At the beginning of June, the Office of Competition and Consumer Protection (UOKiK) announced its intention to initiate legislative work on a law introducing standardized templates for mortgage contracts based on periodically fixed interest rates. These templates would apply to all lenders, without the possibility of modification. The proposed solution is designed to safeguard consumer interests while reducing legal risks for banks and making it easier for consumers to compare offers. The banking sector has expressed support for this initiative.
“Within UOKiK, work is underway on a unified mortgage loan contract template. The Polish Bank Association (ZBP) is participating in this process and is being consulted on its shape. Parallel work on such a template is also taking place within the European Financial Congress, where ZBP is active as well,” said Agnieszka Wachnicka, Vice President of ZBP, in an interview with Newseria. “We hope not only to develop but also to implement a unified mortgage contract. In our view, such a template should be introduced as a universally binding legal act, for example as an annex to a regulation.”
The initiative came from UOKiK in early June. As President Tomasz Chróstny explained, today’s mortgage agreements are often complex, full of unclear clauses and conditions – such as linking margins to the purchase of additional services – which pose major problems for borrowers. UOKiK experts have been working on these templates for over a year, aiming for them to be used in property purchases on both the primary and secondary markets. The Office invited the Polish Bank Association and the Financial Supervision Authority (KNF) to collaborate. The goal is for the final contract template to be introduced into Polish law as a universally binding standard. To that end, Chróstny has requested authorization from the Prime Minister and an entry in the Council of Ministers’ legislative work schedule.
“A unified mortgage loan contract has benefits for both consumers and banks. Both sides could be certain that the terms will not be disadvantageous and cannot be challenged. Banks support this solution,” Wachnicka emphasized.
Predictability for Consumers, Reduced Risk for Banks
Under the standardized contract, banks would no longer be able to bundle additional services with mortgage loans (except for property insurance), a practice that is widespread today. This would make monthly installments more predictable and eliminate significant extra costs. The template would also standardize the calculation methods and set maximum compensation levels that banks can claim when borrowers repay loans early.
For banks, the key benefit would be lower legal risks from borrowers disputing contract clauses. Currently, this risk has a major impact on lending costs. For example, the average mortgage margin last year was 1.7%, of which 0.81 percentage points reflected legal risk. According to UOKiK, this translated into more than PLN 537 million in additional costs.
The template under development applies exclusively to loans with a fixed interest rate for the first five years. According to the AMRON-SARFiN report, in Q2 2025 almost three-quarters of the value and more than three-quarters of the number of newly granted loans were based on periodically fixed rates. Their share has already fallen by over 10 percentage points in the past two quarters, likely due to renewed interest rate cuts by the Monetary Policy Council (RPP). Between May and September, rates were lowered by a full percentage point, and the market expects further reductions. Fixed-rate loans gained popularity after a sharp rise in market interest rates during the inflation surge, when the 3M WIBOR jumped from 0.23% in autumn 2021 to over 7% a year later.
“Many clients still choose periodically fixed-rate loans for security reasons,” Wachnicka explained. “A standardized contract template based on such rates would create a benchmark model for mortgage agreements.”
Why Fully Fixed-Rate Loans Remain Unrealistic in Poland
According to Wachnicka, fully fixed-rate loans covering the entire loan term are not feasible under current Polish conditions.
“Such a solution would certainly be desirable, and banks would be ready to implement it, but it is impossible. First, long-term interest rate hedging instruments are unavailable – banks cannot hedge the risk over such long periods. Second, we still have not resolved the issue of banks being unable to charge compensation for early repayment. This prevents banks from significantly extending the fixed-rate period,” Wachnicka stressed.
