The PZU Group’s activity and operations are sub ect to the impact of both national regulations and European legislation.
Insurance
From the point of view of the insurance business, legal regulations and case law affecting premiums, claims paid and other costs, distribution and coverage are particularly important.
In 2025, the insurance industry will be facing increasing regulatory challenges, especially in the context of EU regulations on Solvency II, IRRD or AML. This will mean having to adapt practices to the new regulations and may involve necessary investment in advanced IT systems.
The most important aspect in motor insurance will be the implementation of the provisions of the Act Amending the Mandatory Insurance, Insurance Guarantee Fund and Polish Motor Insurers’ Bureau and the Act on Insurance and Reinsurance Activity.
In early 2025, the KNF will submit a draft recommendation on insurance distribution for public consultation. According to the announcement of the supervisory authority, the recommendations will address the value of the product to the customer and how to perform the customer needs analysis – its procedure, form, documentation. In addition, the recommendations are to include, among other things, rules for the organization of distribution activities, cooperation with intermediaries, the obligation to adequately supervise agents and OFWCA. The recommendations will be applied to both individual and group insurance contracts.
Year 2025 will also be important in terms of developing a market standard for interpreting the provisions of the Regulation of the European Parliament on digital operational resilience for the financial sector (DORA) and the European Commission Regulation on a framework for Financial Data Access (FIDA). Insurers face a number of challenges to adapt procedures and contracts to the extent required by these regulations.
In addition, the insurance sector in the European Union will face significant changes in 2025 due to the evolving regulation of sustainable financial products. The current regulatory framework, in particular the Financial Services Sustainability Disclosure Regulation (SFDR), focuses on classifying products as “light green” Article 8) or “dar green” Article ), which does not fully address transitional products that play a key role in the transition to a sustainable economy.
In response to these shortcomings, the European Commission plans to propose changes to the SFDR in 2025. They will aim to cover transition products more comprehensively. This is in order to create a more flexible labeling system that reflects the diversity of sustainable investment strategies and supports a smooth transition towards sustainable practices. The European Insurance and Occupational Pensions Authority (EIOPA) had consultations on changes to SFDR’s Regulatory Technical Standards (RTS), seeking to harmonize them with existing regulations and ensure consistency in the approach to sustainable product disclosure.
For insurers, this means adjusting product strategies and reporting processes to meet the new requirements. Introducing a more varied classification of sustainable products will allow the offerings to better reflect sustainability, but will require updating internal procedures and information systems. Furthermore, it will be necessary to train staff on the new standards and ensure compliance with the new supervisory requirements.
In 2025, Poland’s insurance sector will have to adapt to the growing demands of sustainable financing in accordance with the EU Taxonomy, in particular by integrating the Green Asset Ratio (GAR) into its operations. It reflects the share of environmentally friendly assets in a financial institution’s total assets, which is crucial for assessing commitment to sustainability. So far, this ratio has been mainly used in the banking sector, but its importance is also growing among insurers, who are increasingly including sustainable financing in their business strategies, thereby helping to protect the environment and improve the quality of life in the communities in which they operate.
Although EU regulations, such as Solvency II, the AML, or the IRRD, are to be in force as of 2027, they will already have been analyzed and worked on to prepare PZU for their application, which requires committing adequate resources and making preparations to implement changes in systems.
Banking
An important factor affecting the banking sector's profit is the contribution to the Bank Guarantee Fund (BFG).
After a two-year hiatus, the BGF resumed collecting the banks' guarantee fund contributions. As a result, the total contribution to the BFG for banks in 2025 increased by 73% to PLN 2.7 billion, the highest in five years.
Rulings of the Court of Justice of the European Union (CJEU), the Supreme Court or other state institutions will continue to be key, particularly on foreign currency mortgages, free credit sanctions and cash loans. On 13 February 2025, the CJEU ruled in case number C472/23 on aspects of the application of free credit sanctions, leaving a wide margin of discretion to national courts hearing individual cases. Case law on CHF loans remains unfavorable for the sector. In 2024, the number of lawsuits from customers was increasing, also in cases of loans already paid off. This had an impact on the banks’ subsidization of reserves. At the same time, banks are trying to reach out more actively to customers with settlement proposals.
Banking activities may also be affected by possible new government programs to support the financial accessibility of housing.