The grey market in Poland’s non-bank lending sector now accounts for around 15% of the entire market and generates approximately PLN 5.1 billion in annual turnover, according to a new report by the Warsaw Enterprise Institute (WEI), “The Grey Market in Poland. The Non-Bank Lending Sector.” The authors estimate that this corresponds to more than 1.25 million loan transactions per year concluded outside the legal framework. According to WEI, one in six loan transactions currently takes place without state supervision and without real consumer safeguards.
The report highlights a sharp increase in rejection rates within the legal segment of the market. In the first half of 2025, as many as 77% of applications submitted to lending institutions were reportedly rejected. At the same time, 59% of applicants failed to obtain financing from any legally operating non-bank lender. WEI estimates that in 2024 nearly 2.8 million borrowing needs went unmet by legal financing, despite sustained demand for consumer loans.
“This is the first attempt to measure something that is, by definition, invisible. The grey market does not disappear simply because the state fails to see it—it grows wherever regulations prevent legal entities from responding to real consumer needs,” says Wojciech Wyszomierski, an analyst at WEI. According to the report’s authors, nearly half of those who are denied a loan actively seek alternative financing, with some of them turning to entities operating outside the law.
WEI points out that the main driver pushing customers out of the legal market is regulation that limits the ability to tailor offers to different levels of risk. This includes, among other things, rigid caps on non-interest costs, mandatory uniform creditworthiness assessments, and the lack of tools to realistically “price risk” for higher-risk customers. As a result, legal lending institutions are adopting increasingly conservative credit policies, and the share of new customers has fallen—according to the report’s data—to 8.5%, even though the number and total value of loans granted increased by 34% over the past two years.
The authors also stress the social dimension of the problem, pointing to the motivations of people seeking money “immediately.” Research cited by WEI shows that when refused by a legal institution, as many as 72.7% of people seeking financing for health-related needs declare their willingness to use the grey market. High figures also apply to current financial obligations (64%) and the needs of close relatives (59.8%). According to WEI, this indicates that for some households, borrowing is a way to cope with sudden expenses rather than a “consumption whim.”
“The state, instead of genuinely protecting consumers, is pushing them out of the legal market. Outside it, there are no cost limits, no debt collection standards, and no legal safeguards,” says Piotr Palutkiewicz, vice president of WEI. In his view, the grey market represents not only a risk to consumers but also losses for the public budget—no tax revenues, no oversight, and greater scope for abuses, including aggressive debt collection practices and falling into debt spirals.
WEI also emphasizes that the problem does not stem from “excessive indebtedness of Poles” at the macro level. The report notes that household debt in Poland amounted to 22.5% of GDP in the first quarter of 2025, compared with an EU average of 51.1%. At the same time, households in Poland save around 10% of their disposable income on average, compared with approximately 15% across the EU.
In its recommendations, WEI calls for a review of existing regulations and consideration of changes that would increase flexibility for legal lenders in risk assessment and product design. The aim would be to limit the outflow of customers to the grey market, enhance competition, and improve the effectiveness of enforcement against illegal lenders. The report’s authors warn that without a “reality check” of certain regulations—including the cap on non-interest costs—the rejection rate for loan applications may continue to rise, along with the scale of lending conducted outside the law.
