VALUE STREAM · GHTC
Green Hospitals Transformation Centre
After the Omnibus, the reporting duty moved away from hospitals. The cost, the risk and the pressure stayed. The Centre works on what stayed — the boiler house, the tender, the waste stream and the energy bill, not the report.
Sustainability stopped being a report
For three years the sector prepared to report. In February 2026 the European Union narrowed the obligation to undertakings with more than 1,000 employees and more than EUR 450 million in net turnover. Above that threshold, Polish hospital care has practically no one left.
That does not mean the problem went away. It means it stopped being a problem for the finance department and went back to being what it always was: a question of how the building is run, how purchasing is structured, what happens to waste and what energy costs. A report can be written. A bill cannot.
4.4%
of global net emissions come from health care — about 2 Gt CO₂e (Health Care Without Harm with Arup, 2019)
1,000 / €450m
the new CSRD threshold under Directive (EU) 2026/470 — headcount and net turnover together
29.05.2026
transposition deadline for the EPBD, Directive (EU) 2024/1275; Poland is still working on it
2028
from this year new public authority buildings are to be zero-emission
2030
from this year the zero-emission requirement covers all new buildings
250 / 520
entities directly affiliated to the Polish Hospital Federation, and total reach including umbrella organisations
What exactly changed in 2026
Omnibus I — Directive (EU) 2026/470
Published in the Official Journal on 26 February 2026. It narrows the scope of the CSRD to undertakings above 1,000 employees and EUR 450 million in net turnover. Member States must transpose the CSRD amendments by 19 March 2027.
The exemption in the Accounting Act
The amendment implementing the “stop the clock” Directive (EU) 2025/794 was published on 13 March 2026 (Journal of Laws 2026, item 333) and took effect on 14 March 2026. First-wave entities that fall outside the new scope may opt into an exemption for 2025 and 2026.
The value chain cap
The Omnibus introduces a value chain cap — a limit on the sustainability information a reporting undertaking may request from entities in its value chain with fewer than 1,000 employees. For a hospital this is not a technical detail: it is the basis for declining a disproportionate questionnaire from a supplier or an insurer.
Buildings — the EPBD
Directive (EU) 2024/1275 was to be transposed by 29 May 2026. Energy classes, renovation passports and a single methodology for life-cycle emissions are still being built in Poland. The deadlines for zero-emission new public buildings (2028) and all new buildings (2030) stand.
What follows from this
A hospital released from the reporting duty is not released from the taxonomy when it seeks financing, from energy requirements when it builds, from environmental criteria in public procurement, or from its counterparties’ questions. The document disappeared; the exposure did not. The Centre exists for the second one.
How the Centre works — four steps
The model is the same for a district hospital and for a multi-site group. It differs in scale, not in order.
01
Measure
Scope 1 and 2 emissions inventory, utility consumption, waste streams, purchasing structure. The starting point is the facility’s own numbers, not a benchmark from a slide deck.
02
Decide
A list of measures ranked by payback period and operational risk, separating what requires capital expenditure from what requires only a change of procedure.
03
Implement
Tender documentation with environmental criteria, funding applications, changes to purchasing and waste procedures, staff training.
04
Account for it
The measurement repeated after implementation. The difference is the result — and the evidence for the payer, the founding authority and the financing institution.
Services
Carbon footprint and environmental data
Emissions inventory, energy and water use, medical waste management, indicators for reports and applications. Data structured to ESRS standards even where the facility has no reporting obligation.
ESG audit and taxonomy readiness
Alignment with the EU taxonomy (Regulation 2020/852) for investment financing, a double materiality review, and a gap analysis against ESRS for voluntary reporting.
Green and value-based procurement
Environmental criteria in tenders, life-cycle costing, and the shift from unit price to total cost — value-based procurement as the purchasing department actually practises it.
Circular economy
Waste reduction at source, reuse and reprocessing where law and patient safety allow, reverse logistics, and a review of single-use devices.
Energy and buildings
Preparing the facility for EPBD requirements: condition assessment, renovation plan, choice of energy sources, and documentation for national and European funding.
Training and micro-credentials
Programmes for management, technical services and procurement teams, with CPE points recognised by the Polish Hospital Federation. ISO, MDR and EMAS pathways.
PUBLICATION
Greenbook — a hospital sustainability compendium
The Greenbook is a working handbook for hospitals, not a commentary on a directive. It covers reporting to ESRS standards, double materiality assessment, environmental, social and governance data, and EU taxonomy alignment — written from the position of a facility with a small team and a real budget.
The Greenbook is published by the Green Hospitals Office of the Polish Hospital Federation together with Mölnlycke Health Care Poland, within the Coalition for Sustainable Development of Medical Facilities. Work on the next edition provides for national adaptations — public procurement rules and purchasing practice differ in every country of the region — with a Czech chapter prepared with the Czech Hospital Federation.
The handbook is available. Full title: Greenbook — a handbook for implementing ESG reporting in hospitals. Downloading it takes a short form on the Green Hospitals Office site: email address, organisation, name, role and a contact number, together with consent to be contacted. The form is in Polish.
Coalition for Sustainable Development of Medical Facilities
The Coalition brings together hospitals, manufacturers and sector organisations around a single aim: that a facility’s green transition should rest on measurable effects rather than on a declaration. The work includes mapping practice across fourteen countries of Central and South-Eastern Europe — CSRD alignment, hospital federations, reference hospitals, and the support programmes actually available.
Alongside the Coalition, the Department runs CyberC4HE, the Coalition for Cybersecurity in Healthcare. It is the same idea in a different risk domain: a shared standard where a single facility has no leverage to build one alone.
Institutional setting
The Centre operates on the axis between the Healthcare Poland Foundation and the Polish Hospital Federation. On the Federation side it is run by the Department of Sustainable Development and Safety, led by Michał P. Dybowski, Chief Sustainability Officer of the Federation. The Federation has approximately 250 directly affiliated members and, together with umbrella organisations including regional hospital associations, reaches close to 520 hospitals.
That matters practically. A standard developed for one facility is a curiosity; a standard adopted as a federation recommendation changes the terms on which the sector talks to suppliers, to the payer and to financing institutions.
What the Centre does not do
We are neither an audit firm nor an accredited body. The Centre does not provide assurance on sustainability reporting within the meaning of the Accounting Act — that is the task of a statutory auditor or an authorised assurance provider. We issue no certificates with legal effect before public authorities. We bring the data, the documentation and the decisions to the point where such a body can verify them and a funding authority can assess them.
Legal basis
- Directive (EU) 2026/470 (Omnibus I) — amending the scope of sustainability reporting and due diligence; published in the Official Journal on 26 February 2026, CSRD amendments to be transposed by 19 March 2027.
- Directive (EU) 2025/794 (“stop the clock”) and the Polish Act amending the Accounting Act — Journal of Laws 2026, item 333, in force from 14 March 2026.
- Directive (EU) 2022/2464 (CSRD) together with the European Sustainability Reporting Standards (ESRS).
- Regulation (EU) 2020/852 — the EU taxonomy for environmentally sustainable activities.
- Directive (EU) 2024/1275 on the energy performance of buildings (EPBD) — transposition deadline 29 May 2026.
- Act of 16 June 2023 on quality in healthcare and patient safety (Journal of Laws 2023, item 1692) — the internal quality and safety system as the anchor point for a facility’s environmental indicators.
- Sector climate footprint data: Health Care’s Climate Footprint, Health Care Without Harm with Arup, 2019 — 4.4% of global net emissions, about 2 Gt CO₂e.
Contact
Centre matters: ghtc@healthcarepoland.pl. Coalition applications, Greenbook enquiries, audit and training requests — the same address.
Related value streams: Certification and Audit Centre · CyberC4HE Coalition · Centre for Mediation, Conciliation and Arbitration
