What this document is — and how it connects with the water act
In May 2026 we described the water act (Journal of Laws 2026, item 605) — the amendment that introduced mandatory PCA accreditation, a register of laboratories kept by the Chief Sanitary Inspectorate (GIS), partial reports and fines. We wrote then that the act itself is only a framework, and that the specific parameters, limits, methods and frequencies would be set by a separate implementing regulation. This is that document.
The regulation of the Minister of Health on the quality of water intended for human consumption (draft of 17 April 2026) is issued under Art. 13 of the act of 7 June 2001 on collective water supply and collective wastewater disposal. It is issued by the Minister of Health in agreement with the Minister of National Defence. The document implements two EU directives:
- Directive (EU) 2020/2184 of 16 December 2020 on the quality of water intended for human consumption (the so-called new Drinking Water Directive);
- Council Directive 2013/51/EURATOM of 22 October 2013 — requirements for the protection of health with regard to radioactive substances in water.
On its entry into force it replaces the existing regulation of 7 December 2017 (Journal of Laws 2017, item 2294). The regulation enters into force 14 days after its publication and — in line with the structure of the act — closes the transitional period in which the 2017 act applied temporarily.
You can also find the original draft at the Government Legislation Centre — together with the whole consultation path — at legislacja.gov.pl/projekt/12404055.
What exactly does the document deal with? § 1 lists eleven areas: minimum requirements (microbiological, chemical, indicator, additional chemical, radiological and relevant to risk assessment), the list of parameters with the minimum sampling frequency, methods of analysis, sampling, monitoring of Legionella in domestic hot water, deadlines for submitting reports, monitoring of radioactive substances, action in case of non-compliance and operational parameters (turbidity, somatic coliphages).
Figures worth remembering
(20 substances)
(10 µg/l until 2036)
(new parameter)
in domestic hot water
(radiological requirement)
with parameter tables
New and stricter chemical parameters
This is the most important substantive change compared with the 2017 regulation. Directive 2020/2184 brought into water testing several substances that were not previously monitored as separate parametric values, and tightened the limits for metals whose health effects we understand better today.
| Parameter | Value | Status | What it is |
|---|---|---|---|
| Sum of PFAS | 0.10 µg/l | new | The sum of 20 per- and polyfluoroalkyl acids (“forever chemicals”). Monitored when the risk assessment of the catchment area indicates a possible presence. |
| Bisphenol A | 2.5 µg/l | new | An endocrine-disrupting compound; it migrates from plastics and coatings in contact with water. |
| Microcystin-LR | 1.0 µg/l | new | A cyanobacterial toxin; determined in the event of potential blooms in the water source. |
| Haloacetic acids (HAA) | 60 µg/l | new | The sum of 5 disinfection by-products; measured when disinfection methods that generate HAA are used. |
| Chlorate | 0.25 mg/l | new | A disinfection by-product (0.70 mg/l with chlorine dioxide disinfection). |
| Uranium | 30 µg/l | new | A chemical parameter (independent of the radiological assessment in Annex 2). |
| Lead | 5 µg/l | stricter | Until 12 January 2036, 10 µg/l applies. Aim: to reduce exposure, especially of children and pregnant women. |
| Chromium | 25 µg/l | stricter | Until 12 January 2036, 50 µg/l applies. |
PFAS — why this is such a revolution
The regulation distinguishes “PFAS total” (all compounds of this group) from the “sum of PFAS” — a subset of 20 named substances (including PFOA, PFOS, PFHxA, PFBS) with a combined parametric value of 0.10 µg/l. Determining such low concentrations requires an advanced technique (LC-MS/MS), and the performance characteristics of the analysis allow a measurement uncertainty of up to 50% of the parametric value. For many laboratories this is an entirely new scope of accreditation.
Full table — chemical parameters (Part B of Annex 1)
Below is the complete set of 33 parametric values from Part B. Highlighted rows are new parameters (new) or stricter ones (stricter).
| No. | Parameter | Value | Unit |
|---|---|---|---|
| 1 | 1,2-dichloroethane | 3,0 | µg/l |
| 2 | Acrylamide | 0,10 | µg/l |
| 3 | Antimony | 10 | µg/l |
| 4 | Arsenic | 10 | µg/l |
| 5 | Nitrate | 50 | mg/l |
| 6 | Nitrite | 0,50 | mg/l |
| 7 | Benzene | 1,0 | µg/l |
| 8 | Benzo(a)pyrene | 0,010 | µg/l |
| 9 | Bisphenol A new | 2,5 | µg/l |
| 10 | Boron | 1,5 | mg/l |
| 11 | Bromate | 10 | µg/l |
| 12 | Chlorate new | 0,25 | mg/l |
| 13 | Vinyl chloride | 0,50 | µg/l |
| 14 | Chlorite | 0,25 | mg/l |
| 15 | Chromium stricter | 25 | µg/l |
| 16 | Cyanide | 50 | µg/l |
| 17 | Epichlorohydrin | 0,10 | µg/l |
| 18 | Fluoride | 1,5 | mg/l |
| 19 | Cadmium | 5,0 | µg/l |
| 20 | Haloacetic acids (HAA) new | 60 | µg/l |
| 21 | Copper | 2,0 | mg/l |
| 22 | Microcystin-LR new | 1,0 | µg/l |
| 23 | Nickel | 20 | µg/l |
| 24 | Lead stricter | 5 | µg/l |
| 25 | Pesticides (individual) | 0,10 | µg/l |
| 26 | Pesticides total | 0,50 | µg/l |
| 27 | Mercury | 1,0 | µg/l |
| 28 | Selenium | 20 | µg/l |
| 29 | Sum of PFAS new | 0,10 | µg/l |
| 30 | Tetrachloroethene and trichloroethene | 10 | µg/l |
| 31 | Trihalomethanes total | 100 | µg/l |
| 32 | Uranium new | 30 | µg/l |
| 33 | Polycyclic aromatic hydrocarbons (PAH) | 0,10 | µg/l |
Individual pesticide: 0.030 µg/l for aldrin, dieldrin, heptachlor and heptachlor epoxide. Selenium: 30 µg/l in regions with naturally high content. Boron: 2.4 mg/l for desalinated water. Values refer to the draft of 17.04.2026 and may change in the final version.
Microbiological and indicator parameters
The microbiological requirements remain strict: for water intended for consumption the key parameters must be zero.
| Parameter | Parametric value | Unit |
|---|---|---|
| Escherichia coli (E. coli) | 0 | /100 ml |
| Intestinal enterococci | 0 | /100 ml |
| Coliform bacteria (indicator) | 0 | /100 ml |
| Clostridium perfringens (including spores) | 0 | CFU/100 ml |
| Colony count at 22 °C | no abnormal change | CFU/1 ml |
For water put into bottles or containers in emergencies (floods, network failures), the unit is the number /250 ml. For water in tankers and transport tanks additional requirements apply (including Pseudomonas aeruginosa, colony count at 36 °C).
For the organoleptic and physico-chemical parameters (Part C) the following apply, among others:
| Parameter | Parametric value | Unit |
|---|---|---|
| Colour | acceptable to consumers, no abnormal change | — |
| Turbidity | acceptable to consumers, no abnormal change | — |
| Taste / Odour | acceptable to consumers, no abnormal change | — |
| Hydrogen ion concentration (pH) | 6,5–9,5 | pH units |
| Electrical conductivity | 2500 | µS/cm |
| Chloride | 250 | mg/l |
| Sulphate | 250 | mg/l |
| Sodium | 200 | mg/l |
| Ammonium | 0,50 | mg/l |
| Aluminium (Al) | 200 | µg/l |
| Manganese | 50 | µg/l |
| Iron | 200 | µg/l |
| Oxidisability (permanganate index) | 5,0 | mg/l O₂ |
| Total organic carbon (TOC) | no abnormal change | — |
Part D adds requirements for disinfection by-products (including free chlorine 0.3 mg/l, chloramines 0.5 mg/l, ozone 0.05 mg/l, bromodichloromethane 15 µg/l, chloroform 30 µg/l) and parameters: magnesium 7–125 mg/l, silver 0.010 mg/l, hardness (Ca+Mg) 60–500 mg/l.
Legionella and domestic distribution systems
Part E of Annex 1 and Annex 5 are a novelty that most strongly affects priority premises — hospitals, hotels, care homes and other buildings in which water aerosol is generated. Legionella becomes a risk assessment parameter in domestic hot water systems, with a parametric value of <1000 CFU/l — and in premises with immunocompromised patients (immunosuppressive treatment, palliative wards, hospices) the threshold is ten times stricter: <50 CFU/l. For lead in these systems a value of 10 µg/l has been set, with the aim of 5 µg/l by 2036.
Annex 5 links the level of contamination found to a specific mode of remedial action and the frequency of further tests:
| Legionella count | Level | Action | Next test |
|---|---|---|---|
| <1000 /l | Low | Confirm that the control measures (disinfectant concentration, water temperature) are within limits; correct if necessary. | after 1 year, then twice a year |
| ≥1000 – <10000 /l | Medium | Technical review of the installation and operational targets; if it recurs — cleaning and disinfection, preventing stagnation. | ≤4 weeks after sampling |
| ≥10000 – <100000 /l | High | Shut down showers and aerosol-generating devices; control measures together with cleaning and disinfection. | 1 week after disinfection |
| ≥100000 /l | Very high | Proceed as above, immediately. | 1 week after disinfection |
In premises with immunocompromised patients the thresholds are ten times lower (<50, ≥50–<100, ≥100–<1000, ≥1000 /l).
Measuring the temperature at the sampling point is an integral part of every sampling. Annex 5 recommends that the domestic hot water temperature be at least 55 °C at every tap and no less than 60 °C at the heater outlet. In facilities for children and people with disabilities, where thermostatic valves limiting the temperature are used (43 °C for taps, 38 °C for showers), the water supplying these valves must be at least 55 °C.
Radioactive substances
Annex 2 implements Directive 2013/51/EURATOM. It introduces radiological requirements and two-stage monitoring: initial (a first measurement at all intakes — radon, the radium isotopes Ra-226 and Ra-228, and tritium) and check monitoring (for water treated to reduce radioactivity).
| Parameter | Parametric value | Unit |
|---|---|---|
| Radon | 100 | Bq/l |
| Tritium | 100 | Bq/l |
| Indicative dose | 0,10 | mSv/year |
Derived concentrations have been set for natural and artificial isotopes (including Ra-226 0.5 Bq/l, Ra-228 0.2 Bq/l, U-238 3.0 Bq/l, Cs-137 11 Bq/l). The procedure depends on the radon concentration: ≤10 Bq/l — testing once every 10 years; >100 ≤1000 Bq/l — exposure assessment and possible remedial action. The detection limits of the method are set out in Annex 6 (e.g. tritium and radon 10 Bq/l).
Test methods, measurement uncertainty and frequencies
From the point of view of an accredited laboratory, Annexes 3 and 4 are as important as the parametric values themselves — they decide how and how often testing must be done.
Reference methods (Annex 4)
| Microbiological parameter | Reference standard |
|---|---|
| E. coli and coliform bacteria | PN-EN ISO 9308-1 / 9308-2 |
| Intestinal enterococci | PN-EN ISO 7899-2 |
| Colony count at 22 °C / 36 °C | PN-EN ISO 6222 |
| Clostridium perfringens (including spores) | PN-EN ISO 14189 |
| Legionella | PN-EN ISO 11731 |
| Pseudomonas aeruginosa | PN-EN ISO 16266 |
| Somatic coliphages | PN-EN ISO 10705-2 / 10705-3 |
For risk-based monitoring, alternative and molecular methods are allowed (including ISO/TS 12869, qPCR), and for enterococci the Enterolert-DW method is accepted as equivalent to PN-EN ISO 7899-2.
Measurement uncertainty and limit of quantification
For chemical parameters, the method must be able to measure concentrations with a limit of quantification of 30% or less of the relevant parametric value. Annex 4 gives the permissible measurement uncertainty (as a % of the parametric value) for each parameter — for example:
| Parameter | Measurement uncertainty | Parameter | Measurement uncertainty |
|---|---|---|---|
| Arsenic | 30% | Lead | 30% |
| Chromium | 30% | Uranium | 30% |
| Microcystin-LR | 30% | Nitrate | 15% |
| Sum of PFAS | 50% | Bisphenol A | 50% |
| Benzo(a)pyrene | 50% | pH | 0.2 pH units |
Sampling frequency (Annex 3)
The parameters are divided into group A (basic: E. coli, enterococci, coliform bacteria, colony count at 22 °C, colour, turbidity, taste, odour, pH, conductivity) and group B (all the others). The minimum number of samples grows with the volume of water in the supply zone:
| Volume of water [m³/day] | Group A (samples/year) | Group B (samples/year) |
|---|---|---|
| < 10 | > 0 | > 0 |
| ≥ 10 – ≤ 100 | 2 | 1 |
| > 100 – ≤ 1000 | 4 | 1 |
| > 1000 – ≤ 10000 | 4 + 3 for each 1000 m³/d | 1 + 1 for each 4500 m³/d |
| > 10000 – ≤ 100000 | as above | 3 + 1 for each 10000 m³/d |
| > 100000 | as above | 12 + 1 for each 25000 m³/d |
Instead of the volume, the number of inhabitants can be used (200 l/day per person). E. coli and intestinal enterococci are “core parameters” — their frequency cannot be reduced as a result of the risk assessment. Operational parameters (Annex 7): turbidity 0.3 NTU in 95% of samples (none >1 NTU), somatic coliphages 50 pfu/100 ml in raw water.
The watch list and the risk-based approach
The regulation introduces the watch list mechanism — substances and compounds for which guideline values are set, monitored in raw water. If the guideline values are exceeded in raw water (with no exceedances in treated water), the sanitary inspector agrees with the water supplier the frequency of testing and the treatment arrangements. This is part of the broader EU risk-based approach: from the catchment area of the intake, through the supply system, to the domestic installations in buildings.
What this means for the laboratory and the LIMS
For a water testing laboratory, the new regulation is not cosmetic — it changes the scope of accreditation, the method dictionaries and the scheduling logic. In practice, several things have to be addressed at once:
- New parameters in the testing scope — the sum of PFAS, bisphenol A, microcystin-LR, HAA, chlorate and uranium require new methods to be implemented (and often accredited) and the dictionary of determinations to be updated.
- Limit of quantification and measurement uncertainty — every chemical result must be reported with an appropriate limit of quantification (≤30% of the parametric value) and an assigned uncertainty; the system should validate this automatically.
- Schedules based on volume/population — the split into groups A and B and the frequency formulas are crying out for automatic sample planning instead of a spreadsheet.
- The Legionella path — linking the result to the contamination level, the mode of action and the retest date is a ready-made workflow scenario in a laboratory system.
- Test reports in line with the act — the register entry number, the limit of quantification/detection and the sampler’s details must go into the test report automatically, and a partial report must be created immediately when non-compliance is found.
How we approach this at CleverLAB
We are following the legislative path of this regulation from the consultation stage and progressively mapping its requirements in the system: up-to-date dictionaries of parameters and PN-EN ISO reference methods, validation of limits of quantification and measurement uncertainty, sample schedules by groups A/B and action scenarios for Legionella. We keep our finger on the pulse so that laboratories using CleverLAB enter the new requirements with ready configurations rather than a last-minute migration. When the draft becomes a binding act, we will update this article with the Journal of Laws number and the final values.
Timeline — what and when
Ready for the new parametric values?
We will show how to map the new parameters, PN-EN ISO methods, measurement uncertainty and the Legionella path in a laboratory system — based on your current scope of accreditation and workflow.
Related articles
Water act 2026 — the laboratory’s obligations
PCA accreditation, the GIS register, partial reports and fines — the act that this regulation implements.
LIMS compliance with ISO/IEC 17025
The foundation of PCA accreditation for water testing — methods, validation, measurement uncertainty.
Electronic signatures in the laboratory
How the authorisation of electronic test reports sent to the sanitary inspectorate works.
Legal basis and sources
- Draft regulation of the Minister of Health on the quality of water intended for human consumption (draft of 17 April 2026, no. MZ 1841) — legislacja.gov.pl/projekt/12404055. Download the full text of the draft (PDF, in Polish).
- Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the quality of water intended for human consumption — EUR-Lex.
- Council Directive 2013/51/EURATOM of 22 October 2013 (radioactive substances in water) — EUR-Lex.
- Regulation of the Minister of Health of 7 December 2017 on the quality of water intended for human consumption (the act being replaced) — Journal of Laws 2017, item 2294.
- Act of 13 March 2026 amending the act on collective water supply and collective wastewater disposal and certain other acts — Journal of Laws 2026, item 605.
- Chamber of Commerce “Polish Waterworks” — consultation of the draft regulation: igwp.org.pl.
About this article
The article is based on the full text of the draft regulation of 17 April 2026 (MZ 1841) and materials on Directive (EU) 2020/2184. Since we are discussing a draft, the final parametric values, deadlines and annex numbering may change — we will update the article after publication in the Journal of Laws.
The CleverLAB team develops LIMS software for laboratories accredited to PN-EN ISO/IEC 17025. Our clients include water, wastewater and microbiology laboratories, physico-chemical laboratories and technical cleanliness laboratories.