Press release of the Financial Stability Committee after its meeting on macroprudential supervision

Date of publication:

Warsaw, 19 September 2025

The meeting of the Financial Stability Committee on 19 September 2025 was attended by:

  • Artur Soboń, Member of the Management Board of Narodowy Bank Polski, as the Chair of the Committee,
  • Jarosław Neneman, Undersecretary of State at the Ministry of Finance,
  • Marcin Mikołajczyk, Deputy Chairman of the Polish Financial Supervision Authority,
  • Maciej Szczęsny, President of the Management Board of the Bank Guarantee Fund.

Performing its statutory duties, the Financial Stability Committee (FSC) passed a resolution in which it upheld its recommendation of 14 June 2024 for the Minister of Finance on the rate of the countercyclical capital buffer. The target countercyclical capital buffer rate recommended by the Committee is 2% with a gradual achievement of this level. In the first stage, the countercyclical buffer rate, introduced by way of regulation of the Minister of Finance[1] and applicable from 25 September 2025, amounts to 1%. The representative of the Minister of Finance accepted the recommendation and informed the Committee about the upcoming issuance of a new ordinance that sets the rate of the countercyclical capital buffer at 2% after the lapse of 12 months from the date of publication of the ordinance, fulfilling the second stage of the Committee’s recommendation.

The Committee members discussed the sources of risk in the Polish financial system and its environment. The synthetic risk assessment indicator remained unchanged from the previous quarter. The risk associated with the FX housing loan portfolio remains the most significant vulnerability in the Polish financial system. Geopolitical risk, the risk of WIBOR being undermined, the free credit sanction, and residential real estate (RRE) risk are next in the hierarchy of such vulnerabilities.

The Committee took note of the opinion of the Advocate General of the Court of Justice of the EU of 11 September 2025, which confirms the assessment expressed in the Committee’s press releases on the lack of legal grounds to challenge the WIBOR benchmark.

In the context of the free credit sanction risk, the Committee considered that in the draft Act on consumer credit presented for public consultation, the statement of the FSC on the risk related to the application of the free credit sanction had not been adequately addressed. The Committee considers that no regulatory solutions have emerged that would sufficiently limit the scope and possibility of applying the free credit sanction. The Committee continues to see areas that may encourage the abuse of the consumer protection regulations.

The analysis of current trends in the RRE market indicates that the last quarter saw a further slowdown in nominal and real housing price growth on the back of lower demand. However, supply-side adjustments mean that the risk of a price correction on the real estate market is assessed as low. The value of housing loans is growing at a moderate pace and their quality remains very good. The squeeze on banks’ margins continues. A decline in the use of aid from the Borrower Support Fund was observed.

At the request of the Polish Financial Supervision Authority, the Committee issued opinions on the identification and imposition of adequate buffers on other systemically important institutions (O-SII).

The Committee reviewed the following documents: (i) Macroprudential Policy Strategy, and (ii) Macroprudential Supervision in Poland – institutional and functional framework. It was considered that these documents remain relevant and meet the needs of the macroprudential policy conducted by the Committee. Reorganising changes were made, reflecting the need to update the provisions in order to bring them into line with the current legal order and reduce duplication of the same information in both documents.

Implementing the recommendations of the European Systemic Risk Board, the FSC reviewed:

  • the results of the monitoring of the Polish banking sector’s exposures in Luxembourg, Denmark, and Italy,
  • the analyses of the Polish banking sector’s exposures in Germany, Norway, and Sweden

and decided that there were reasons allowing Poland not to reciprocate the macroprudential measures implemented in those countries.

The Committee took note of the review of the macroprudential policies pursued by individual countries and at the European Union level.

The next regular meeting of the FSC on macroprudential supervision has been scheduled for December 2025.

[1] Ordinance of the Minister of Finance of 18 September 2024 on the countercyclical buffer (Journal of Laws 2024, item 1400).