2025 in the banking sector: legal and tax changes, and strategic challenges

22 December 2025 | Knowledge, News, The Right Focus

The Polish banking sector underwent profound reforms and new regulatory obligations in 2025. Despite achieving record financial results, banks were faced with mounting tax pressures and changes in benchmarks, as well as the implementation of EU regulations concerning operational security, anti-money laundering, digital payments, the use of artificial intelligence, environmental issues, ESG reporting and green transformation. Against this backdrop, we also observed market consolidation, partly driven by growing competition from new banks. In this article, we explore how these factors have transformed the Polish financial institution market.

CIT and new fiscal burdens

The most significant changes were those to CIT. The legislature decided to increase the rate for financial institutions, which is expected to increase budget revenues in the short term, but at the same time raises concerns about limiting banks’ ability to finance the economy. From a legal perspective, this change requires not only an adjustment of tax policy, but also an analysis of its impact on long-term credit agreements and capital structures.

POLSTR instead of WIBOR

Meanwhile, the reform of benchmarks is progressing, with the POLSTR index set to replace WIBOR. This new benchmark, which is based on overnight transactions, is intended to increase market transparency and resilience to abuse. Although full implementation will not take place for several years, banks are already preparing to convert agreements and update credit documentation. This requires precise inclusion of the new mechanisms in their regulations and agreements.

New EU regulations – DORA, AML, PSD3, AI Act and CSRD

The DORA regulation, which introduces stringent requirements for operational resilience and cybersecurity, has been in force since January. At the same time, the implementation of the 6th Anti-Money Laundering Directive and the launch of the European AMLA supervision are underway, meaning an extension of customer verification and transaction monitoring obligations.

In the payments sector, preparations for PSD3 and the PSR are paving the way for robust authentication measures and a new supervisory regime. Meanwhile, capital requirements under CRD VI and CRR III are tightening the risk management framework. Other notable developments include the AI Act, which governs the use of algorithms in banking processes, and the CSRD, which requires companies to report on ESG and incorporate sustainability principles into their credit policies.

Banks as catalysts for the green transition

Financial institutions are becoming real catalysts for climate transformation. They design financing structures for renewable energy, energy efficiency and low-carbon transport, arrange green bond issues, offer ESG-linked loans and provide consultancy on sustainable development. They are also increasingly combining commercial financing with guarantees and aid instruments to reduce the cost of capital and increase the availability of funds for projects of high environmental importance.

Market consolidation and new players

In 2025, several interesting market phenomena emerged.

VeloBank obtained approval to acquire Citi Handlowy’s retail business, which covers individual clients and micro-enterprises.

Meanwhile, Erste Group announced the acquisition of a significant stake in Santander Bank Polska, thereby strengthening its presence in Central and Eastern Europe.

Furthermore, the Industrial Bank of Korea – the first Korean bank to be present in Poland – began operating in Warsaw to support SME financing and the development of trade relations with the Asian market.

Financing strategic projects

Banks are involved in financing the modernisation of the defence sector and the nuclear energy programme. This requires complex legal and financial structures, state guarantees, and compliance with EU state aid regulations.

In practice, this means creating structures based on CfD mechanisms, involving export credit agencies and integrating commercial financing with public instruments.

The year 2025 saw significant legal, tax and market changes for the banking sector. The implementation of new regulations (DORA, AMLA, PSD3, the AI Act and the CSRD), the growing importance of ESG, market consolidation, the emergence of new players and the financing of strategic projects all require institutions to adapt their procedures as well as engage in strategic planning and seek legal support. The coming years will also be crucial for aligning the activities of banks with the rapidly changing regulatory and economic landscape. We will be watching this with genuine interest.

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