Energy is crucial to economic development, but its production usually has a negative impact on the environment. This ambivalence leads to the need for methods to improve energy efficiency. Transportation is one of the largest global energy consumers. Therefore, improving the energy efficiency of transportation is crucial for sustainable development. The aim of this article is to show the limitations of energy management in railways, resulting from the model of market regulation. The question in this context is whether only technological methods can be used in railways to steer its energy efficiency, as is suggested by the existing research. Critical analysis, desk research and a case study of Polish railway undertaking were used to find an answer to the research question. The discussion of the results shows that the European regulatory system leads to greater complications in the field of energy management than in other global regions, where railways are also important for the economy. Due to these limitations, rail operators use indirect methods to measure energy efficiency. Results indicate that although energy efficiency improvements are being achieved, they are mainly due to organizational measures and not technological ones as could be expected based on previous research.