The number one change awaiting bank customers in 2026 will certainly be the new Consumer Credit Act. New innovations in transfers and protection of payers against fraud are also fast approaching.
As every year, we present the “regulatory timetable” for the coming year in Bankier.pl. Sometimes we observed periods of accumulation of changes, and sometimes periods of relative calm. The coming year is somewhere between these extremes. There will be few legal revolutions, but they will affect the foundations of the market, this time lending for consumption.
Some loans may disappear from the market
The project was published in mid-2025 new act on consumer credit. The act is intended to implement the provisions of the second version of the EU directive (CCD2, Consumer Credit Directive) into Polish law, and the Office of Competition and Consumer Protection is responsible for the implementation. The result is a lot of pro-consumer novelties, often going beyond the minimum imposed by the European directive.
From the point of view of customer-borrowers, the new law will change a lot, mainly in three areas:
- It will eliminate certain types of ads and products.
- It will change the principles of operation of free loan sanctions.
- It will tighten the rules for checking creditworthiness, especially for non-bank loans.
Firstly, any advertisement for consumer credit will also have to include the warning 'Borrowing money costs money'. In the Act several prohibitions are provided forwhich will probably eliminate some of the products known to consumers today from the market, including:
- “Loans without BIK”, i.e. suggesting that other liabilities, including those recorded in databases, do not affect access to financing.
- “Immediate loans”, i.e. emphasizing the ease and speed of obtaining a loan.
- “You do not pay the first installment”, i.e. granting a discount depending on taking out a consumer loan.
- “30 installments 0% and the first payment in half a year”, i.e. deferment of the installment repayment date for a period longer than 3 months.
Secondly, the sanction of the free loan will be graduated. Penalties apply for the most serious offenses (such as financing without the consumer's explicit consent). “gifting” a loani.e. there is no need to return both the amount and costs. Refund without interest and fees however, it may trigger, for example, a breach of obligations related to creditworthiness testing. Semi-free credit
can be obtained if the lender violates some of the information obligations, e.g. does not indicate under what conditions and how the contract can be terminated.
Thirdly, the threshold at which simplified creditworthiness testing is possible is to be lowered. For non-bank lenders, it was twice the minimum wage in the economy. Proposed in the project the new limit is one time of this indicator (as of today – PLN 4,666). Up to this limit, the client will only be able to submit a declaration of his or her household's income and expenses.
There are many smaller, noteworthy novelties in the draft act. One of them is the “opening” of loan repayment insurance on a similar basis to real estate insurance in mortgage loans. This means that if the lender requires loan repayment insurance as security, we will be able to provide the appropriate insurance from the market ourselves, provided that it meets the limit conditions.
It is worth emphasizing that the act has not yet taken its final form. The project aroused a lot of controversy, as evidenced by the list of comments submitted during the consultations. The new rules are to come into force November 20, 2026
Financial e-commerce will have new rules
The described project by the Office of Competition and Consumer Protection implements into Polish law not only the CCD2 directive, but also the EU act on distance selling. It provides for several new requirements in all scenarios where a consumer purchases financial services remotely.
Firstly, it is expected to appear on websites and applications clearly marked “withdraw from the contract here” function. The customer will not have to look for hidden buttons or links. Saying goodbye to the service provider should be as easy as concluding a contract.
Secondly, we will gain the right to contact a living personwhen the service provider relies on automatic “explanation” systems (e.g. chatbot). A number of misleading tricks have also been banned, including repeatedly submitting previously rejected options.
We wrote more about changes in remote service in this article. The new law is about to come into force June 19, 2026
Instant transfers in euro must go to banks
In December, a government bill was submitted to the Sejm amending certain acts related to the functioning of the financial market and the protection of market participants. This is a package that includes several elements resulting from the need to implement EU regulations. One of them is a set of regulations necessary to launch the IPR (Instant Payments Regulation) in Poland.
Instant transfers in euro they will have to become a mandatory element of the offer payment service providers. Such orders should be available 24 hours a day, seven days a week, regardless of the selected channel. The fee for such a service cannot be higher than the cost of a regular transfer. Money sent by the sender must reach the recipient's account within maximum 10 seconds.
It will also be mandatory to use the Verification of Payee (VoP) process. If the data provided by the person ordering the transfer is not consistent with the data available to the recipient's payment service provider, the payer should receive a warning that he may become a victim of fraud.
The deadlines applicable to institutions in Poland are 2027, but at least several implementations can be expected next year. Down January 9, 2027 banks in Poland must be ready to accept immediate Euro transfers. It's also a deadline Equalization of fees for cross-border ordinary and instant transfers in euro.
Down April 9, 2027 Polish payment institutions and electronic money institutions are also to be ready. Until July 9, 2027 banks in Poland must be able to send instant euro payments and use the payee verification service.
The same project also introduces changes in Poland regarding access of non-bank entities to payment systems and protection of funds of customers of payment institutions. We wrote in more detail about the importance of this change in Bankier.pl in April 2025.
Delay counted in years – cryptoassets and online currency exchange offices
At the end of 2024 (!), the time has passed to introduce into Polish law the solutions necessary for the functioning of the EU MiCA regulation regarding the digital assets market. Meanwhile, the fate of the project became so complicated that we witnessed a “regulatory series”. After the presidential veto, the act is now in the upper house of parliament in almost unchanged form.
The project affects not only cryptoassets, but also entities conducting cashless currency exchange (in other words – online currency exchange offices). If changes to the law come into force in their current form, online currency exchange offices will have to obtain payment institution licenses. Cashless currency exchange will only be made via payment accounts. This, in turn, means that customers' money will benefit from a specific legal protection mechanism (we presented it in this article).
PSD3 is taking shape on the horizon
The EU Payment Services Directive has already brought about a market revolution twice. In the first version of the PSD, the banks' monopoly on providing some payment-related services collapsed. In the second one, it was sanctioned, among others: open banking and strong authentication requirement in several scenarios.
In 2025, the next version took more shape. This time it will be a package. The directive (PSD3) focuses on more strategic issues (e.g. licensing), while more practical and detailed issues are included in the PSR (Payment Services Regulation). This will be an act directly applicable in EU countries, not requiring implementation into the national legal order.
Among the new solutions proposed in PSR, the most important for customers will be:
Finalization of work on the PSR regulation is expected in 2026. and in the second half of the year, some of the new regulations could come into force.
