Loan institution

The Polish Consumer Credit Act (Article 5 point 2a) defines a loan institution as a lender of consumer credit other than a bank, a credit institution, a credit union (SKOK), or a seller that defers payment for its own goods and services. In practice these are the companies behind cash loans and installment loans sold online and through apps.

Article 59a sets the entry conditions. A loan institution may operate only as a joint-stock company or as a limited liability company with a supervisory board. Its minimum share capital is PLN 1,000,000, paid in cash only, and the money may not come from a loan, a bond issue or undocumented sources. Board members, supervisory board members and proxies may not have final convictions for offenses against documents, property, business transactions or money.

The company may start lending only after it is entered in the register of loan institutions (Article 59aa). The Polish Financial Supervision Authority (KNF) keeps the register and publishes it online (Article 59ab). The capital and supervisory board conditions above have applied since December 18, 2022; according to KNF, the minimum capital was PLN 200,000 before that date and a limited company did not need a supervisory board. KNF makes the entry within 14 days of the application, which costs PLN 600. A lender that operates without the entry faces a fine of up to PLN 500,000 (Article 59h).

Since January 1, 2024 the consumer lending activity of loan institutions has been under KNF supervision under chapter 5ab of the Act. KNF says that institutions which did not meet the new conditions by then were to be struck off the register.

Supervision turns several legal duties into data and reporting requirements. Most of them land in the loan system and its backend, and some reach the customer app.

KNF reporting comes straight from the loan book. Under Article 59dg a loan institution sends KNF quarterly and annual reports, electronically and only through KNF's own forms and channels. They cover the number and value of loans with their term and currency structure and the delays in repayment, the number, types and status of agreements, the number of customers, total revenue with non-interest costs shown separately, the balance sheet with sources of funding, and the people in management roles. KNF may also ask for other data and documents (Article 59dh). If the loan system cannot produce these figures by query, someone ends up assembling them in spreadsheets every quarter.

The pricing engine has to enforce the cost cap. Article 36a caps non-interest costs at (K x 10%) + (K x n/R x 10%) for credit of 30 days or more, where K is the total amount of credit, n the repayment period in days and R the number of days in the year, and at K x 5% for credit shorter than 30 days. Non-interest costs may never exceed 45% of the total amount of credit. Articles 36b and 36c add the costs of a deferral, or of further loans to a customer who has not repaid, within 120 days of the first payout into one calculation. The engine therefore has to look across a customer's loans, not just at the one being priced. A breach of Articles 36a to 36c lets the consumer repay the credit without interest and other costs (Article 45).

Article 9a makes the credit decision something the lender has to prove. It requires a positive creditworthiness assessment based on data from trusted providers such as credit bureaus, and an income statement with documents when that data is not enough or the amount exceeds twice the minimum wage. The data behind the assessment is kept for three years after the relationship ends, and the burden of proof sits with the loan institution. Lenders that confirm income through open banking have to store that account data with the decision it supported. Under Article 59b a loan institution that shares data with the banks' credit bureau must report full repayment, corrections and new obligations within 7 days.

The main source is the Consumer Credit Act of May 12, 2011, most recently published as a consolidated text in Dziennik Ustaw 2025, item 1362. KNF supervision can end in a fine of up to PLN 15,000,000 for the institution and up to PLN 150,000 for the board member responsible, a request to dismiss that board member, or removal from the register (Article 59di).

The EU directive that replaces Directive 2008/48/EC, including its rules on cost caps, is described under CCD2. What it changes for Polish loan institutions depends on the national implementing act.

We have built and developed Aasa24 since May 2023, the mobile lending app of Aasa Polska S.A., a lender entered in the KNF register of loan institutions under number RIP000127. The first public release came in November 2023, and a permanent team has developed the app since, with 47 production releases by September 2026. Aasa's team changes calculator parameters, documents and messages in an admin panel, without a new release in the app stores.

Since January 2026 we have built the mobile app of AvaFin Poland, a loan institution under KNF supervision. AvaFin keeps pricing and process rules, including the order of the loan application steps, in its central system; the app displays them.