The Point for CEEMEA

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The Point for CEEMEA

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Wednesday, 17 June 2026

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Poland Diversified Banks - Will the recent CJEU ruling on consumer loans impact

2026 results? Emerging Markets Economic Outlook

In 2019, CJEU ruled on interpretation of the EU Consumer Credit Directive (CCD) & Strategy - Global Imbalances – EM’s

Role and Policy Responsesregarding return of fee on early repaid loans (the ruling was dubbed “lesser ECJ”,

for details see LINK), which forced Polish banks to change their practices

immediately and over 2H19-2021 led to more than Zl 3bn in costs. We see a risk

that repercussions of the April 2026 CJEU ruling (‘lesser ECJ no.2”), which was also

under interpretation by CCD, may be similar: banks may immediately stop

charging borrowers interest on a part of loans provided to finance upfront costs

and create provisions for customers’ claim to return interests charged in the past.

The range of potential costs is wide (between Zl 2bn and Zl 20bn for 8 Polish

banks covered) but in the base case we expect Zl c.3.5bn (i.e. 7% of expected net

profit).

Andrzej Powierza

Polish Banks Big Picture - Next solid month but we flag legal risks

April was the next solid month in terms of volume growth, both on loan and

deposit side and best this year in terms of profitability but we maintain our view

that these positives are already priced-in while the balance of risk is skewed to the

downside (see Poland Diversified Banks - A chapter is closing – Turning Neutral on

Polish banks). The banking sector still analysis the consequences of CJUE ruling in

case C-744/24 (see LINK, BI 6/14) but we see a risk that the banks will decide to