The year 2025 brings significant changes to financial market supervision introduced by the Polish Financial Supervision Authority (KNF). These new regulations aim to enhance the stability of the financial sector, increase transparency, and reduce the risk of conflicts of interest and abuses. The changes respond to current market and technological challenges and stem from the need to implement EU regulations, including the DORA and MiCA regulations.

One of the key elements of the amendment is the introduction of term limits for the Chairperson of the KNF and their deputies. Starting from January 11, 2026, the total time in these roles will be capped at 14 years. Cooling-off periods have also been established — former members of the KNF leadership will be prohibited from taking employment with supervised entities or providing services to the supervised sector for at least 12 months after their term ends. Similar restrictions apply to KNF employees, with a cooling-off period of 6 months. These rules aim to limit conflicts of interest and the “revolving door” phenomenon.

Another important change is the expansion of KNF’s authority regarding the approval of appointments to key positions in large financial institutions. Until now, KNF approval was only required for appointing bank presidents. Starting in 2025, this supervision will extend to other board members, chairpersons of supervisory boards, heads of internal control units, and chief financial officers. The goal is to ensure that individuals responsible for risk management and internal supervision meet high standards of qualification and ethics.

Supervision over significant transactions conducted by banks and other financial institutions will also be strengthened. Reporting planned transactions such as acquisition or disposal of significant shareholdings, transfers of assets or liabilities of substantial value, and mergers, acquisitions, or splits of credit institutions will become mandatory. KNF will gain the right to object to such transactions and to impose sanctions in cases of regulatory breaches.

New regulations will also require banks to incorporate environmental, social, and governance (ESG) risks more comprehensively in their risk management processes. This aligns with the global trend toward responsible and sustainable financial management.

KNF’s supervisory priorities for 2025 will focus on verifying the correctness of capital requirement calculations, managing risks related to banking products, interest rate and liquidity risk, as well as cybersecurity and operational resilience.

From January 17, 2025, the Digital Operational Resilience Act (DORA) will come into force, imposing uniform requirements on all financial sector entities to ensure operational resilience against digital threats. Key provisions include mandatory reporting of significant ICT incidents, maintaining a register of external ICT service providers and reporting them to KNF, conducting IT system testing, and implementing ICT risk management procedures. KNF will also gain new powers to supervise ICT service providers critical to the sector, thereby significantly enhancing cybersecurity and digital resilience across the financial market.

Another significant development is the implementation of the Markets in Crypto-Assets regulation (MiCA), establishing harmonized rules for the crypto-asset market within the European Union. MiCA aims to protect investors, regulate the issuance and trading of tokens and stablecoins, oversee service providers in the crypto sector, and increase the transparency and stability of the financial market in the context of new technologies. Entities operating in blockchain and tokenization will need to adapt to the new supervisory and reporting requirements.

Additional organizational and formal changes include modifications to PKD codes classification for funds and asset managers, affecting the registration and reporting processes of financial entities. KNF also plans to expand its inspection and sanction capabilities, particularly in the insurance and capital markets sectors.

In summary, 2025 marks a significant tightening and systematization of supervision over Poland’s financial sector. The new regulations aim to enhance market transparency, mitigate systemic risks, and align the national supervisory framework with EU standards. Financial institutions should begin adjusting their internal procedures, risk management systems, and reporting frameworks promptly to ensure compliance with the upcoming requirements.

Our law firm offers comprehensive legal and advisory support for implementing the new KNF requirements and the DORA and MiCA regulations. We invite you to contact us to discuss how best to prepare your organization for these upcoming changes.