Banking Regulation 2025

POLAND Trends and Developments Contributed by: Marcin Olechowski, Wojciech Iwański, Tytus Brzezicki and Piotr Orłowski, Sołtysiński Kawecki & Szlęzak

and will function as a regular bank in the Polish market. Deferral of loan repayment for flood victims As a result of the flood of September 2024 in south-west Poland, substantial material losses occurred, involving damage to buildings and destruction of infrastructure, which has resulted in considerable hardship for residents and busi - nesses in the region. The banking sector, in co-operation with the Polish Bank Association and the National Asso - ciation of Co-operative Banks, has developed a special non-statutory moratorium for people affected by the disaster. This is aid that allows the deferral of loan repayment for those who suf - fered flood damage in September 2024. Formally, the flood moratorium will be subject to European Bank Authority (EBA) approval – anal - ogous as the moratorium and its subsequent updates to the COVID-19 pandemic. The rel - evant documentation has already been submit - ted to the Polish Financial Supervision Authority (PFSA) – through which the notification will be submitted to the EBA. Pending formal approval by the EBA, banks will already be individually launching assistance on the basis of the pre - pared moratorium. Borrowers who meet certain conditions can apply for deferment of repayment until 31 December 2024. The deferment can last up to three months and covers individual customers, micro-entrepreneurs, farmers and agritourism companies. The assistance also applies to other products, such as leasing and revolving loans. Loan “holidays” In 2022, the Polish Parliament implemented a special measure allowing borrowers with zloty-

denominated housing loans to postpone the repayment of up to eight monthly instalments over the next two years without any additional fees. This measure was extended to 2024, but under modified rules. Borrowers with zloty-denominated mortgages taken before 1 July 2022 were eligible to sus - pend loan repayments if the loan was used for personal housing needs. Eligibility was based on additional criteria, such as the loan amount not exceeding PLN1.2 million, the borrower’s debt- to-income ratio exceeding 30%, or having at least three dependent children. The government recently announced that there is no plan to extend the loan “holidays” to 2025. Amendments to bank tax The Minister of Finance has announced forth - coming amendments to the bank tax. Specifics have yet been released. It has been indicated that the aim of the changes is to ensure that, without diminishing state budget revenues, banks will be incentivised to more actively sup - port economic growth in Poland. Discussion on WIBOR replacement continues The replacement of WIBOR (Warsaw Interbank Offered Rate) stems from the need to modern - ise the benchmarks used in the Polish financial system. WIBOR has traditionally served as the basis for setting interest rates on loans, mort - gages and other financial instruments in Poland. However, its structure relies on data on expected transactions on interbank market and not actual transactional data. In response to these challenges, the replace - ment of WIBOR with WIRON (Warsaw Interest Rate Overnight) was considered. WIRON is based on short-term (overnight) transactions.

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