack of funds. This situation endangers the interests of the EU, and in particular the timely completion of the TEN-T network. We also share the opinion of the sector that the new requirements set out in the new TEN-T Regulation additionally justify the need to increase the budget of the new CEF or a similar tool in the next MFF perspective. The sector estimates that this amount should be at least EUR 100 billion for rail needs. 3. Simplification of both the financial rules and the application process can make it easier for applicants to enter a given financial program. For example, standardization of unit costs would facilitate the preparation of project budgets; lump sum grant agreements could further reduce the administrative burden and training in the use of the EU Funds and Tenders Portal would streamline the application process. Furthermore, technical assistance to infrastructure managers has to be a horizontal priority that should be continued in CEF2 and CEF3. 4. The description of the call itself and the description of the priorities for the work programs should be more detailed. Too general description, especially of the specific objectives, makes it difficult for the applicant to assess whether the application would have a chance of obtaining funding. Further breakdown of priorities (or geographical areas for infrastructure projects) in the work programs and calls for proposals may be helpful. 5. It is important to ensure flexibility in the CEF3 regarding the eligibility of rail sector expenditure, given that there are currently significant constraints on the eligibility of expenditure related to (station) buildings or ERTMS Level 2, which together have a significant impact on rail upgrade projects, but are not considered eligible under EU funds. 6. It will be crucial to ensure a better transition between the current and the next MFF. Projects that were positively assessed in the previous budget period but did not receive funding due to limited budget should be given priority for selection in the next period, even if rules and guidelines are changed in the meantime. 7. Due to the fact that the currently drafted regulations on the use of rail infrastructure capacity will introduce high-cost solutions (legal, technological ones), CEF 3 or its successor should guarantee a budget allowing for the implementation of tasks related to TTR implementation (inclusive of the adjustment, purchase or creation of IT tools).
Read full responseMeeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Community of European Railway and Infrastructure Companies and
29 Nov 2023 · Rail Capacity proposal
Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail
17 Nov 2023
In attachment you'll find PKP PLK position on the draft Regulation on the use of railway infrastructure capacity in the Single European Railway Area.
Read full responseResponse to European Sustainability Reporting Standards
7 Jul 2023
PLK SA appreciates the efforts on the CSRS and presents below its position on the standards. the proposed ESRS seems very complex and lacks clear guidance in terms of what is mandatory or voluntary to report; templates for reporting for companies are also missing in the draft legal act; we think that at the beginning of the application of the standards, the scope of reporting should be narrow and expanded in subsequent years. The first reports of companies should contain basic data, the scope of which will increase over time. For many of the elements specified in the standards, specific numeric values are required. In order to be able to do this reliably, large entities/enterprises need time to define key indicators, introduce tools for appropriate data collection, prepare stakeholders, suppliers, etc. to the need to provide relevant data. The issue is really complex due to the need to include multiple actors in the value chain. In addition, the collection of a certain amount of data requires systemic changes at national level, including changes to the national legislation that is currently in force. Examples of information that requires many years of preparation are below: a. anticipated financial effects from material physical risks; b. anticipated financial effects from material transition risks; and c. potential to pursue material climate-related opportunities. ESRS E2 - We ask for clarification of the below provisions by indicating that these provisions concern only emissions of substances and do not apply to emissions of energy such as heat, noise, vibration or electromagnetic fields: This Standard sets out Disclosure Requirements related to the following sustainability matters: pollution of air, water, soil, substances of concern, including substances of very high concern. Pollution of air refers to the undertakings emissions into air (both indoor and outdoor), and prevention, control and reduction of such emissions. ESRS E5 we see no legal basis for obtaining information on waste: The undertaking shall disclose the following information on its total amount of waste from its own operations, in tonnes or kilogrammes (). In waste management, there is a waste producer, waste collector and waste processor.The transfer of waste by the producer to the waste collector causes the collector to take responsibility for it and decides on the manner of its management. The collector does not have to inform the waste producer about it. In addition, we ask for clarification of what is meant by the wording (in the context of the definition of a waste producer defined in the Waste Directive): The undertaking shall disclose the following information on its total amount of waste from its own operations. Does the amount of own waste mean the amount of waste of which the reporting entity is the producer? As defined in the Waste Directive (Directive 2008/98/EC): 'waste producer' means any operator whose activities generate waste (original waste producer) or anyone involved in pre-processing, mixing or other processes leading to a change in the nature or composition of that waste. In the field of energy, it would be advisable to specify the assumptions for providing information on: o consumption of purchased or supplied electricity, heat, process steam and cold generated using fossil sources (MWh); o consumption of purchased or supplied electricity, heat, process steam and cold generated using renewable sources (MWh). On the basis of the percentage distribution of the energy mix indicated by the electricity seller and the consumption recorded in a given year by the company, we can convert the desired amount of the above consumption. Guidelines/interpretations in this respect would indicate whether the available options for determining the above consumption are consistent with the reporting assumptions in this respect.
Read full responseResponse to List of essential services that critical entities provide
16 Jun 2023
Regarding the list of essential services in connection with the provisions of Directive (EU) 2022/2557 of the European Parliament and of the Council of 14 December 2022 on the resilience of critical entities, PLK SA proposes the following changes in the list of essential services: - article 2 (2) (b) (ii) is replaced by: construction of timetables, management and operation of rail traffic, operation, management and maintenance of trans-European railway infrastructure, including passenger stations, freight terminals, railway stations and traffic control centres; - delete Article 2(2)(b)(iv). Justification: The risk assessment referred to in Article 5 of Directive 2022/2557 should apply to those essential services which once interrupted may have a significant disruptive effect on a scale affecting the functioning of the internal market (cross-border scale). We point out that not every element of the network managed by the infrastructure manager will cause the above effect. For example, disruption of a part of the network of local or peripheral nature will not cause disruption in trans-European traffic.
Read full response15 Jun 2023
PLK SA position on the public consultation on the draft delegated regulation amending Regulation 2017/1926 with regard to the provision of multimodal travel information services 1.Regarding the introduction of real-time information requirements, we indicate that: the definition of real-time information should be clearly defined; in accordance with Art. 2 p. 5 of Regulation 2021/782 rail passengers rights and obligations, there is a 9-year transition period for infrastructure managers (i.e. until 2030) for the requirements concerning providing dynamic data in real time if the technical preparation is insufficient. Art. 2 p. 5 states that: Until 7 June 2030 Member States may provide that Article 10 shall not apply where it is not technically feasible for an infrastructure manager to distribute real-time data within the meaning of Article 10(1) to any railway undertaking, ticket vendor, tour operator or station manager. At least every two years, the Member States shall reassess the extent to which it is technically feasible to distribute such data. It should be noted that there must be no incompatibility between EU legal acts, we therefore propose to add a transitional/exempt period provision to this draft. 2. We point out that the duration of historical data storage is not specified - we suggest limiting this to 1 year. 3. The issue of providing data on the comprehensive TEN-T network is unclear - is it only for the comprehensive layer excluding the core layer or just the whole TEN-T double-layer network?
Read full response24 Jan 2023
Below please find PLK comments to the annex to the Commission Implementing Regulation amending Commission Regulations: (EU) No 321/2013, No 1299/2014, No 1300/2014, No 1301/2014, No 1302/2014, No 1304/2014 and Commission Implementing Regulation (EU) 2019/777. Applies to TSI PRM: Ref. Annex III paragraph 9 point 4.2.1.2.2. is replaced by the following: 4.2.1.2.2. Vertical circulation (3a) When they are used as a complement to stairs, ramps may have a width of 120 cm. Remark: The wording in this form allows for different interpretations regarding the measurement of the width of the ramp and still does not solve the problem. It is advisable to clarify this wording: (3a) When they are used as a complement to stairs, ramps may have a minimum width of 120 cm at surface level and a minimum width of 100 cm measured between the handrails. (Justification is ISO/FDIS 21542 Bulding construction - Accessibility and usability of the built environment" point 8.3 Width of ramps). Applies to TSI ENE: Ref. to point 2.1(2) (a) of TSI ENE The text which reads: (a) substations: connected on the primary side to the high-voltage grid, with transformation of the high-voltage to shall be corrected as follows: (a) substations: connected on the primary side to the high- or medium- voltage grid, with transformation of the high- or medium- voltage to Justification: Feeding of traction substations from a medium-voltage level is quite common in the case of DC traction power supply systems. In Poland the most TSs are powered by 15 kV power grids. Ref. to point 6.1.4.1(3) (f) of TSI ENE The text which reads: (f) The uplift of at least two steady arms shall be measured. shall be corrected as follows: (f) The uplift of steady arms for at least two subsequent suspension structures shall be measured. Justification: In our opinion the above correction will reflect the intensions of this supplementary requirements in more precise way, making the statement correct for both AC and DC OCL, the latter most often comprising of two contact wires. Thus two steady arms in the case of DC systems would in practice represent only one measurement point. Ref. to point 7.1.2.1 (a) of TSI ENE The text which reads: (a) New energy subsystems with speed greater than 250 km/h shall accommodate both pantographs If this is not possible, the OCL shall be designed for use by at least a pantograph with the head geometry (1600 mm) shall, in our opinion, either more specifically present acceptable factors / reasons which would make fulfilling the main requirement (accommodation of both pantographs ) impossible otherwise the above can be seen as a widely open door to implement technical solutions permitting the use of only 1600 mm pantographs or be deleted because, in practice, IMs declare in RINF only one of the pantographs widths from the commonly adopted data set (1600 mm, 1950 mm). Moreover, in our opinion, also point 6.1.4.1 (1) (e) of TSI ENE is worth reconsidering which reads: e) If an existing OCL design has been in operation for at least 20 years, then the requirement for simulation defined in the point (2) is optional. According to our experience, carrying out simulation for OCL designs being in operation for years means time- and money- consuming excessive activities providing fully expectable repetitive results. Therefore we regard 5 years as sufficient time period for the reason indicated above.
Read full responseMeeting with Bogusław Liberadzki (Member of the European Parliament)
30 Nov 2022 · Exchange of views
Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)
13 Feb 2020 · Transports