This article examines whether the current Polish legal and institutional framework can accommodate the expected forms of small modular reactor deployments (SMR), including multi-site projects, industrial cogeneration, and early fleet development. It builds on earlier Polish scholarship that identified the mismatch between a framework designed primarily for large nuclear units and the emerging logic of SMR deployment but moves the analysis further by focusing on institutional interfaces, procedural sequencing and risk allocation across the full project-development pathway. It combines doctrinal analysis, institutional mapping, and process mapping, supplemented by selected legislative materials and emerging administrative practices, to identify the regulatory interfaces that are most relevant to project timing, legal certainty, and risk allocation. The article argues that Polish law already contains the basic tools needed to authorise SMR projects, but these tools were largely designed for a limited number of large, site-specific plants. As a result, the central challenge is not the absence of a legal basis for SMRs, but rather the limited degree of procedural differentiation, interoperability, and portfolio-level coordination across licensing, environmental reviews, spatial planning, construction permitting, grid and heat integration, and liability and insurance arrangements. On that basis, the article proposes targeted legislative changes aimed at preserving high nuclear-safety standards while reducing avoidable delay risk and improving the bankability of early SMR projects.
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