Polish Banking Law: Transposition of CRD VI - Branch Requirement and Removal of Grandfathering Protection
16 September 2026
Poland's Parliament has adopted legislation implementing Directive 2013/36/EU as amended by Directive (EU) 2024/1619 of the European Parliament and of the Council of 31 May 2024 (CRD VI). The Act was published in the Journal of Laws on 14 September 2026.
The Act of 31 July 2026 amending the Banking Law and certain other statutes (the Act) introduces, among other changes, a new branch requirement for third-country banks and third-country non-bank entities that wish to carry out lending and deposit-taking activities in Poland.
Whilst the Act is broadly consistent with the requirements of CRD VI, a critical grandfathering provision protecting clients' acquired rights under pre-existing contracts was removed during parliamentary proceedings without sufficient justification.
