Polish DSR Market Report
Comprehensive analysis of Demand Side Response in Poland: transition from Capacity Market reliance to a broader flexibility ecosystem
Executive Summary
The Polish DSR (Demand Side Response) market is undergoing a significant transformation between 2023 and February 2026. The paradigm is shifting from "DSR equals Capacity Market" to "DSR as a key component of a broader flexibility market".
The primary catalyst for this change is the Phase 2 of the Balancing Market reform (RB Phase 2), implemented in June 2024. This reform aligned Poland with European standards by introducing 15-minute settlement intervals and scarce pricing mechanisms, fundamentally altering the revenue potential for flexible assets.
Market Status
Volumes, Pricing, and Capacity Market trends
Tech Potential
10.6 GW
Registered Capacity
2026 Volume
1,504 MW
Contracted DSR
2026 Price
400.39 PLN
per kW/year
2028 Value
416M PLN
Est. Market Value
Technical Potential vs. Market Utilization
While the theoretical technical potential of DSR in Poland is estimated at 10.6 GW (based on registered generation and curtailable load resources), the actual market utilization remains significantly lower (~1.5 GW contracted in 2026).
Large industrial assets often maintain capacity for internal redundancy rather than market participation due to operational risk aversion.
Many facilities lack the sub-second telemetry and automated control systems (SCADA/EMS) required for advanced Balancing Market products.
Hesitancy to invest in compliance upgrades amidst rapidly changing Balancing Market regulations (Phase 1 vs Phase 2).
Capacity Market Prices
Price per kW/year (PLN)
DSR Volumes
Contracted Capacity (MW)
DSR Market Value Estimation (2024-2028)
Estimated total market cap in Million PLN (Capacity Market + Ancillary)
| Year | Pessimistic | Realistic | Optimistic |
|---|---|---|---|
| 2024 | 267.4 | 267.4 | 267.4 |
| 2025 | 131.2 | 164.0 | 196.8 |
| 2026 | 481.8 | 602.2 | 722.6 |
| 2027 | 500.3 | 625.4 | 750.5 |
| 2028 | 333.0 | 416.3 | 499.6 |
Regulatory Landscape
Impact of Balancing Market Reforms
Phase 2 Reform Implementation
The introduction of Phase 2 reform has fundamentally altered the operational landscape for DSR assets. Key changes include:
- ✓ 15-minute settlement intervals replacing hourly blocks
- ✓ Strict telemetry requirements (real-time data to OSD/PSE)
- ✓ New BSP/BRP participant structure
- ✓ Introduction of Scarcity Pricing mechanisms
Implications for Industry
The shift to 15-minute intervals requires significantly faster reaction times. Manual dispatch is no longer viable for capturing peak prices. This drives a need for automated Energy Management Systems (EMS) capable of reacting to price signals or operator commands within seconds.
Technology & Architecture
Reference DSR Implementation
Modern DSR implementation requires a robust stack connecting physical assets (HVAC, Pumps, BESS) to the central market operator via an aggregator. The architecture must ensure secure, low-latency communication.
Economics & Revenue Models
Financial Performance Scenarios
1. Industrial Plant DSR Model (1 MW)
Analysis of a typical industrial facility participating in the Capacity Market (2026 delivery). Assumes a base capacity payment of 400.39 PLN/kW/year.
| Metric | Pessimistic | Realistic | Optimistic |
|---|---|---|---|
| Reduction Potential (MW) | 0.5 | 1.0 | 1.5 |
| Revenue Share (%) | 70% | 80% | 85% |
| Performance Factor | 0.85 | 0.95 | 0.98 |
| EBITDA (PLN) | 144,140 | 374,765 | 615,099 |
| Payback Period (Years) | 1.0 | 0.4 | 0.3 |
| IRR (5y) | 92% | 240% | 307% |
* Pessimistic: Conservative reduction potential (50%), lower performance during test events.
* Realistic: Standard reduction (100% of nominated), typical 80/20 revenue share.
* Optimistic: Enhanced reduction (150% via over-performance), premium revenue share conditions.
2. BESS Investment Variant (1 MW / 2-4 MWh)
Investment analysis for a dedicated Battery Energy Storage System (BESS) participating in both Capacity Market and aFRR (Automatic Frequency Restoration Reserve).
| Metric | Pessimistic | Realistic | Optimistic |
|---|---|---|---|
| CAPEX (PLN/MW) | 3.2M | 2.8M | 2.5M |
| OPEX (% of CAPEX) | 2.5% | 2.0% | 1.5% |
| Owner Share (%) | 70% | 80% | 90% |
| Payback (Years) | 4.2 | 3.1 | 2.4 |
| IRR (10y) | 18% | 29% | 38% |
Capacity Market
Primary revenue stream. Long-term contracts providing stable base revenue. Prices peaking in 2026-2027 before a projected dip in 2028.
Ancillary Services (aFRR)
Growing opportunity for fast-response assets like BESS. Revenue sharing models (e.g., 80/20) becoming standard for active players.
Energy Trading
Optimization on Spot/Balancing markets. Requires sophisticated forecasting and automation capabilities.
Aggregator Landscape
Key players and market positioning
| Aggregator | Status (URE) | Main Markets | Scale | Revenue Model | Notes |
|---|---|---|---|---|---|
| Enel X Poland | Registered 01/2026 | DSR Capacity Market | 450+ firms, ~670 MW | Revenue share, no-capex | Enterprise DSR leader with global backing. |
| Photon Energy/Lerta | Registered 001/2024 | DSR, aFRR for BESS | 389 MW (2024), 315 MW (2025) | 80/20 revenue share in aFRR | Most market-active player, pioneering BESS aggregation. |
| Columbus | Registered 002/2025 | Aggregation planned | Not disclosed | Not specified | Focus on prosumer aggregation and energy retail. |
| Verda | Registered 003/2025 | Aggregation declared | Not disclosed | Not specified | Emerging aggregator focused on industrial efficiency. |
| CheckWatt | Registered 013/2025 | VPP, BESS/EV | 15k sites Nordics | Not specified | Nordic giant entering with mass-market VPP tech. |
Timeline of Key Events
The evolution of Polish flexibility markets
New Balancing Conditions (WDB) Approved
Approval of new Balancing Conditions and introduction of ISP (Increasing Consumption) to system services.
Phase 2 Balancing Market Reform
Implementation of 15-minute settlement intervals, updates to Capacity Market Regulation, November dispatch periods, and URE aggregator registry requirements.
PSE Joins PICASSO Platform
Polskie Sieci Elektroenergetyczne (PSE) joins the European aFRR platform (PICASSO). Publication of PSE Strategy 2040.
MARI Accession Planned
Planned accession to the MARI (mFRR) platform. Updated URE aggregator registry.
Barriers & Risks
Challenges in market adoption
Regulatory
Uncertainty regarding the post-2028 capacity market mechanisms ("DSR Phase 3"). Frequent changes to technical requirements for certification and testing.
Technical
High cost of integrating legacy BMS/SCADA systems with modern aggregator APIs. Strict requirements for telemetry reliability (VPN tunnels, redundancy).
Market
Price volatility in the Balancing Market may lead to penalties for under-delivery. "Cannibalization" of revenue streams as more BESS capacity enters the system.
Negative Energy Prices in Europe
ENTSO-E day-ahead market analysis — an opportunity for flexible crypto mining loads
Our system has been continuously backfilling day-ahead spot price data from the ENTSO-E Transparency Platform since 2023 across all major European bidding zones. The analysis below quantifies the growing phenomenon of negative electricity prices — hours when grid operators effectively pay consumers to absorb excess energy.
This structural oversupply, driven by growing renewable capacity (wind & solar) outpacing storage and demand flexibility, represents a compelling economic opportunity for Bitcoin mining as a flexible, interruptible load. Miners can consume energy during negative-price periods and curtail during peak demand, creating a symbiotic relationship with the grid.
DE-LU 2025
2,265 h
↑ ~26% of yearAT Growth
×2.7
↑ 671→1,805 hrsSpain Surge
0→703 h
↑ 2023→2025Deepest Spike
-500 €
↓ DE, NL, FIGermany (DE-LU): Negative Hours Growth
Day-ahead hours below 0 €/MWh
Austria (AT): Negative Hours Growth
Day-ahead hours below 0 €/MWh
2025
11 zones with negative prices
| Zone | Neg. Hours | % of Year | Min Price (€) | Avg Neg (€) | Days Affected | Intensity |
|---|---|---|---|---|---|---|
| 🇩🇪DE-LU | 2,265 | 25.9% | -499.99 | -20.51 | 140 | |
| 🇦🇹AT | 1,805 | 20.6% | -252.60 | -37.64 | 167 | |
| 🇸🇪SE2 | 896 | 10.2% | -25.22 | -1.71 | 107 | |
| 🇪🇸ES | 703 | 8.0% | -15.00 | -2.54 | 106 | |
| 🇳🇱NL | 684 | 7.8% | -350.00 | -10.53 | 116 | |
| 🇧🇪BE | 601 | 6.9% | -462.33 | -12.49 | 105 | |
| 🇩🇰DK1 | 514 | 5.9% | -38.14 | -3.42 | 86 | |
| 🇫🇷FR | 462 | 5.3% | -118.01 | -7.22 | 99 | |
| 🇫🇮FI | 446 | 5.1% | -21.39 | -1.29 | 90 | |
| 🇨🇿CZ | 343 | 3.9% | -224.49 | -14.19 | 72 | |
| 🇵🇱PL | 323 | 3.7% | -132.95 | -15.08 | 72 | |
2024
11 zones with negative prices
| Zone | Neg. Hours | % of Year | Min Price (€) | Avg Neg (€) | Days Affected | Intensity |
|---|---|---|---|---|---|---|
| 🇩🇪DE-LU | 1,912 | 21.8% | -187.99 | -21.52 | 140 | |
| 🇦🇹AT | 1,425 | 16.2% | -150.00 | -27.22 | 168 | |
| 🇸🇪SE2 | 688 | 7.8% | -59.96 | -2.51 | 109 | |
| 🇫🇮FI | 687 | 7.8% | -20.01 | -1.71 | 118 | |
| 🇳🇱NL | 448 | 5.1% | -200.00 | -18.42 | 98 | |
| 🇧🇪BE | 401 | 4.6% | -140.00 | -15.49 | 85 | |
| 🇩🇰DK1 | 370 | 4.2% | -60.05 | -4.91 | 78 | |
| 🇫🇷FR | 340 | 3.9% | -87.29 | -10.52 | 70 | |
| 🇨🇿CZ | 311 | 3.5% | -138.75 | -15.30 | 63 | |
| 🇵🇱PL | 194 | 2.2% | -61.64 | -10.34 | 53 | |
| 🇪🇸ES | 178 | 2.0% | -2.00 | -0.37 | 46 | |
2023
11 zones with negative prices
| Zone | Neg. Hours | % of Year | Min Price (€) | Avg Neg (€) | Days Affected | Intensity |
|---|---|---|---|---|---|---|
| 🇩🇪DE-LU | 1,777 | 20.3% | -149.99 | -17.58 | 132 | |
| 🇦🇹AT | 671 | 7.7% | -500.00 | -22.91 | 76 | |
| 🇫🇮FI | 443 | 5.1% | -500.00 | -3.86 | 65 | |
| 🇸🇪SE1 | 422 | 4.8% | -60.04 | -2.55 | 58 | |
| 🇸🇪SE2 | 422 | 4.8% | -60.04 | -2.55 | 58 | |
| 🇳🇱NL | 310 | 3.5% | -500.00 | -23.30 | 66 | |
| 🇩🇰DK1 | 279 | 3.2% | -440.10 | -12.36 | 52 | |
| 🇧🇪BE | 217 | 2.5% | -120.00 | -10.62 | 45 | |
| 🇫🇷FR | 140 | 1.6% | -134.94 | -7.18 | 30 | |
| 🇨🇿CZ | 134 | 1.5% | -68.54 | -8.09 | 26 | |
| 🇵🇱PL | 43 | 0.5% | -13.81 | -4.94 | 8 | |
Accelerating Trend
Germany (DE-LU) leads with 1,777 → 1,912 → 2,265 negative hours, representing ~26% of all hours in 2025. Austria surged from 671 to 1,805 hours with deepening average negative prices (-22.91 → -37.64 €/MWh).
New Markets Emerging
Spain went from zero negative hours in 2023 to 703 in 2025. Poland jumped from 43 to 323 negative hours with prices hitting -132.95 €/MWh, signaling expanding opportunities beyond traditional Nordic/Central European zones.
Depth vs. Frequency
Nordic zones (NO, SE, FI) exhibit high frequency but shallow depth (avg -1 to -6 €/MWh), while Central European zones show fewer hours but extreme spikes: NL at -500 €/MWh (2023), BE at -462 € and DE at -500 € (2025).
Mining Opportunity
A mining operation in DE-LU could have operated at effectively zero or negative energy cost for 2,265 hours in 2025. Combined with curtailment revenue during peak demand, this creates a dual revenue stream that significantly improves mining economics.
Methodology & Data Source
Data sourced from ENTSO-E Transparency Platform day-ahead market prices. Backfilled continuously since January 2023. Only hours with price < 0 EUR/MWh are counted. "Days Affected" counts distinct calendar days with at least one negative-price hour. Nordic zones include all SE (SE1–SE4) and NO (NO1–NO5) bidding zones; the table shows the highest-volume zone per country for brevity.
International Benchmark
Poland vs Global Markets
Germany
Transparent regulatory markets (regelleistung.net). 1 MW minimum threshold. Advanced integration with PICASSO/MARI platforms.
Spain
REE "active demand response". 1,148 MW contracted at 56.43 EUR/MW/h for 2025. Strong focus on reliability.
USA
FERC Order 745 & 2222 driving DER aggregation. Massive scale with ~24 GW of Demand Response available.