POLAND Trends and Developments Contributed by: Michał Mostowik, Karol Juraszczyk, Kamila Mróz and Jakub Lach, Deloitte Legal, Gizicki i Wspólnicy sp.k.
key market players assert their financial stabil - ity and preparedness for the regulatory environ - ment, ongoing discussions suggest that further consolidation within the sector is likely in the coming years. The impact of supervision by the KNF is becom - ing increasingly apparent across the industry, particularly through rising costs driven by com - pliance with new regulatory requirements. In November 2024, a representative of the KNF suggested that replacing the current registra - tion system with a licensing or quasi-licensing requirement for lending institutions in coming years is possible. However, these plans have not been officially confirmed. The implementation of the Non-Performing Loans Directive in Poland imposed additional formal requirements on lenders regarding the restructuring of borrower debt. In practice, lend - ing institutions have had to adjust or introduce debt restructuring processes, develop internal regulatory frameworks and prepare the neces - sary product documentation to comply with these new obligations. The market is also preparing for the implemen - tation of the revised Consumer Credit Directive (the “CCD2” ). In January 2025, Poland’s legisla - tive agenda included a draft Consumer Credit Act, along with amendments to consumer pro - tection laws, aimed at transposing the CCD2 into Polish law. The proposed regulations intro - duce significant changes designed to enhance consumer protection and align Polish law with EU standards. Key modifications include: • the removal of the upper credit limit; • the extension of regulatory oversight to all buy now, pay later providers (including those
who operate beyond a consumer credit regime); • stricter creditworthiness assessment require - ments; and • new rules governing the advertising of credit products. Artificial Intelligence in Financial Institutions The pursuit of maximising artificial intelligence or AI adoption in organisations is one of the most prominent trends observed not only in the fintech industry but across the entire economy. The Polish government has also announced the creation of an AI Fund, which will invest approxi - mately EUR1 billion in the digitalisation of key areas for the state. However, most businesses reasonably evaluate the opportunities and risks associated with AI, viewing technological trans - formation as a gradual evolution rather than a sudden revolution. AI is predominantly used for automating and enhancing internal, back-office processes, with its application in customer-facing processes being much less common. However, simple tools such as chatbots on websites, in banking apps and AI in phone channels are becoming increasingly popular. The use of generative AI tools on the Polish market is also quite common. However, according to Deloitte’s “Trust in Gen- erative AI” study, only 18% of respondents use generative AI for professional purposes. They do so mainly to generate ideas (45%), create or edit content (37%) and analyse data (36%). On the other hand, Deloitte’s “Trust in Genera- tive AI” study shows that the use of generative AI tools often occurs outside the organisation’s control, generating additional legal and reputa - tional risks. 56% of employees use generative AI for work purposes without the explicit approval of their employer and only 19% of respondents
672 CHAMBERS.COM
Powered by FlippingBook