The government is working on a draft bill designed to establish a national system for responding to disruptions in the internal market. One of its key elements will be a list of companies operating within supply chains for goods and services of critical importance. Draft UC157 is due to be adopted by the Council of Ministers in the third quarter of 2026.
The new regulations are a national supplement to the EU’s IMERA Regulation, which has been in force since 29 May 2026. The regulation was drawn up in the wake of the pandemic, Russia’s aggression against Ukraine and the energy crisis. Its aim is simple: in the event of another crisis, EU Member States are to identify supply chain problems more quickly and respond without imposing uncoordinated restrictions on the movement of goods, services and workers.
In Poland, the minister responsible for the economy is to oversee the Central Liaison Office and the Single Point of Contact. The administration will monitor key supply chains, and under certain conditions, companies may be asked to provide information on, amongst other things, production capacity, stock levels and disruptions. EU regulations require, however, that trade secrets be protected and that the burden on SMEs be taken into account.
This means greater pressure to provide up-to-date data on suppliers, stocks and production capacity. In practice, the list is intended to be an operational tool, not a sanctioning mechanism. Its importance will become apparent during a crisis, when the authorities will need to quickly identify where bottlenecks are occurring and which companies are critical to the continuity of supply.
A possible side effect is additional reporting requirements. On the other hand, a benefit could be faster coordination of public procurement, distribution and the flow of critical goods. This measure forms part of the EU’s broader shift towards economic resilience, which also covers semiconductors and critical raw materials.
