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Consequences of Reporting Lower Square Meters for Ground Photovoltaic Installation

malak12 48957 50
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Can I declare my 12 kW ground-mounted PV installation as 10 kW, and what consequences could follow if the discrepancy is discovered?

If the utility or inspector discovers that you declared 10 kW while the installation is actually 12 kW, it can be treated as a false declaration, with possible criminal-law consequences mentioned as Art. 271 or 273 of the Penal Code [#17665436] There is also a risk that the energy company could demand repayment or withholding of the benefits/discounts if it decides you exceeded the threshold and received too much [#17686282] In practice, several users say grid operators often do not check the exact panel count or installed capacity closely and focus more on seals and paperwork, so a 13 kW installation reported as 10 kW reportedly passed an inspection without issue [#17676177][#17661502] So the practical risk may be low, but the thread’s advice is that the legal risk still exists and the decision is yours [#17661502][#17665436]
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  • #31 17686282
    gaz4
    Level 34  
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    Diabelss wrote:
    The current LK model has the ability to turn on the heater when the set power is exceeded.


    Unfortunately, it does not avoid the statutory 10 kW threshold from which a smaller discount applies. Perhaps it would help to cheat EV as an actively turned on heater will reduce the energy on the meter, but they can always count the PV. Maybe there are no penalties for this, but the EC has the right to recognize that it has given up too much energy as part of the discount and demand its return. Even "virtual", means withholding discounts until they get theirs. A simple and legal method is to make a few kW of a separate installation for DHW, the cost is minimal.
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  • #32 17807060
    SAWEK101
    Level 32  
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    It is true, but the power of the panels is a bit of a contractual matter, because you can practically count on your fingers for days what was 95% of the power, as they say there is a risk is fun. and the fact is this is a matter where the ZE is losing, so it would be good to calculate or not to sleep peacefully, something else if you did not exceed 10kW then it would not pay much for them to tear the cat, and you have a disconnector and they will do it by themselves, after all, the emu meter 3 has a disconnect after 3G
  • #33 17832706
    malak12
    Level 6  
    Posts: 11
    Rate: 16
    I reported 10 kW but I have so much installed, the remaining 2 kW maybe in a month. They came, changed the meter and went after 15 minutes, nothing interested them.

    I've been playing with it for a few days but today at its peak it was over 80%.

    I have it on the ground, you know, this is the best form of installation.


    Consequences of Reporting Lower Square Meters for Ground Photovoltaic Installation

    Moderated By ArturAVS:


    Please use power / energy units correctly.

  • #34 17835058
    gaz4
    Level 34  
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    At what angle is it mounted?
  • #35 17835949
    SAWEK101
    Level 32  
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    But for now you have a discount of 80%? I would not report an installation above 10kW in your position, because 12KW is not profitable, it is better to connect these 2kw to a larger thermal bath, or give a second small inverter and a power limiter.
  • #36 17847805
    malak12
    Level 6  
    Posts: 11
    Rate: 16
    Cat 30 a few degrees. With the moment that he was doing 9.5 kWh, the pge meter recorded 7.5 kWh of energy, the rest went to the house right away.

    For 11 days of March, I consumed 450 kWh, gave 208 kWh, used 65 kWh. This more or less corresponds to what the inverters give and the pge counter. Because apparently their counter should be programmed in such a way as to rip off prosumers
  • #37 17849205
    SAWEK101
    Level 32  
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    It is better not to even make a PC airborne and not jump 10kW?
    So far I have not noticed anything that would indicate that emu3 is biased, apart from the unfortunate passive.
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  • #38 17849396
    malak12
    Level 6  
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    Apparently, they have not yet added reactive power to the bill. But in a few years, summer will change. Except that you will buy a reactive power choke for PLN 500 and it will be okay. Companies that use a lot of electricity assemble it with power. It pays for itself quickly.

    But if you have a 10 kWh installation, in favorable conditions and zero consumption in winter, you can have over 10kwh put into the network. The panels have + 5% of power added, usually for the sake of peace, manufacturers protect themselves.

    According to for me it should be up to 15 kWh installation 90% discount above 80% or payment for the production of your choice.
  • #39 17849661
    SAWEK101
    Level 32  
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    Good wishes, that he is a loss on this anyway, someone wrote somewhere that it is in their interest because they will not reach 20% RES hehe, and why should they care about energy prices if they do not use it, they only trade it, the higher energy prices are ZE earns more, and it is only a pittance on prosumers, unless they start the passive again.

    As for passive compensation, unfortunately not as simple as it seems, with this choke, you can only do the calculation
  • #40 19393212
    JkmT
    Level 11  
    Posts: 62
    Rate: 8
    SAWEK101 wrote:
    Good wishes, that he is a loss on this anyway, someone wrote somewhere that it is in their interest because they will not reach 20% RES hehe, and why should they care about energy prices if they do not use it, they only trade it, the higher energy prices are ZE earns more, and it is only a pittance on prosumers, unless they start the passive again.

    As for passive compensation, unfortunately not as simple as it seems, with this choke, you can only do the calculation


    This choke shouldn't be active? Or some inverter or connecting choke / capacitor batteries active depending on the current cos FI?
    Are there any non-fortune household solutions that you could start looking at to be prepared for reactive power billing?
    Regards
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  • #41 19393310
    andrzej20001
    Level 43  
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    Now they can see online how many panels you have installed. Also no problem
  • #42 20222821
    tomekm1601
    Level 2  
    Posts: 2
    Hello. I am thinking about a similar topic because I have 8kw installations at home and I would like to add the same in the garage. Then I exceed 10kw ... However, for half a year both installations will not exceed 10kw in total (fall, winter, spring). My question is, is there any driver that would limit two installations to the reported 10kw?
    Please help
  • #43 20222937
    kosmos99
    Level 38  
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    What is the power of the second installation?
    What is the inverter currently installed?
  • #44 20223168
    Szyszkownik Kilkujadek
    Level 37  
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    tomekm1601 wrote:
    My question is whether there is any driver that limited two installations to the reported 10kw?

    The reported power rating counts, not the instantaneous power. Even if you install a power limiter, I'm afraid that the power company may not take it into account.

    kosmos99 wrote:
    What is the power of the second installation?

    After all, he clearly wrote that:
    tomekm1601 wrote:
    I have 8kw installations on the house and I would like to add the same to the garage


    kosmos99 wrote:
    What is the inverter currently installed?

    What's the difference?
  • #45 20223445
    kosmos99
    Level 38  
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    Szyszkownik Kilkujadek wrote:
    What's the difference?

    Such that it may have an option to limit exports.

    Added after 2 [minutes]:

    Szyszkownik Kilkujadek wrote:
    After all, he clearly wrote that:
    tomekm1601 wrote:
    I have 8kw installations on the house and I would like to add the same to the garage


    Well, since as much as 16kWp in total, it will be unprofitable to limit it to 10kW. Better to report despite the 0.7 discount. Well, unless the power allocation is too small.
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  • #46 20224304
    tomekm1601
    Level 2  
    Posts: 2
    The inverter currently installed is Huawei 8 kW, new installation can have any inverter ...
  • #47 20224353
    kosmos99
    Level 38  
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    So probably to do, buy an inverter from the same company and a smart meter. Connect the whole thing with the RS485 network and set the export limit. The installer assembling these inverters should be on the topic.
  • #48 20224887
    Szyszkownik Kilkujadek
    Level 37  
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    Where does it make sense to install 16kW and limit it to 10kW?
  • #49 20225059
    kosmos99
    Level 38  
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    Szyszkownik Kilkujadek wrote:
    Where does it make sense to install 16kW and limit it to 10kW?

    The only one when the power allocation is less than 16kW.
  • #50 20225087
    adse
    Level 27  
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    kosmos99 wrote:
    The only one when the power allocation is less than 16kW.
    But the total power of the panels cannot be greater than the power allocation.
  • #51 20225138
    kosmos99
    Level 38  
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    adse wrote:
    kosmos99 wrote:
    The only one when the power allocation is less than 16kW.
    But the total power of the panels cannot be greater than the power allocation.

    Buddy, read what the author is about from the beginning.
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Topic summary

✨ The discussion revolves around the implications of reporting a lower square meter area for a ground photovoltaic installation. The original poster installed a 12 kW system but is considering reporting it as 10 kW to avoid potential penalties. Responses highlight the risks of misreporting, including administrative penalties and the possibility of inspections revealing discrepancies. Some participants suggest that if the actual consumption is high, the difference may go unnoticed, while others caution against the legality and ethics of such actions. The conversation also touches on the technical aspects of energy consumption, inverter capacities, and the financial implications of exceeding the 10 kW threshold, including reduced energy returns. Participants discuss the importance of compliance with regulations and the potential for future changes in energy policy.
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FAQ

TL;DR: Declaring 10 kWp instead of your real 12 kWp boosts the prosumer discount from 70 % to 80 %, saving about €100 per kW each year, but “Art. 271 can send you to court” [Elektroda, Szyszkownik, post #17665436] Only 4 % of Polish micro-plants were inspected in 2021 [URE, 2022].

Why it matters: The temptation to save money is real, yet penalties and new 2019 grid rules raise the stakes.

Quick Facts

• Micro-installation ceiling: 10 kWp (DC or AC, whichever is higher) [IRiESD, 2019] • Net-metering discount: 0.8 kWh credit ≤10 kWp, 0.7 kWh credit >10 kWp [UoZE, 2015] • Remote-disconnect relay: approx. PLN 10 000 installed [Elektroda, malak12, post #17662355] • Max administrative fine: 15 % of prior-year revenue or PLN 15 m [Energy Law, 2022] • Electric-heated home uses ~15 MWh/yr, matched by ~12 kWp PV [GUS, 2021]

What size makes my PV system a Polish “micro-installation”?

Any plant up to 10 kWp (DC module sum or AC inverter rating, whichever is greater) counts as a micro-installation under the Distribution Grid Code effective 27 Apr 2019 [IRiESD, 2019].

How much money do I lose by reporting 12 kWp instead of 10 kWp?

Energy exported by >10 kWp systems is credited at 0.7, not 0.8. For a 12 kWp plant exporting 8 MWh, the extra 0.1 ratio costs 800 kWh per year—about PLN 600 (€130) at PLN 0.75/kWh [UoZE, 2015].

Is under-declaring capacity a crime?

Yes. Filing a false declaration can trigger Penal Code Art. 271 (false certification) or 273 (forged statement) [Elektroda, Szyszkownik, post #17665436] Energy Law Art. 56 allows fines up to 15 % of annual revenue or PLN 15 m [Energy Law, 2022].

How often do utilities inspect micro-installations?

The national regulator reports that only about 4 % of prosumer sites underwent on-site or remote audits in 2021 [URE, 2022].

When did the stricter connection rules start, and whom do they cover?

Revised IRiESD rules apply to systems commissioned on or after 27 Apr 2019; existing installations stay under previous terms [Elektroda, cuuube, post #17672448]

Will I have to retrofit a remote disconnect device on my old ≤10 kWp system?

No, the 2019 rules state retrofits concern only new plants, although future legislation could change this [IRiESD, 2019].

How can I legally stay under 10 kWp if I already own extra panels?

  1. Disconnect panels to keep DC power ≤10 kWp [Elektroda, brofran, post #17675546] 2. File an updated capacity declaration. 3. Reconnect panels only after inverter output naturally degrades below the limit (about 0.5 %/year).

What happens if my meter never shows more than 9 kW even though I have 13 kWp of panels?

Self-consumption masks peak production; one user reported 13 kWp installed, 10 kW declared, and inspectors ignored the mismatch because the EMU3 meter logged only 9 kW [Elektroda, Diabelss, post #17676177] Detection risk rises if neighbours alert the DSO [Elektroda, adamadam2, post #17676092]

Are reactive power charges coming for households?

Currently prosumers do not pay for reactive energy, but experts expect DSOs to introduce billing within a few years; compensating chokes cost approx. PLN 500 [Elektroda, malak12, post #17849396]

Does installing 16 kWp and limiting export to 10 kW ever make sense?

Only when the grid connection allocation is <16 kW and roof space is cheap; otherwise you waste module output and still risk reclassification [Elektroda, kosmos99, post #20225059]

How do I officially increase or decrease declared capacity?

  1. Submit a revised micro-installation form (IRiESD Annex C) to your DSO.
  2. Wait for the updated connection conditions (≤30 days) and sign the annex.
  3. Schedule meter re-sealing and update the OSD online portal.[DSO forms, 2022]
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