In 2025, the Polish financial market entered another phase of adjustments to EU legislation. The draft new Consumer Credit Act implementing the CCD2 Directive, alongside the regulations on distance financial services, represents one of the most comprehensive attempts to standardise the rules for providing finance to consumers. The changes are so extensive that they cover all stages, from advertising and customer acquisition to the assessment of creditworthiness, the structure of agreements, the scope of the lender’s liability, withdrawal rules and the detailed organisation of remote sales.
The Consumer Credit Act. Does the Polish market need such extensive regulation?
The draft, which emerged in mid-2025, sparked a lively debate from the outset, partly because the legislature opted to go beyond the minimum scope of the directives and introduce additional requirements.
The intention was to enhance consumer protection and prevent abuse. However, the banking sector and the Polish Bank Association argue that such a broad approach will require virtually every stage of the credit process to be adjusted.
One of the key elements of the reform is the regulation of advertising rules for loans and credit.
The new act introduces clear restrictions on messages that suggest financing is easily accessible, quick or seemingly inexpensive. The regulations provide for the removal of certain forms of communication, including those that have already become commonplace in marketing and are a permanent feature of the short-term loan market. This means that slogans associated with offers claiming ‘no verification’, ‘no formalities’ or ‘deferred first instalment’ may disappear completely. Instead, each advertisement will have to include a clear message about the cost of borrowing.
From the banks’ perspective, this change will significantly alter the way products are communicated. At the same time, it is an attempt to bring order to a market that, until now, has been characterised by a wide variety of forms and standards of communication.
Changes to the free credit sanction
A much greater transformation concerns the sanction of free credit. Under the current legal framework, this sanction is applied automatically, regardless of the scale of the breach. The new draft introduces a graduated scale, meaning that the consequences will vary depending on the type and severity of the violation. The most severe consequences will apply in cases where credit was extended without the consumer’s explicit consent. Milder forms of sanctions are envisaged in cases involving procedural and documentation issues. According to the draft’s authors, this structure is intended to provide greater transparency and proportionality in response to long-standing demands from the banking sector. However, banks also point out that the scale of the changes requires not only a restructuring of procedures, but also a new operational compliance monitoring system.
Assessing customer creditworthiness
The rules for assessing creditworthiness are to be significantly revised.
The central element of the operational part of the act is a change to the threshold below which a simplified assessment of the customer’s financial situation will be permitted.
With the threshold being lowered to the minimum wage, in practice, full verification will be necessary in most cases.
The legislature argues that this will minimise the risk of over-indebtedness. However, financial institutions point out that the new rules may lengthen the credit process and require a reorganisation of risk models.
This change is particularly significant for non-bank entities that have based their operations on simplified verification mechanisms. While creditworthiness assessment forms the basis of responsible lending, introducing uniform, more detailed procedures for a wide range of debts may, in practice, slow down the operations of these entities and affect their ability to compete in terms of decision-making time.
Loan instalment insurance
Another area of change is extending consumer rights with regard to loan repayment insurance.
In accordance with the draft, customers will be able to choose their own policy, provided it meets the minimum conditions specified in the act.
On the one hand, this means greater flexibility and transparency for consumers; on the other, it makes the market more open to competitive insurance products. According to the banking sector, this change requires new procedures to be created for verifying the quality of policies, as well as systems to be adapted to handle different document formats and standards.
Changes in mobile banking
The most extensive changes will be seen in the area of remote financial services. The new law requires institutions to provide consumers with a clearly visible tool for withdrawing from an agreement. Additionally, consumers must be guaranteed the ability to contact a staff member when using automated systems. These solutions are intended to increase security when concluding online agreements, which is an expected development from the market’s perspective. However, banks point out that such extensive technical requirements will necessitate thorough modernisation of IT systems and service processes, resulting in high costs and the need for precise operational risk management.
The scope of the act has been expanded to include new types of agreements that were not previously regulated.
The act will cover credit products of all values, including leasing products, leases and overdraft facilities. This broad approach means that the information and procedural obligations set out in the act will apply to products with different structures, risk scales and types of customer relations. The banking sector has pointed out that the lack of differentiation in the regulations according to product type may cause practical complications and require greater flexibility in interpretation.
Time of implementation of the changes
The legislature assumes that the new regulations will come into force on 20 November 2026. From the institutions’ perspective, this will require complex processes, procedures, tools and decision-making models to be adjusted in just a few months. The sector points out that, given the scope of the changes – from advertising and risk assessment to online service processes – it may be extremely difficult to implement the schedule without disrupting operations.
Summary
The new Consumer Credit Act introduces significant and far-reaching changes aimed at improving market transparency and increasing consumer protection. From the perspective of banks, however, it constitutes a set of regulations that require caution and precise adjustment, as well as time for implementation, in order to strike a balance between consumer safety and the stability and predictability of financial institutions.
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