An on-site water abstraction point, supplying water to other entities or responsibility for a building's plumbing system — each of these situations may be relevant when determining water quality obligations. The changes introduced in 2026 are not limited to water utilities or priority premises.
For businesses, the key is to establish their role in the water supply system and which part of the infrastructure they are responsible for. Only then can the required assessments, testing and deadlines be determined.
What has changed in the legislation?
The Act of 13 March 2026 amending the Polish Act on collective water supply and collective wastewater disposal entered into force on 21 May 2026. A new Regulation of the Minister of Health on the quality of water intended for human consumption has also applied since 24 June 2026.
The new rules introduce a risk-based approach throughout the supply chain: from the catchment area for the abstraction point, through treatment, storage and distribution, to the domestic distribution system.
Although the amended Act also concerns wastewater, the obligations described here relate to the quality and safety of water intended for human consumption. Act, Regulation.
Water suppliers — not just water utilities
The statutory definition of a water supplier covers an entity supplying water intended for human consumption, including a water and wastewater utility and an entity engaged in the wholesale supply of water.
Further analysis is therefore needed, for example, where an industrial site:
- uses its own abstraction point to supply buildings and their users;
- supplies water to another business through its own infrastructure;
- shares a system with other entities and bills them for water consumption.
Ownership of a well, the presence of a submeter or issuing bills alone are not sufficient to establish the full scope of obligations. Relevant factors include the intended use of the water, how it is supplied, its recipients and the actual allocation of responsibilities.
Statutory exclusions and specific rules for smaller suppliers must also be checked. It should not be assumed that every site with its own abstraction point needs the same set of assessments and tests.
For entities subject to the relevant requirements, obligations may include water quality monitoring, risk assessments, remedial measures and reporting to the competent authorities. Relevant provisions for determining applicability include Articles 1b, 2(1), 4e–4h and 4p of the Act.
When can an industrial site include priority premises?
Priority premises are non-residential premises in which more than 50 people per day are exposed to water-related risks.
This does not mean that every company employing more than 50 people automatically meets the definition. At a site comprising several production halls, offices and staff facilities, it is necessary to determine what constitutes each individual premises, who uses it and who is responsible for its domestic distribution system.
Showers, domestic hot water or equipment generating water aerosols are important when analysing hazards and the scope of testing. However, they do not replace verification against the statutory definition of priority premises.
The owner or manager of such premises must prepare a written risk assessment of the domestic distribution system. This covers the plumbing system, materials in contact with water and their potential impact on water quality at the points of use.
The assessment must be reviewed at least every six years and updated where necessary. The person carrying it out must meet the requirements set out in Article 4l of the Act — simply having a document prepared by any employee or consultant is not sufficient. Articles 4i–4l of the Act.
Legionella and lead: testing requirements differ between premises
Classification as priority premises does not automatically mean identical obligations to test for Legionella and lead in every building.
For Legionella, the Act identifies specific categories of premises, including healthcare facilities, premises intended for temporary accommodation and public-use buildings with installations or equipment generating water aerosols.
For lead, both the categories of premises specified in the Act and the findings of an analysis of potential plumbing-related risk must be considered. If the analysis identifies such a risk, testing frequency is agreed with the competent sanitary authority. If it identifies no such risk, the Act provides for testing to be waived.
The new Regulation sets out sampling rules, Legionella testing frequencies and the action to be taken depending on the results. The scope of monitoring should therefore follow the classification of the premises and the applicable provisions, rather than a single universal testing package. Articles 4i–4j of the Act, Sections 7–8 of the Regulation.
Not being priority premises does not end the enquiry
The legislation also provides for broader measures by building owners and managers concerning the safety of domestic distribution systems.
These include risk-proportionate measures to reduce the risk of Legionella in domestic hot water: temperature checks, limiting stagnation, flushing pipework, and cleaning and maintaining water-heating equipment.
The Act also provides for the replacement of components containing lead where this is economically and technically feasible.
Consequently, finding that a building is not priority premises does not mean there are no water quality obligations. The other requirements applicable to the particular entity and installation must be checked. Article 4m of the Act.
Which deadlines need to be considered?
Three deadlines are key for entities subject to the respective obligations:
| Obligation | Submission deadline |
|---|---|
| Risk assessment of the catchment area for the abstraction point, together with a summary report | By 31 December 2026 — to the competent Director of the Regional Water Management Authority (RZGW) of Polish Waters and the competent sanitary inspector |
| Risk assessment of the water supply system, together with a summary report | By 30 June 2028 — to the competent sanitary inspector |
| First risk assessment of the domestic distribution system of priority premises | By 30 June 2028 — to the competent sanitary inspector |
For priority premises brought into use after 30 June 2028, the deadline is six months from the date they are brought into use.
Risk assessment deadlines do not mean that ongoing requirements for water quality, monitoring or responding to irregularities may be postponed until then. Articles 7 and 9 of the amending Act.
Where should a business start?
A useful starting point is to gather answers to five questions:
- Where does the water come from, what is it used for and to whom is it supplied?
- Who is responsible for abstraction, distribution and the plumbing systems in individual buildings?
- Could any of the premises meet the definition of priority premises?
- What hot water installations, showers and other aerosol sources are present at the site?
- What documentation, test results and installation maintenance procedures does the company have?
This classification makes it possible to determine the appropriate scope of action — without overlooking obligations, but also without commissioning assessments and tests that do not fit the site's circumstances.
How can Ecothesis help?
Ecothesis helps determine which obligations apply to a particular site: analysing its water supply arrangements, classifying premises, clarifying responsibility for installations and planning the required assessments and testing.
If a formal risk assessment of the domestic distribution system is required, it must involve a person meeting the statutory requirements. We agree on the scope of further support after reviewing the site's circumstances.
Would you like to check where your business should start? Contact us: This email address is being protected from spambots. You need JavaScript enabled to view it. | +48 530 778 650.
Legal position verified as at 9 September 2026. This material is for information purposes and does not constitute an individual legal opinion. The scope of obligations must be determined for the specific premises and factual circumstances.