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Bank Gospodarstwa Krajowego

BGK

Bank Gospodarstwa Krajowego is a Polish development bank – the only institution of this type in Poland.

Lobbying Activity

Meeting with Herald Ruijters (Deputy Director-General Defence Industry and Space)

28 Nov 2025 · BGK role in financing defence expenses

Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

30 Jul 2025

Affordable housing in Poland needs a prompt revision of state aid rules due to the fact that currently state support is desperately needed to provide tenants with affordable rent. Considering factors such as high interest rates and construction cost there is absolutely no way to keep rent levels at bay while staying reasonably close to market conditions. Moreover, it has to be taken into account that in the area of social/municipal housing state aid plays no part whatsoever since municipalities are a part of the public sector and thus, are not subject to state aid regulations. Unless state aid rules are significantly altered in affordable housing, the gap between that sector and social housing will broaden, creating a disjointed rental housing market segmentation. The SGEI framework that currently operates in affordable housing was conceived to ensure that help is targeted appropriately, i.e. does not distort competition or crowd out private investors, and also supports social groups that actually need it. In Poland both goals are guaranteed to be achieved because the affordable housing program is very clearly defined at national level (in legal acts governing it). There are limits imposed on household income (ensuring that the target group consists of people unable to satisfy their housing needs on commercial terms) as well as rent levels (ensuring that rent remains affordable and does not reach levels enabling investors to generate excessive profit). Also, investors eligible for the program are exclusively social housing associations (TBS/SIM companies, usually owned by municipalities), municipal companies and housing cooperatives. All TBS/SIM companies are not-for-profit organizations that, while being allowed to generate some profit, have to reinvest it in its entirety in their statutory, mission-driven activities, i.e. providing affordable rental housing to less socially advantaged groups with limited solvency. Housing cooperatives operate according to very similar principles. Therefore, there is virtually no risk of undue state aid. Considering the above, we recommend a thorough revision of SGEI regulations in the area of affordable housing. In case of open programs with broad eligibility extending to the private sector, reasonable profit could (and in our opinion should) be calculated on the entirety of SGEI costs incurred by the investor, not only on the promoters own contribution excluding any aid sources like grants or concessional loans. The Decision does not really specify how it should be done but it would be worth making clear so that local authorities do not interpret SGEI regulations in an overly (and unnecessarily) stringent manner. Besides, swap rates used to calculate reasonable profit should be matched with SGEIs entrustment period. IRS rates published by the EC go up to 10 years which is insufficient in many cases where services are provided for 20-30 years or more. Given the lack of market benchmarks, we suggest increasing shorter term swap rates with a certain coefficient that would reflect the extended entrustment period. In case of closed programs addressed to particular types of investors (like cooperatives or entities specializing in affordable housing) the SGEI framework could be abandoned in its entirety given the non-existent risk of improper aid targeting. With income and rent caps firmly established and enforced, and the not-for-profit orientation of promoters, there is zero market distortion or crowding out. Last but not least, its worth noting that (at least in Poland) the affordable housing program does not have two features of state aid: it does not distort competition (see above) and it does not affect trade between member states in any conceivable manner. There is no cross-border competitive pressure generated by SIM/TBS companies or housing cooperatives.
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and International Copper Association Europe and

24 Jun 2025 · Implementation of Critical Raw Materials Act

Response to European Affordable Housing Plan

2 Jun 2025

Poland, as any other member state, has its own set of challenges in the area of social and affordable housing. Some of them are independent from possible EU-coordinated actions, like dwindling supply of investment-ready land or high interest rates and construction costs. Others, however, can be jointly tackled or at least mitigated as part of the European Affordable Housing Plan. Summarizing BGKs proposals regarding affordable housing, we would like to indicate several solutions or measures that could be implemented, as well as rules to be observed when establishing EU-wide facilities. 1. Customized, tailored solutions adjusted to member state specificities. Any measures implemented have to take into account regional/local realities, including financial market (interest rates, currency, availability of public funds, private equity etc.), housing market (rent vs. ownership, market segments, household income levels) as well as existing housing programs (available instruments, target groups, regulations). 2. Adjustment and simplification of InvestEU procedures. BGK is currently in the process of signing an annex to the InvestEU agreement which focuses on obtaining a portfolio guarantee for newly established affordable housing entities (mainly municipal companies) applying for concessional long-term loans. Being pillar-assessed, we consider our organization a reliable, secure financial partner for the EC. As such, we reckon the appraisal process should be as streamlined as possible, while maintaining risk at a satisfactory level. 3. Amendment of state aid rules and regulations in the area of affordable housing. While we consider the EC Decision on SGEI broad enough to encompass affordable housing in addition to purely social housing, it is getting increasingly challenging for investors to fit within the tight SGEI framework based on net cost calculation with reasonable profit generated on the investors own contribution added on top. The state aid limit calculated in such a way has become a major constraint now that grants and interest rate subsidies are substantial in order to keep rent rates at bay, on a level adequate for tenants with moderate income. We suggest a review of state aid rules that would result in making the framework less stringent or even exempting affordable housing from state aid rules altogether, provided that programs are targeting appropriate investors and, more importantly, beneficiaries. Legally enforced rent caps, for instance, could qualify a program as state aid-compliant, given that rents require lending instruments to be concessional/preferential but also investors to be focused on social impact rather than profit-driven. 4. Emphasis on subsidiary and intermediated cooperation of NPBs and IFIs. BGK has had a very fruitful and long-standing relationships with the EIB and the CEB over the recent years. Both banks actively support the so-called SBC program, which is aimed at affordable housing by providing investors with long-term concessional loans. We would like to continue this collaboration within the EAHP. Favorable refinancing conditions in PLN being a prerequisite, we can see new opportunities in terms of developing affordable housing instruments jointly with EIB/CEB, working together on a complementary basis, rather than competing with each other and artificially dividing the portfolio into larger projects that would be deemed worthy of direct IFI support and remaining investments handled by NPBIs or local players. While we would make great use of IFI-provided funding, IFIs would leverage on our local business relationships, know-how, well-proven risk management and vast experience in both implementing (on behalf of the government) and running housing programs in an efficient manner.
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Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva), Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva)

12 May 2025 · Exchange of views on the possible governance and operation of a public-private scaleup fund.

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva)

22 Apr 2025 · Exchange of views on new initiatives in financing technology and innovation

Meeting with Krzysztof Hetman (Member of the European Parliament)

19 Mar 2025 · Enhancing the cohesion policy via the innovative solutions

Meeting with Ekaterina Zaharieva (Commissioner) and

6 Mar 2025 · Discuss collaboration and funding initiatives to support innovation and start-ups in Central and Eastern Europe and enhance Europe's competitiveness.

Meeting with Andrius Kubilius (Commissioner) and

25 Feb 2025 · Financial sector on defence, investment policies, EU regulatory framework

Response to European Sustainability Reporting Standards

7 Jul 2023

Dear Sirs, attached please find our feedback concerning European sustainability reporting standards first set. Best regards, Bartłomiej Danek
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Meeting with Lora Borissova (Cabinet of Commissioner Jutta Urpilainen)

1 Jun 2023 · Global Gateway implementation in Africa