⚠ A Franchise Built on Policy That Can ChangeModerate threat

GPW (GPW) — threat to the moat

What a rule created, a rule can retire.

The certificate markets are creatures of policy, and the policy is already changing. Poland reduced the obligation to redeem green certificates, and cancellations on TGE's register fell from 19,0 terawatt-hours in 2023 to 14,0 in 2024 and 8,0 in 20251. In the first half of 2026, property-rights trading volume fell another 32,3%2.

Property rights cancelled on TGE's register (TWh)19,0202314,020248,02025GPW Management Board report 2025, Register of Certificates of Origin
Cancellations fell by 58% in two years as the redemption obligation was cut.

The consequence is visible in a single line. Revenue from trading property rights was 39,6 million złoty in 2017 and 17,7 million in 20253, while TGE's electricity and gas lines grew. Nothing TGE did caused the decline; a statute made it.

This is the general risk of the commodity business in concentrated form. Volumes a law creates, a law can remove, and the exchange is not consulted either way. The State Treasury, which holds 51,80% of GPW's votes4, belongs to the same government that writes the energy rules.

Watch register revenue. If it keeps falling while guarantees of origin grow, the franchise is changing shape; if both fall, it is ending.

References
  1. ReportedPoland reduced the obligation to redeem green certificates, and cancellations on TGE's register fell from 19,0 terawatt-hours in 2023 to 14,0 in 2024 and 8,0 in 2025.
    GPW Management Board report on 2025 - TGE: electricity and gas volumes 2021-2025, share of consumption, certificates of origin and guarantees of origin, the draft reinstatement of the exchange obligation (80% electricity, gas 55% to 85%) — FY2025 · publ. March 2026 · source ↗
  2. ReportedIn the first half of 2026, property-rights trading volume fell another 32,3%.
    GPW Group interim report for H1 2026 - revenue by line, turnover, listings, TGE volumes, operating expenses, FTEs, ratios, dividend, associates (KDPW 33,33%) — H1 2026 · publ. September 2026 · source ↗
  3. ReportedRevenue from trading property rights was 39,6 million złoty in 2017 and 17,7 million in 2025, while TGE's electricity and gas lines grew.
    GPW Group Basic financial data workbook (to Q2 2026) - consolidated income statement 2007-2025, EBITDA and margins, employee and external-service costs — 2015-2025 · publ. September 2026 · source ↗
  4. ReportedThe State Treasury, which holds 51,80% of GPW's votes, belongs to the same government that writes the energy rules.
    GPW Management Board report on 2025 - GPW shares and shareholders: EPS, dividend per share 2021-2025, dividend yield, P/E, share price, payout rates, State Treasury 35,01% of shares and 51,80% of votes — FY2021-FY2025 · publ. March 2026 · source ↗
Sources
Generated September 24, 2026