• Detached from market realities, the conditions of the “My Electric 2.0” program announced by NFOŚiGW create the risk of significant funds going unused and slowing down the development of electromobility in Poland, warn PSNM and the Instrat Foundation.

• The biggest drawbacks of the new program include the exclusion of the largest group of electric vehicle buyers in Poland from support, as well as restrictive conditions for receiving additional bonuses.

• The government’s priority should be the continuation of the proven “My Electric” program, implemented since 2021, which has led to a significant increase in electric vehicle registrations in Poland, emphasize PSNM and Instrat.

PSNM and the Instrat Foundation point out that to decisively accelerate the electrification of Poland’s car fleet, it is necessary not only to provide a sufficiently high budget but also to set rational rules for granting support. Despite its many flaws, “My Electric 2.0” could complement the existing “My Electric” program if both were implemented in parallel. However, as a standalone and sole instrument for supporting passenger car electrification, the new program is likely to produce the opposite of the intended effects. Unfortunately, the public administration has not provided any official or concrete information about plans for support programs, which deepens informational chaos and market uncertainty. Another problem is the very limited influence of the industry and civil society on the final shape of the program.

– Despite the very positive impact of the “My Electric” program on Poland’s electromobility market, in September the key banking pathway (covering leasing and long-term rental) was suspended, while this week consultations on a completely new program began. Unfortunately, there is no information from the central administration on whether “My Electric” will continue under these circumstances. Very specific information is urgently needed. EV subsidies in Poland remain essential. At the same time, there is a high risk that a successful program, which should remain a priority and has been widely consulted with the industry and optimized over many months, will be replaced by a completely untested instrument based on unrealistic, market-detached assumptions, says Aleksander Rajch, PSNM Board Member.

PSNM and Instrat emphasize that the share of individuals, the target group of the program, in registrations of new passenger BEVs in Poland does not exceed about 40–50% (including vehicles leased or rented by individuals but registered to companies). This means that the largest group of potential beneficiaries—entrepreneurs who are not individuals, making up the majority of new car buyers in Poland—will be excluded from support. Another strength of the “My Electric” program is the involvement of financial institutions providing car leasing in the funding procedure. The new program does not foresee their participation.

– “My Electric 2.0” allocates as much as PLN 1.6 billion—a great sum, significantly higher than the current program’s budget and potentially able to have a very positive market impact. To enable these funds to support rapid and widespread transport decarbonization (i.e., registering an additional 40,000 BEVs), they must be spent efficiently. However, considering the proposed scope and support conditions and the current market share of individual buyers, this budget is unlikely to be fully used. How can we further develop this instrument if we restrict rather than expand the groups covered by support? This is obvious even before the application process begins. The central administration creates the impression that Poland has a surplus of funds for sustainable transport support, while the reality is quite the opposite, says Michał Hetmański, President and Co-founder of the Instrat Foundation.

The “My Electric 2.0” program provides additional bonuses for scrapping old vehicles and for annual incomes below PLN 120,000. According to PSNM and Instrat, these provisions also do not reflect Polish market and economic realities. While the intention to support lower- and middle-income groups is commendable, in practice it is extremely rare for new car buyers to scrap their existing vehicles, which often re-enter the secondary market. The PLN 10,000 additional bonus is unlikely to influence their decisions, as it is not market-based. Consequently, very few beneficiaries will use this incentive, and the current version of the project opens the door to potential abuses, similar to the “Clean Air” program. Instead of unrealistic bonus conditions, it would be more effective to establish a single, fixed amount for the basic subsidy.

PSNM also points out that “My Electric 2.0” sets the maximum eligible vehicle price at PLN 225,000, while the net vehicle price cannot exceed about PLN 183,000. This makes VAT a non-eligible cost, regardless of whether the beneficiary conducts business. This worsens conditions compared to “My Electric,” where VAT is only non-eligible to the extent it can be deducted. As a result, VAT-paying beneficiaries, eligible to deduct 50% or 100% of VAT on the vehicle purchase, can only receive funding for vehicles with a net price of PLN 225,000 (full VAT deduction) or about PLN 202,000 (50% VAT deduction). These assumptions will exclude a large portion of vehicles (about 51% of the current BEV offerings in popular A–D segments), reduce interest in support, and decrease its effectiveness.

– Another criticism of the new program is the exclusion of zero-emission commercial vehicles. The original “My Electric” program provided attractive support for these vehicles. As a result, the N1 category BEV fleet has grown more than fivefold since the end of 2021. The industry received the exclusion of such vehicles in “My Electric 2.0” with considerable surprise. These vehicles are often used commercially, covering many kilometers, especially in cities where road transport emissions are a major problem. Withdrawing subsidies for commercial vehicles, often purchased by individuals running a business, is an irrational decision that will significantly slow electrification in this crucial market segment. The negative impact is worsened by the fact that price differences between electric and combustion N1 vehicles are often larger than in the M1 segment, says Jan Wiśniewski, Director of PSNM Research and Analysis Center.

Public funding support is an effective and popular form of promoting zero-emission transport across the EU. Subsidies are or have been available in many member states, both in Western Europe and CEE. In Poland, EV subsidies were introduced late. The “My Electric” program launched in 2021, with all calls effectively starting in 2022 (for comparison, Romania offered subsidies from 2014, Slovakia and Hungary from 2016). Nevertheless, “My Electric” has been very popular among Poles. According to official NFOŚiGW data, beneficiaries have submitted over 27,000 applications, and more than three-quarters of the BEVs currently on Polish roads were registered during the program’s existence.

– Even though “My Electric 2.0” has been subject to public consultations since November 18, we will not be able to effectively submit our objections. Key program elements are not open to consultation and cannot be changed afterward. This concerns forms and total amount of support, types of bonuses, scope of beneficiaries and eligible vehicles, and budget size. We must sadly admit that while continuing EV subsidies in Poland is essential, and the decision to support the e-mobility market is justified (BEV share of the new passenger car market in Poland is more than four times lower than the EU average), “My Electric 2.0” is inherently a flawed program. We hope, however, for continued constructive dialogue with the central administration and optimization of the new program where possible at this stage, concludes Aleksander Rajch, PSNM Board Member.

– From next year, a very wide range of lower- and mid-class electric cars, including from European manufacturers, will enter the market. The government should recognize this breakthrough and actively support not only purchase but also leasing to make EVs accessible not only to the wealthy. I understand and share the intentions of the Ministry of Climate, but the program must better reflect this. The leasing pathway from the first version of the program is an excellent solution, and I cannot understand why NFOŚiGW does not use it. In a world of still-high interest rates, financial support should be extended toward lower-than-market rates, not restricted, comments Michał Hetmański from Instrat.

Due to the numerous flaws of “My Electric 2.0” and the lack of official information from the central administration regarding the continuation of the “My Electric” program, PSNM, on behalf of the new mobility industry, sent an open letter addressed to Paulina Henning-Kloska, Minister of Climate and Environment.

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Below, we present a list of the most serious flaws of the “My Electric 2.0” program.

Exclusion of a key group of beneficiaries

Commercial companies are responsible for the majority of new passenger car registrations in Poland. This is confirmed, among others, by the results of the “My Electric” program calls, in which individual applicants submitted significantly fewer applications (estimated at around 40%). Implementing the “My Electric 2.0” program in its current form will exclude the largest (and therefore most important) group of potential beneficiaries from support, significantly limiting the impact of subsidies on the zero-emission vehicle market in Poland.

Serious risk of underutilizing substantial financial resources that could significantly impact the development of sustainable transport

The budget of the “My Electric 2.0” program is PLN 1.6 billion. This amount is sufficient to generate positive market effects. To achieve the program’s objectives, these funds should be spent as efficiently as possible. However, considering the scope and conditions of support under “My Electric 2.0” and the current market share of individual applicants, it is already clear at this stage that this budget will not be fully utilized. This creates a risk of criticism for wasting substantial public funds, which—if allocated to a better subsidy program—would provide significant support to the electromobility sector in Poland. Meanwhile, Poland does not have an excess of financial resources for subsidizing zero-emission transport—in fact, the opposite is true.

Conditions for receiving a scrapping bonus that do not reflect market and economic realities

The “My Electric 2.0” program provides additional bonuses to beneficiaries for scrapping an old vehicle. However, the project does not take into account Polish market and economic realities. In practice, it is extremely rare for individuals purchasing new cars to give up their existing vehicles, as these vehicles successfully re-enter the secondary market. As a result, very few beneficiaries will take advantage of this incentive, and the proposed provision opens the door to numerous abuses. Instead of proposing bonuses that are practically unattainable, it would be more effective to proportionally increase and establish a single basic subsidy amount.

Conditions for receiving an income-based bonus that do not reflect market and economic realities

Another bonus in the “My Electric 2.0” program is aimed at individuals with an annual income of no more than PLN 120,000, who can receive an additional PLN 10,000. Meanwhile, the weighted average prices of cars in Poland exceed PLN 180,000. Consequently, few people with an income of up to PLN 120,000 decide to purchase new vehicles (regardless of the type of powertrain), especially since companies are responsible for the vast majority of car registrations in Poland. Therefore, this incentive will also benefit only a very limited number of recipients. Considering the realities of the Polish market, this income-based bonus primarily adds unnecessary complexity to the rules for receiving support.

Unexplained lack of support for zero-emission commercial vehicles

The original “My Electric” program offered attractive support conditions for zero-emission commercial vehicles. As a result, the fleet of BEV category N1 vehicles increased more than fivefold since the end of 2021. These vehicles are frequently used for business purposes, covering many kilometers, especially in cities where transport emissions are most problematic. The industry was surprised by the exclusion of N1 vehicles from the “My Electric 2.0” program. Removing subsidies for commercial vehicles, which are often purchased by self-employed individuals, is an irrational decision that will significantly slow the electrification of this crucial segment of the Polish economy. The negative effects of this limitation are compounded by the fact that price differences between electric and combustion N1 vehicles are often greater than for M1 vehicles.

Potential replacement of an effective support instrument with an untested, potentially ineffective program

To date, beneficiaries of the “My Electric” program have submitted over 27,000 applications. The program is very popular among Poles. During its implementation, over ¾ (76%) of BEVs currently on Polish roads were registered under it. “My Electric” was widely consulted with the industry, and its procedures were gradually optimized to effectively manage a project of such scale. Ultimately, the program proved effective. Its continuation (combined with increased support amounts) should therefore be a priority. In practice, however, the competing “My Electric 2.0” program, if implemented alone, will not only fail to achieve similar positive market effects but will also reduce demand for zero-emission vehicles compared to the scenario in which the original “My Electric” program continued.

Too low maximum price of subsidized vehicles

The “My Electric 2.0” program sets the maximum price of a subsidized vehicle at PLN 225,000. At the same time, the net price of the vehicle cannot exceed approx. PLN 183,000, meaning that VAT is a non-eligible cost regardless of whether the beneficiary is running a business. This significantly worsens conditions compared to the “My Electric” program, in which VAT was a non-eligible cost only to the extent that it could be deducted. As a result, VAT-paying beneficiaries eligible to deduct 50% or 100% of the VAT incurred on vehicle purchase can receive funding only for vehicles with a net price of PLN 225,000 (full VAT deduction) or approx. PLN 202,000 (50% VAT deduction). These assumptions of “My Electric 2.0” will exclude a wide range of vehicles (approx. 51% of the current BEV offerings in popular A-D segments), reduce interest in the support, and lower its effectiveness.

Limited scope of public consultations

The primary goal of public consultations is to gather feedback on proposed changes, with the secondary effect of improving the legislative process. Public consultations are a key instrument of direct democracy. However, key elements of the “My Electric 2.0” program are not subject to consultation and will not be changed after the process. This applies to crucial aspects such as forms of support, total funding, types of bonuses, scope of beneficiaries and subsidized vehicles, and budget size. As a result, stakeholders have very limited influence on the final shape of the program.