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HWW Hewelt Wojnowski Lindner i Wspólnicy

Hedging strategy for an electricity trading company

For electricity trading companies that need a hedging strategy linked to contracts and the options for financing supplies. We prepare documentation for the President of the Energy Regulatory Office (URE) and handle the matter at the stage of supplementation, reporting or proceedings concerning a penalty.

This offer is prepared by the team of HWW Hewelt Wojnowski Lindner i Wspólnicy sp.k. The matter is led by Aleksandra Lindner, partner and adwokat (Polish advocate). Telephone: +48 22 100 42 24.

Request a quote +48 22 100 42 24
Fee
from 3 400 EUR net
We agree the scope of the engagement from among the tasks listed below, according to the stage of the matter.
Prices are net, in EUR. VAT depends on your status and place of establishment.

You can order this service directly, without a prior consultation. We confirm the scope and the fee before we start.

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A consultation is optional. To discuss your matter with a lawyer first, you can book a consultation. If you then order the work, its cost is credited against the project fee.

Before we start, we agree and confirm the scope and the fee. The price is indicative and does not constitute an offer within the meaning of the Polish Civil Code.

What it includes

  • We determine whether the company must develop and apply a hedging strategy, to define the scope of further work (Article 10e(1) of the Polish Energy Law (Prawo energetyczne)).
  • We develop the strategy: we assess the risk, select hedging measures and take account of the guidelines of the President of URE (Article 10e(1), (2) and (3)).
  • We submit the first strategy to the President of URE by 30 January 2027 (Article 27(2) of the Act of 13 March 2026). We submit subsequent strategies by 15 December of the last year preceding the period they cover (Article 10e(4) of the Energy Law). The strategy is developed every 3 years (Article 10e(4)).
  • We supplement the strategy after a request from the President of URE within one month of receiving it (Article 10e(5)).
  • We prepare and submit an annual report describing the implementation of the strategy in the previous year, by 30 April each year (Article 10e(6)).
  • We review energy purchase contracts and hedging contracts against the measures adopted in the strategy (Article 10e(2)(1) and (2), and 10e(3)(1)).
  • We represent the company before the President of URE in proceedings concerning a penalty (Article 56(1)(61) and (62), and 56(2)). We conduct the appeal to the Regional Court in Warsaw, Court of Competition and Consumer Protection (Article 30(2) and (3)). The time limit for the appeal is 14 days from delivery of the decision (Article 30(2)).

What the price does not include

  • Entering into hedging transactions and obtaining financing.
  • Continuous monitoring of the company's trading position and handling settlements.
  • Negotiating contracts with counterparties, disputes over their performance and criminal proceedings.

What you receive

The documents correspond to the stage of the matter indicated in the engagement:

  • An assessment of the obligation and a strategy with a description of the risk and a justification of the measures adopted.
  • The strategy submitted to the President of URE together with confirmation of submission.
  • A supplementation of the strategy referring to the objections indicated in the request.
  • An annual report linked to documents confirming the actions taken.
  • Comments on energy purchase contracts and hedging contracts, indicating divergences from the strategy.
  • Letters in proceedings concerning a penalty and the appeal, if the matter requires that stage.

Who this service is for

We address this service to management boards and to the legal, commercial and financial departments of electricity trading companies. You can commission the development of the strategy, its supplementation after a request from the President of URE, or the preparation of a report on its implementation.

We start with the company’s contracts and financial data. We set the commitments towards customers against the terms of energy purchases, to justify the choice of measures in the strategy.

Please prepare

  • A description of the business and customer groups and a list of energy sale and purchase contracts.
  • Hedging contracts, data on prices, volumes and supply periods.
  • Data on liquidity, payment terms and available sources of financing.
  • The existing strategy, reports and documents confirming the implementation of the measures adopted.
  • Correspondence with the President of URE, including requests and decisions, together with the dates of their receipt.

Trading and financial data should cover the same period. This makes it possible to link the measures described in the strategy with the contracts they are intended to hedge.

When this service is not enough

If you need to renegotiate contracts, obtain financing or resolve a dispute with a counterparty, we agree a separate scope of work. Handling REMIT obligations or criminal proceedings also requires a separate engagement.

What the fee depends on

  • The number of companies and energy sales models.
  • The number of energy purchase contracts and hedging contracts.
  • The completeness of documentation and financial data.
  • The stage of the matter: strategy, supplementation, report or representation in proceedings concerning a penalty.

The quotation indicates the tasks covered by the engagement, the stage of the matter, the companies, the strategy period and the reporting year. It also states whether the fee covers representation before the President of URE and an appeal to the court. The final quotation depends on the client’s factual and legal situation; we present it once we know that situation, before work begins.

To discuss the matter with a lawyer first, you can book a consultation for PLN 600 net + VAT. If you then order the work, its cost is credited against the fee for this project.

The price is indicative and does not constitute an offer within the meaning of the Polish Civil Code.

Questions and answers

Which energy undertakings must develop and apply a hedging strategy?

The obligation covers energy undertakings engaged in electricity trading (Article 10e(1) of the Energy Law).

What should the hedging strategy contain?

The strategy sets out measures limiting the risk of contracts with customers becoming unprofitable as a result of changes on the wholesale electricity market (Article 10e(2)(1)). The strategy also includes measures designed to ensure liquidity on the day-ahead and intraday markets and continuity of supplies (Article 10e(2)(2) and (3)).

By when does the company submit the strategy to the President of URE?

The company submits the first strategy to the President of URE by 30 January 2027. The deadline is 9 months from the entry into force of the Act of 13 March 2026 amending the Energy Law and certain other acts (Article 27(2)). The company develops subsequent strategies every 3 years and submits them by 15 December of the last year preceding the period they cover (Article 10e(4) of the Energy Law).

Act of 10 April 1997, the Energy Law (Prawo energetyczne), consolidated text: Journal of Laws of 2026, items 43, 516, 607, 900, 1347 and 1348:

  • Article 10e(1), (2), (3), (4), (5) and (6).
  • Article 56(1)(61) and (62), and 56(2).
  • Article 30(2) and (3).

Act of 13 March 2026 amending the Energy Law and certain other acts (Journal of Laws of 2026, items 516 and 900):

  • Article 27(2).

How to instruct us

  1. Please describe the matter in the form or call +48 22 100 42 24.
  2. Please indicate the stage of the matter and the date of receipt of a request or decision, if such a letter has been received.
  3. We will reply by 17:00 on the next working day. Before work begins, we will confirm the scope and the fee.
Company or private individual?
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How to start

You can order this service directly or book a consultation first. A consultation is not required to order the service.

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