Poland Diversified Banks: Will the recent CJEU ruling on consumer loans impact 2026 results?

Research evidence excerpt

Poland Diversified Banks: Will the recent CJEU ruling on consumer loans impact 2026 results?

Poland Diversified Banks

16 June 2026 Citi Research

Three categories of legal risks

So far investors were focused on two categories of legal

risks…

In recent quarters, investors were focused on two categories of legal risks for Polish

banks:

n Litigations risks, namely:

– FX mortgage litigations (see Poland Diversified Banks: Counting Down to the

End of FX Mortgage Saga);

– Non-mortgage litigations, i.e. Zloty mortgage (Wibor) litigations and

consumer loan litigations concerning breaching information obligations

(”free-loan-sanction” or “SKD” litigations – for details see Poland Diversified

Banks - Non-FX Mortgage Legal Risks – CJEU Ruling Paves the Way For New

Type of Consumer Loan Litigations).

n Some investigations of the Antimonopoly and Client Protection Office (UOKiK),

including:

– Sector-wide investigation on unauthorised transactions and

– Some stock-specific investigations (e.g. clients’ complaints and

implementation of loan moratoria at Pekao and modification clauses and

interest modification clauses at PKO BP – see Poland Diversified Banks - Non-

FX Mortgage Legal Risks – CJEU Ruling Paves the Way For New Type of

Consumer Loan Litigations).

…which are diminishing or remain low

FX mortgage costs are – in line with the banks’ guidance and in line with our and

consensus expectations – declining (see Poland Diversified Banks - Solid 1Q26

results).

According to data as of an end of 1Q26, banks have been winning nearly all WIBOR

cases and more than 80% of SKD lawsuits (see in Poland Diversified Banks - Non-

FX Mortgage Legal Risks – CJEU Ruling Paves the Way For New Type of Consumer

Loan Litigations).