The impetus for change was, among others, alarming signals coming from honest market participants.
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The Polish Organization of Petroleum Industry and Trade (POPiHN) in its report for 2025 identified a harmful mechanism of the so-called three-field cars.
It involves the cyclical establishment and closure of legal entities only to temporarily avoid the costly obligation to maintain emergency stocks.
“As a result, the same fuel volumes circulate between different entities or legal structures, and the real reserve load is unevenly distributed, which undermines the stability of the fuel security system,” POPiHN points out.
Greater role of RARS and new obligations for companies
The draft amendment provides for a number of solutions that are intended to make the system more transparent and resistant to manipulation. The most important changes include:
- extension of the inventory holding period: Entrepreneurs ending their business will not be able to abandon their warehouse duties overnight.
- repurchase mechanism: companies exiting the market will be able to apply to RARS to buy back the accumulated fuels.
- blocking “escape” before settlement: the new regulations will make it impossible to close the business before all liabilities and receivables to the Agency have been settled.
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Objectives of the amendment: transparency and proportionality
The Ministry of Energy emphasizes that the amendment is intended not only to tighten the system, but also to organize the rules of the game for all market participants.
“The purpose of the draft act is to organize and increase the transparency, predictability and proportionality of regulations related to the creation and maintenance of emergency stocks of crude oil and fuels.“, we read in the government list.
When will the changes come into force?
According to schedule, The Council of Ministers is to adopt the project in the second quarter of 2026. The new law will hit entities that have so far transferred the costs of maintaining the state's fuel security to companies operating continuously and reliably.
Currently, the Polish system is based on two pillars: mandatory stocks (maintained by producers and importers) and agency stocks (managed directly by RARS). The amendment is intended to ensure that both pillars will cooperate in a stable manner and resistant to rapid market changes.
