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Związek Banków Polskich

ZBP

The Polish Bank Association represents banks in Poland, founded in 1991 to promote banking sector interests and coordinate with government and regulators.

Lobbying Activity

Meeting with Gijs Schilthuis (Director Agriculture and Rural Development)

28 Jan 2026 · Cooperative banks in the banking sector in Poland.

Meeting with Marlena Maląg (Member of the European Parliament)

28 Jan 2026 · Potrzeba uproszczenia przepisów ostrożnościowych i ram nadzorczych

Polish Bank Association urges simpler and consolidated taxonomy rules

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to simplify technical screening criteria.
Message — The association calls for consolidating fragmented regulations and simplifying complex technical screening criteria. They request that the responsibility for proving compliance shifts to producers and manufacturers.123
Why — Simplification would reduce the risk of misinterpretation and lower high compliance costs for banks.4
Impact — Manufacturers and supply chain entities would bear more responsibility for documenting environmental compliance.5
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Meeting with Tomasz Dolny (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

25 Nov 2025 · Polish Banking Sector

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 Sept 2025 · Banking matters

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

24 Jul 2025 · Exchange with the Polish Banking Association

Polish banks urge non-binding EU savings account blueprint

8 Jul 2025
Topic — The consultation seeks to create a European blueprint for savings and investment products.
Message — The association supports non-binding recommendations that allow banks to tailor products to local markets. They propose flexible accounts with tax exemptions and fewer bureaucratic barriers for consumers. Investment should focus on long-term goals like retirement rather than speculation.123
Why — Simplified rules and tax incentives help banks attract capital and reduce regulatory compliance costs.4
Impact — National governments may face reduced tax revenue due to proposed exemptions on investment profits.5
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

We appreciate the initiative taken by the European Commission. Please find attached the position of the Polish Bank Association.
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Polish Bank Association calls for unified EU sustainability rules

30 May 2025
Topic — The EU is reviewing rules for financial entities to disclose sustainability information.
Message — The association wants to unify definitions across green regulations and introduce clear product labels. They propose simplifying reporting forms and allowing parent companies to report for their whole group.123
Why — These changes would reduce operational costs and avoid frequent, expensive updates to internal IT systems.45
Impact — Sustainability goals lose priority when banks prioritize financial risk over client ESG preferences.6
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Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

13 May 2025 · Exchange of views with the local representatives of the SGB (Cooperative Banking Group) in Poland, members of ZBP.

Meeting with Christophe Hansen (Commissioner) and

9 May 2025 · Presentation of the Polish Bank Association / Financing of agriculture in Poland

Polish Bank Association urges suspension of Green Asset Ratio reporting

26 Mar 2025
Topic — EU initiative to simplify Taxonomy reporting and reduce costs for financial institutions.
Message — The association requests suspending the Green Asset Ratio until a full regulatory review occurs. They want to limit reporting only to companies already within sustainability disclosure scopes. They also propose completely removing multiple mandatory templates and disclosure tables.123
Why — Banks would avoid the significant difficulty of collecting unavailable data from retail customers.45
Impact — Financial regulators and market participants lose access to comparable data on environmental risks.67
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Polish Bank Association urges simpler, more efficient securitisation rules

26 Mar 2025
Topic — The European Commission is conducting a holistic review of the EU securitisation framework.
Message — The association requests correcting capital efficiency rules for senior tranches and simplifying reporting to reduce costs. They also suggest relaxing Liquidity Coverage Ratio criteria to help securitisation compete with covered bonds.123
Why — These adjustments would decrease compliance expenses and free up bank capital for further lending.4
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Response to Savings and Investments Union

7 Mar 2025

The Polish Bank Association would like to thank for the opportunity to present the Polish banking sector comments on the concept of building a savings and investment union. The aim of the project is to increase the efficiency of EU capital markets, which is strongly supported by the Polish Bank Association. Please find the detailed position of the Polish Bank Association in the attachment.
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Polish Bank Association backs permanent rules for securities financing

6 Mar 2025
Topic — This consultation addresses proposed changes to banking rules for securities financing transactions.
Message — The association urges the Commission to make the current temporary rules for securities financing transactions permanent. They argue this is necessary to support efficient capital allocation and ensure the repo market remains an active source of liquidity.12
Why — Permanent rules would lower bank funding costs and prevent business from shifting to offshore competitors.34
Impact — Member States face higher borrowing costs and difficulty rolling over their stock of sovereign debt.5
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Meeting with Maria Luís Albuquerque (Commissioner) and

6 Mar 2025 · • Omnibus package • Implementation dialogue with the banking sector in the central European Member States • Payment Services Regulation

Meeting with Hanna Gronkiewicz-Waltz (Member of the European Parliament)

20 Feb 2025 · Insights into the legislative process from the perspective of the Polish Bank Association

Meeting with Krzysztof Hetman (Member of the European Parliament)

15 Jan 2025 · Cooperative banking sector role in agriculture financing

Meeting with Maria Luís Albuquerque (Commissioner) and

15 Jan 2025 · Exchange of views with the Polish and Romanian Bank Associations

Meeting with Hanna Gronkiewicz-Waltz (Member of the European Parliament)

15 Nov 2024 · Reflections on financial legislation by the Polish Bank Association

Meeting with Bogdan Rzońca (Member of the European Parliament)

26 Sept 2024 · Current situation and challenges of the Polish banking sector

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

12 Oct 2023 · Meeting with with Vice-President and Technnical Director of the Association of Polish Banks

Meeting with Marek Belka (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs

27 Sept 2023 · Payment Services Regulation (APA on behalf of MEP)

Polish Bank Association urges delay and simplification of tax reform

14 Sept 2023
Topic — EU initiative to standardize withholding tax relief and speed up refund processes.
Message — The association requests a simplified system relying on formal documentation instead of complex due diligence. They advocate for removing reporting thresholds and delaying implementation until 2028 for system readiness.123
Why — Simplified requirements would reduce administrative costs and prevent the need for manual contract analysis.45
Impact — Cross-border investors lose out on faster tax refunds due to the proposed implementation delay.6
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Polish Bank Association warns against ban on investment inducements

28 Aug 2023
Topic — The consultation concerns new EU rules to protect and encourage retail investors.
Message — The Association strongly appeals to the Commission to resign from the proposed cost benchmarks and the ban on inducements. They argue these measures interfere with economic freedom and fail to account for local market specificity.12
Why — Maintaining the current system preserves existing revenue streams and avoids costly technical infrastructure updates.34
Impact — Retail clients face higher direct fees and a significantly reduced selection of investment products.56
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

23 Aug 2023

Dear Sirs, Please find attached the Polish Bank Association position on: - proposal for a Directive of the European Parliament and of the Council amending Directive 2014/49/EU as regards the scope of deposit protection, use of deposit guarantee schemes funds, cross-border cooperation, and transparency published 18 april 2023; - proposal for a Directive of the European Parliament and of the Council amending Directive 2014/59/EU as regards early intervention measures, conditions for resolution and financing of resolution action published 18 april 2023. Yours faithfully, Katarzyna Pawlik Adviser to Management Board Polish Bank Association
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Polish banks urge mandatory reporting to close ESG data gaps

7 Jul 2023
Topic — New European standards for companies to report environmental, social, and governance factors.
Message — The association demands mandatory reporting on all sustainability topics to prevent data gaps for financial institutions. They argue that voluntary disclosures create complexity and risk market uncertainty.12
Why — Mandatory reporting provides banks with the reliable data required for their own regulatory disclosures.3
Impact — The public loses transparency as companies might use confidentiality clauses to hide negative impacts.4
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

15 Feb 2023 · Mortgage loans

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen) and Banco Santander, S.A. and

7 Jul 2022 · Topic: Polish loans in foreign currency (CHF) and the UCTD Directive. Eu Commission made it clear that we do not interfere in cases before the ECJ and with the SJ work in this regard.

Meeting with Mairead McGuinness (Commissioner) and

28 Jun 2022 · Financial inclusion, financial literacy, macroeconomic context.

Meeting with Danuta Maria Hübner (Member of the European Parliament) and Romanian Association of Banks

28 Jun 2022 · Presentation of PBA, RBA and HBA enhanced cooperation

Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings

2 Jun 2022

Szanowni Państwo, dziękujemy za możliwość udziału w tej konsultacji. W załączniku przekazuję stanowisko Związku Banków Polskich.
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Polish Bank Association urges alignment of EU sustainability rules

23 May 2022
Topic — EU proposal requiring companies to identify and mitigate environmental and social risks.
Message — The association demands aligning terminology with existing EU green finance laws to avoid interpretative doubts. They also request narrowing the due diligence scope to exclude small businesses and retail customers.12
Why — This would lower compliance costs and shield banks from unpredictable legal risks.3
Impact — Affected groups and environmental organizations lose the right to claim financial damages.4
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

29 Mar 2022

Dziękujemy za możliwość przedstawienia opinii polskiego sektora bankowego w przedmiotowej konsultacji. W załączniku przekazujemy stanowisko Związku Banków Polskich.
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Response to Alternative Investment Fund Managers – review of EU rules

24 Mar 2022

Please find enclosed the position of the Depository Banks Council within the Polish Bank Association.
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Response to Review of the regulatory framework for investment firms and market operators (MiFID 2.1)

22 Mar 2022

Związek Banków Polskich dziękuje za możliwość przedstawienia opinii w sprawie zmian w MIFID II. W załączniku przekazujemy stanowisko Związku Banków Polskich.
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Response to Consumer Credit Agreement – review of EU rules

2 Sept 2021

PBA positively assesses the objectives to be achieved by the new EU consumer credit legislation aiming at achieving a smoothly functioning internal market and adapting the legislation to the changing technological tools used to provide credit. This is extremely important, since the adaptation of the previous regulation (2008) - the financial market underwent a technological revolution, which have fundamentally changed channels of access to financial services, as well as habits and preferences of customers. In addition, the draft directive, based on previous experience, clarifies many issues that were only mentioned in the previous directive and as a result their implementation in member states was very different, so in essence, the fragmentation of the EU market increased. It also seems particularly valuable to extend the scope of the Directive to further groups of credit-related service providers, such as crowdfunding credit services because consumers have right to the same level of protection regardless of the source of credit. The PBA also agrees with the concept of full harmonisation of these rules across Member States and the absolutely binding nature of the new Directive. However, to this end, it is necessary to introduce more detailed solutions at the EU level in several parts of the draft to ensure its uniform implementation in individual markets. However, analysis of the draft Directive leads also to a conclusion that it imposes excessive obligations related to the Directive's objective (e.g. an information overload for every step in the relation between consumer and creditor). Such attitude can hinder the technological development of this market and give an impulse to consumers; dissatisfaction with services offered by European creditors. PBA suggest to improve the quality of the EU legislation and create a common EU- market by taking into consideration the following issues, which could balance both the needs of customers and credit providers in order to ensure legal framework for efficient and modern European credit market: Adaptation of the Directives to the technology used currently successfully by consumer and credit providers. One should e.g. keep in mind that rules on standard information to be included in advertising of credit agreements need a coordination with technical limits of modern advertisement like text messages or internet banners. Another example for regulation which will have a negative impact on the credit services quality is the general directive to provide pre-contractual information to the consumer at least one day before he or she is bound by any credit agreement. Consumers will undoubtedly recognise is as a bureaucratic barrier in the credit application and will e. g. be forced to visit a shop next day to sign the credit contract and take the purchased good. Such attitude could also damage in a serious way access to credit via internet, which today is preferred by the young generation. Early repayment rules reimbursement should involve only a reduction in the total cost of the credit, consisting of the interest and the costs for the remaining duration of the agreement . The interest and costs for the period of use loans should be due to the lenders in full. Otherwise it is impossible to prepare by creditors a reliable calculation of costs and incomes related to particular credit portfolio. The new rules of assessment of the consumer’s creditworthiness presented in the draft leave many doubts how to assess the consumer's interest and what criteria should be taken when assess that interest.
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Response to Designation of a statutory replacement rate for EONIA (Benchmark)

31 Aug 2021

The Polish Bank Association (“PBA”) welcomes and fully supports the Commission's initiative to designate a statutory replacement rate for EONIA. Polish banking sector supports this legal initiative as a needed for ensure the smooth transition from EONIA to €STR. The systemic solution in the form of implementing regulation under art 23b BMR guarantees the legal certainty and it will be a comprehensive solution for cash and derivative products. Please find enclosed full Position of the PBA.
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Response to Designation of a statutory replacement rate for CHF LIBOR (Benchmarks)

31 Aug 2021

The Polish Bank Association (“PBA”) welcomes and fully supports the Commission's initiative to designate a statutory replacement rate for CHF LIBOR as part of a comprehensive solution especially for financial contracts with consumers, as it will provide legal certainty, guarantee continuity of contracts and will provide a high level of consumer protection. We strongly believe that there is a need to use the power from art. 23b of the of the Benchmark Regulation (“BMR) in relation to CHF LIBOR and we fully support the argumentation used by the Commission in the preamble of the Draft. The statutory replacement under the art. 23b is the only common solution common for all Member States which provides the proper level of protection of the financial markets in the EU (preventing the significant disruption the functioning of financial markets in the Union) and simultaneously guarantees an appropriate level of protection for those contracts which do not contain adequate fallback provisions and especially on residential mortgages. Statutory benchmark replacement (under 23b of the BMR) allows to keep a particular feature of a mortgage credit contract with LIBOR as an underlying benchmark, which is the variable interest rate provision. The Draft of implementing regulation meets our expectations and we would like to express our appreciation to the Commission. We stand on the position that using the power from art. 23b of the will help all financial market participants to sustain concluded agreements in force. Please, find enclosed full Position of the PBA with some specific appreciations and some remarks of the aspects which could be reviewed in order to improve the effectiveness of the statutory replacement tool in this particular case.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

1 Jun 2021

Please find enclosed the statement of the Polish Bank Association.
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Response to Review of the Benchmark Regulation

5 Oct 2020

Thank you for the opportunity to comment the project of the review of BMR Regulation. Please find enclosed the statement of the Polish Bank Assosiation.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

The Polish Bank Association welcomes the opportunity to comment on the European Commission’s inception impact assessment on the proposed Delegated Regulation on Taxonomy-related disclosures by undertakings reporting non-financial information. Please find the PBA position paper attached.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

Please find enclosed the opinion of the Polish Bank Association on sustainable finance - obligation for investment firms to advise clients on social and environmental aspects of financial products.
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Response to Review of Regulation on cross-border payments

12 Jun 2018

Joint position of six national banking associations from 6 Member States of the European Union, representing hundreds of banks, including private and state banks as well as cooperative banks, employing thousands of employees in all combined banking sectors: - Association of Banks in Bulgaria - Croatian Banking Association - Czech Banking Association - Hungarian Banking Association - Polish Bank Association - Romanian Association of Banks Attached please find our detailed joint position. We welcome the opportunity to express our comments to one of the latest legislative proposals of the European Commission, namely the EC proposal for a Regulation amending Regulation 924/209 as regards certain charges on cross-border payments in the Union and currency conversion charges. We are concerned by the unequal treatment of euro and other national currencies of the non-euro zone Member States of the European Union. If a Bulgarian, Czech, Croatian, Hungarian, Polish or Romanian bank processes bank transfer in euro to a French or German bank and charge the client the same fee as for a transfer in their respective national currency, a French or German bank may be able to charge its client much higher fees - when processing bank transfer in Polish zloty or Romanian lei - than the fees for domestic transfer in euro. It is also very important to mention that the data provided by the Commission in the accompanying documents, showing the examples of fees for a cross-border bank transfer in euro in the amount of 10 (ten) euros, is not a representative exemplification of the current market situation, as well as the scope of fees charged by the banks for such a payment service in non-euro Member States. We would like to underline that a transaction of 10 (ten) euros shall be treated as a very small part of the payment market and as such cannot be taken on board as a benchmark value for all the non-euro Member States. We would like to note that in our respective banking sectors the statistics on cross-border transfers shows that average amounts of transfers are much higher than 10 euros. This is crucial to ascertain the percentage level of fees for such transfers. The Commission’s proposal seems to be contradictory with the EU Acquis, as it could rule out some of the market players – especially the small and medium sized payment service providers - jeopardizing their current market positions and operation. We find the European Commission proposal as non-proportionate and drastically changing the market practices. Imposing such a significant regulatory measure for the fees on the payment market might lead to unexpected results, including rapid change of other fees or limitation of payment services offered by some banks. This might be counterproductive to the aim of the proposed legislation. Moreover, we strongly urge the European Parliament, the Council and the Commission to take equal approach versus euro and other national currencies in the European Union in order to preserve equal market conditions for payment service providers in all European Union Member States. If this Regulation shall be a regulatory incentive for banks and other payment services providers to lower the fees for European consumers, we stand on the very clear position that this should be reciprocal and not only “one way” approach to support merely the euro currency. It is crucial to keep the level playing field in this matter. We remain at your full disposal for any exchange of views or discussions so as to ensure the highest quality of the regulatory framework in the European Union which takes into account all the views and justified interests of all consumers and businesses. Contact person – coordinating our joint activity in this matter: Mr Piotr Gałązka, Director of the Representation Office in Brussels of Polish Bank Association, piotr.galazka@zbp.pl
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Response to Development of secondary markets for non-performing loans

7 Jun 2018

Polish Bank Association (PBA) welcomes the opportunity to present the position regarding the legislative package of the European Commission containing draft EP and Council Regulation amending Regulation (EU) No 575/2013 regarding the minimum coverage of losses due to non-covered exposures and the Directive of the EP and of the Council on credit servicers, credit purchasers and the recovery of collateral. PBA wants to declare that it supports the legislative proposal as necessary to tackle the issue of a high percentage of non-performing loans (NPLs) in the banking sector in the European Union. We recognize the significant importance of the need to address the problem of non-performing loans in Europe. Polish Bank Association strongly supports the assumptions of the directive regarding the introduction of an accelerated enforcement mechanism out of collateral in relation to credit agreements for the purposes of which collateral was established between issuers and entrepreneurs, called AECE (accelerated extrajudicial collateral), defined in particular in articles 23 and the next ones draft Directive. The proposed solutions for AECE are proportional and correct. It is worth noting that AECE will - in accordance with the EC proposal - apply only in the case of contracts with entrepreneurs, and not with consumers. In addition, AECE will apply only to credit agreements secured by a mortgage on real estate or pledge on movable property owned by the borrower. Equally important, the mortgage on the residential real estate in which the entrepreneur lives is excluded from the scope of AECE. All these restrictions have been clearly indicated in the proposed art. 2, paragraphs 2 and 5 of the proposal of the Directive. In the opinion of PBA, these exemptions allow the borrower to use the AECE instrument only in cases where it is necessary for the proper performance of the loan agreement and without violating the borrower's fundamental rights. It should also be borne in mind that the proposed art. 23 sec. 1 of the Directive proposal introduces a series of restrictions on which the possibility of applying the AECE mechanism by the borrower depends. The most important is the obligation to notify the borrower with at least four weeks’ notice to repay the loan. In addition, the lender is obliged to inform the borrower accordingly about the possibility of using the mechanism, and consent for its use must be included in the loan agreement. The proposed provisions also allow the Member State to introduce in the national law the obligation to suspend the AECE mechanism for a period of 6 months if within the four-week deadline the borrower repays at least 85% of the value of the claim. PBA also draws attention to the fact that the proposed art. 28 of the Directive unambiguously provides the debtor with the possibility of judicial review of the AECE mechanism, while Art. 24 sec. 2 of the directive proposal specifies that a Member State may require that proceedings under the AECE mechanism be conducted not independently by the borrower but by a bailiff. An additional safeguard of the borrower's rights is the rule specifying the obligation to correctly assess the value of the collateral. In the opinion of the PBA, the proposal to change the CRR imposes additional capital charges on banks, which will make the bank loan more expensive and harder to access for many potential borrowers. Imposing an additional capital requirement will also encourage banks to accelerate their claims against borrowers, which may worsen the situation of many indebted borrowers.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

Dear EC, Please find attached position of Custodian Banks Board within Polsih Bank Association . Kind regards, Jacek Mierzejewski Chairman Custodian Banks Board
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Response to Statutory prudential backstops addressing insufficient provisioning for newly originated loans that turn non-performing

10 Apr 2018

Dear Sirs, In reference to the proposal for Regulation of the European Parliament and of the Council on amending Regulation (EU) No 575/2013 as regards minimum loss coverage for non-performing exposures, please find attached Polish Bank Association official position, signed by Krzysztof Pietraszkiewicz, President of the PBA. If you have any question, do not hesitate to contact us directly. Yours faithfully, Katarzyna Pawlik Economic Affairs and Regulation Department Polish Bank Association
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Response to Draft Delegated Act amending the Commission Delegated Regulation on the Liquidity Coverage Ratio ('LCR')

20 Feb 2018

Dear Sirs, In reference to the public consultations on Draft Delegated Act amending Delegated Regulation (EU) 2015/61 of 10 October 2014 to supplement Regulation (EU) No 575/2013 of the European Parliament and the Council with regard to liquidity coverage requirement for Credit Institutions, please find attached Polish Bank Association official response signed by Mr Krzysztof Pietraszkiewicz, President of the PBA. If you have any question, do not hesitate to contact us directly. Yours faithfully, Katarzyna Pawlik Economic Affairs and Regulations Polish Bank Association
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Finance Denmark

31 Aug 2017 · PSD2