Credit data in Poland: Regulators, banks, and the case for demonopolization

If not now, then when? That is the premise adopted by, among others, the Sobieski Institute and the Polish Financial Enterprises Association (KNF).

The issue is also being taken up by other institutions, including the heads of the Polish Financial Supervision Authority (KNF) and the Office of Competition and Consumer Protection (UOKiK), though each approaches it in a different way. The Credit Information Bureau (BIK), for its part, maintains that some of the arguments miss the mark – and that competition does not necessarily mean lower prices. Quite the opposite, it argues.

The Sobieski Institute’s November 2025 report on consumer protection in the credit information market passed almost unnoticed. The 37-page publication explains the legal framework governing the processing of credit data and points to the privileged, monopolistic position of the Credit Information Bureau (BIK) and its consequences.

The report’s call for market demonopolization carries particular weight because it comes from a team working under the supervision of Leszek Skiba. Between 2020 and 2024, Mr. Skiba served as chief executive of Bank Pekao – ironically, the largest shareholder of BIK, controlling 41.6 percent of its share capital.

UOKiK’s work as the catalyst for the report

One of the triggers for the debate on Poland’s credit information market has been the work carried out by the president of the Office of Competition and Consumer Protection (UOKiK) on a draft amendment to the Consumer Credit Act, which is intended to implement the relevant EU directive in Poland (CCD2). As we reported in XYZ, the draft attracted a total of 1,500 pages of comments. One of the issues raised most frequently concerns the way the credit information market operates in Poland.

Just before Christmas, the Office released 1,355 pages of tables responding to individual proposals – often, however, without providing any substantive reasoning. The market is likely to gain a clearer picture on January 20 and 21, when reconciliation conferences are scheduled to take place at UOKiK’s headquarters. Their purpose will be to hear proposals and suggestions submitted, among others, by organizations representing the financial sector.

Lenders verify customers against data repositories

The BIK issue surfaces in Article 30 of the draft Consumer Credit Act. This provision is a slightly more detailed version of Article 9 of the 2011 law currently in force. While the existing wording refers to the obligation to assess a customer’s creditworthiness before entering into a contract, the draft goes further. It specifies that a lender – whether a bank or a non-bank lending institution – must, before granting consumer credit, verify the borrower’s income and expenses in so-called data repositories.

Both versions of the law rely on the same definition of data repositories. Only two types of institutions are permitted to provide them.

The first is defined in Article 105(4) of the Banking Law. Under this provision, only banks, acting jointly with banking industry associations (namely the Polish Bank Association), may establish entities authorized to collect, process, and make available to banks and other institutions data covered by banking secrecy. According to the Sobieski Institute, it is precisely this provision that effectively blocks the creation of institutions that could compete with BIK.

The second category consists of so-called business information bureaus. These include BIG Infomonitor (controlled by the BIK Group), ERIF, the National Debt Register Business Information Bureau (KRD BIG), and the National Business Information Bureau (KBIG). These institutions collect information on overdue liabilities, but they do not have automatic access to credit data.

What differentiates the two legislative approaches is the potential involvement of a third type of provider. The amended version of the law that has been in force for more than two years allows lending institutions to rely on so-called trusted providers. These are entities offering account information services (AIS), such as Kontomatik, which provide access to data from bank accounts. The UOKiK draft removes this provision.

The Polish Financial Enterprises Association (ZPF), led by Marcin Czugan, hopes to persuade the authority to change its position during the forthcoming reconciliation conference. Similar demands have been put forward by the Polish Association of Loan Institutions (PZIP) and the Federation of Polish Entrepreneurs (FPP).

Exclusive reporting to BIK draws attention

Beyond requiring lenders to verify information in data repositories, the UOKiK draft introduces another significant change. At present, non-bank lending institutions are required to report the granting of a loan to BIK. However, any delay in repayment may be reported either to BIK or to one of the business information bureaus – or to all of them. Lenders have seven days from the date the delay occurs to do so. Under the draft, however, both banks and non-bank lenders would be required to report these categories of information exclusively to BIK.

“This means that BIK would receive a statutory obligation for banks and lending institutions to feed its own database, and then to process that data and sell it back to the very same entities from which it obtained the information,” one of our interlocutors points out.

Established in 1997, BIK has eight shareholders: in addition to the Polish Bank Association, nine universal banks, including PKO BP, Pekao, and ING Bank Śląski. As the Sobieski Institute notes in its report, however, BIK’s clients are not limited to its shareholders. They also include smaller players – cooperative banks, credit unions (SKOKs), and loan companies.

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“This means that these financial institutions have no choice and must rely on the services of an entity over which they have no influence, and which holds a monopolistic position in the area of credit scoring services. The UOKiK draft merely reinforces this situation. Once consumer data have been made available, a lending institution will also be required to report the full repayment of liabilities, their extinguishment, the determination that a liability does not exist or the correction of its amount, as well as newly incurred liabilities and any updates thereto,” the authors of the report argue.

Regulators push back against BIK’s information monopoly

Among those calling for a change to the provision is KRD BIG. In its comments, the institution – headed by Adam Łącki – has proposed retaining the reporting obligation while allowing lenders to choose the database to which such information would be submitted.

Industry feedback appears to have had an impact. In a November interview with XYZ, Tomasz Chróstny – the head of consumer watchdog – acknowledged that, after weighing the pros and cons, he had decided to adjust the authority’s approach.

“Initially, we assumed that information on incurred loans would have to be reported exclusively to BIK. However, we do not want to strengthen BIK’s information monopoly with respect to access to consumer data, including creditworthiness. That is why we will give lenders a choice,” the president of UOKiK said in the November interview.

In addition to market input, the shift in UOKiK’s position may also have been influenced by suggestions from Jacek Jastrzębski, chairman of the Polish Financial Supervision Authority (KNF). In a letter to the head of UOKiK, he wrote that “the authority has been receiving signals that the original version of the provisions undermines freedom of economic activity by making the operations of certain categories of lenders dependent on a private entity.”

Mr. Jastrzębski added that “without questioning the importance of BIK as a platform for the exchange of information among banks, in the KNF’s view it is worth considering whether the proposed definition of a data repository – combined with an expanded list of lenders and entities obliged to report credit data to BIK – remains optimal and appropriate.”

Some institutions call for demonopolization

In its report, the Sobieski Institute stresses that while the credit information market is built around BIK’s monopolistic position, the business information segment – where four business information bureaus operate – is competitive, and the activities of these entities are subject to oversight by a public authority.

“The ongoing work on the Consumer Credit Act is a good moment to reconsider whether the credit information exchange model created in 1997 is still optimal. In our comments on the draft, we proposed allowing business information bureaus to establish institutions as provided for in Article 105(4) of the Banking Law. Today, BIGs are technologically, financially, and organizationally strong institutions, and they are supervised by the minister of finance and economy. They operate under a dedicated, stringent, and well-developed legal framework. They are prepared to take on such a role. If we do not open this discussion now, the next opportunity may not arise for at least another ten years,” says Marcin Czugan.

A similar proposal has been put forward by the KNF’s Office in its submission. According to the supervisor, lenders other than banks should be allowed to establish institutions modeled on those set out in Article 105(4) of the Banking Law. At a minimum, this would involve reviewing the legislation to assess the possibility of granting credit register status to institutions other than BIK.

UOKiK: The proposal falls outside the scope of this regulation

Tomasz Chróstny, the head of Poland’s consumer watchdog, goes even further. Since March 2025, he has been conducting proceedings concerning BIK, examining creditworthiness assessment rules and their impact on lending terms. In an interview with XYZ, he indicated that he already has initial critical observations. In his view, a model in which such sensitive data are fully controlled by an entity owned by eight of Poland’s largest commercial banks (the ninth shareholder being DNB Nord, a relatively small bank specializing in corporate clients) may not be conducive to market transparency or competitiveness.

“The Polish state should have a central register to which data from financing entities would be submitted. These data could then be selectively made available to financial institutions for the purposes of verifying credit applications and assessing creditworthiness,” the head of UOKiK argues.

In its table of comments on the draft Consumer Credit Act, however, the Office remains cautious. It states that proposals to open up the credit information market – submitted by ZPF, KRD, and KBIG – were not taken into account. The reason given is that they fall outside the scope of this regulation. This suggests that, in the authority’s view, any potential unblocking of the market should be addressed in a separate legislative act.

According to Leszek Skiba, the issue requires thorough debate. The current model has ceased to be attractive both for BIK’s clients and for customers of banks and lending institutions.

“When will changes occur? It is hard to say. What is certain is that a substantive discussion is needed on competition in this market, as well as on supervision and data security. We will not avoid this debate, and it should result in sound legislative changes,” he told XYZ in a comment.

Sobieski Institute: more bureaus mean lower costs

The Sobieski Institute’s report, prepared under the supervision of the former CEO of Pekao, is frequently cited by Adam Łącki. He argues that all lenders rely on the scoring model of a single provider – BIK – and that the market has no effective way to verify that model.

“Only competition would create real pressure to improve data quality, enhance the credibility of models, and reduce service costs. From lenders’ perspective, the lack of competition translates into higher data acquisition costs, which are then passed on to consumers. In 2024, BIK’s sales profitability stood at 28 percent. Its net profit, meanwhile, was paid out in full to shareholders – that is, banks [and the Polish Bank Association]. This shows that a monopoly model results in very high profitability. If the market were competitive, costs would fall by around 30 percent, which would translate into a 37 percent drop in BIK’s revenues. These would be tangible savings for financial institutions and for customers,” Adam Łącki emphasizes.

In his view, relevant benchmarks should be sought abroad. In Germany, Italy, Spain, and Czechia, several credit bureaus operate side by side. They compete on data quality and the accuracy of scoring models – and above all, on price. France is the only exception, with a single bureau, but it is worth noting that this is a state-owned institution.

“Demonopolization is a step toward more comprehensive, integrated information, enabling a more reliable assessment of risk. Bringing business information bureaus into the group of entities that create credit registers would strengthen the system’s resilience. Competition, in turn, leads to greater transparency and reduces the risk of systemic exclusion. This is a reform in the public interest, not a private one,” Łącki argues.

“Introducing competition would not threaten the security of the system – on the contrary, it could strengthen it through the exchange of experience among market participants, greater transparency of operations, and broader public oversight,” the report concludes.

BIK’s CEO points to a range of global models

We asked Mariusz Cholewa, president of BIK since June 2013, to respond to the proposals. He begins by distinguishing between two areas of the credit process in which data processed by BIK are used. In both, he argues, BIK is not the sole source of information.

The first is credit risk assessment – that is, estimating the probability that an obligation will not be repaid. This is based, among other things, on the history of loan and credit repayments, analysis of payment transactions, data from business information bureaus, and public registers. The second area is the assessment of creditworthiness carried out by the lender. In addition to the sources mentioned above, this requires information on a consumer’s income and expenses. Such data can be obtained not only from BIK but also from other financial-sector institutions, such as AIS providers.

Since May 2020, Mr. Cholewa has also chaired ACCIS, the international association of credit information bureaus. He explains that ownership models vary across markets. In Romania, Croatia, and Turkey, credit bureaus are established directly by banks. In France and Belgium, the register operates within the central bank. In Finland and Sweden, by contrast, private entities are active in this field. He acknowledges that there are markets where competition among credit bureaus exists, but argues that this can create challenges that some countries are now grappling with.

“In countries where credit information is fragmented, debates emerge about centralization. In the United States, for example, there is an ongoing discussion about whether it is really necessary to rely on as many as three separate registers to properly assess creditworthiness and credit risk. Suggestions have been made to reduce costs by limiting the system to two bureaus. The question, however, is whether this would not ultimately be to the detriment of consumers,” Mariusz Cholewa notes.

ZBP: Fragmented information can be harmful

As our interlocutor points out, in the United Kingdom – where competition among credit bureaus is high – financial institutions most often verify data with just one bureau. This creates a risk that positive or negative credit history held by another bureau may not be taken into account when assessing creditworthiness and credit risk.

This can result in some clients with heavy financial obligations receiving funding beyond their means, potentially falling into a debt trap. Conversely, other clients may be denied credit because their positive credit history is overlooked.

Agnieszka Wachnicka, vice president of the Polish Bank Association (ZBP), highlights a similar risk. She argues that lenders’ access to complete, reliable, and integrated data on clients and their repayment capacity is crucial for the proper functioning of the market.

“Fragmented information that hinders the assessment of creditworthiness and reliability would weaken consumer protection and increase the risk of over-indebtedness. In recent years, the credit register has been systematically expanded to include additional categories of entities, so that it can maintain the most comprehensive database of financial market information possible,” Ms. Wachnicka adds.

Rejecting claims of price drops and market improvement

The BIK president emphasizes that the bureau’s revenues grow alongside the volume of inquiries and increasing client activity in areas such as fraud prevention, data analytics, and services for both individual and corporate customers.

He does not directly address concerns about the high profitability of the monopoly. He merely notes that profitability has remained at a similar level for years and reminds that BIK, as a public trust institution, also carries out numerous projects related to financial education.

He does, however, respond to the Sobieski Institute’s expectation that competition would lead to lower prices. In his view, this assumption is a major misunderstanding. The cost of credit inquiries across multiple bureaus will always be higher than using a single one. He points to ongoing discussions on this topic in the United States.

“Any responsible lender, when making a credit decision, would have to query all active registries rather than just one, as is currently the case. This is more likely to increase, rather than reduce, costs. It could, in turn, translate into higher prices for financial services,” confirms Agnieszka Wachnicka.

Demonopolization does not mean cheaper services

The head of BIK stresses that if the market were fragmented, banks and non-bank lenders would have to decide which bureaus to query and how much information to request.

“One argument in the report assumes that BIK’s monopoly makes services more expensive. That is not true. Costs rise when it is impossible to properly assess risk, because institutions cannot then distinguish reliable clients from potentially problematic ones. In that case, risk costs are spread across all customers. With a single reliable register, it is cheaper,” the BIK president notes.

He adds that currently all banks, lending companies, roughly one-third of leasing firms, and nearly all deferred payment providers report to the bureau.

BIK does not yet have data from debt collection companies. However, it has proposed, during the ongoing work on the Consumer Credit Act, that purchasers of receivables be required to report as well. This would allow the bureau to complete information on the “customer lifecycle” within the financial sector. According to UOKiK’s table of comments, BIK’s proposal has been accepted, paving the way for the bureau to gather an even larger volume of data.

Key Takeaways

1. BIK and ZBP reject claims of cost reduction. Both BIK and the Polish Bank Association (ZBP) reject the argument that opening the market to competition would lower the cost of individual credit inquiries. BIK president Mariusz Cholewa calls this a major misunderstanding. Agnieszka Wachnicka, vice president of ZBP, adds that in a competitive scenario, any responsible lender would need to query all active registries rather than just one. The result? Costs would rise rather than fall.
2. Sobieski Institute pushes for demonopolization. Encouraged by UOKiK’s ongoing work on the draft Consumer Credit Act, the Sobieski Institute, led by Leszek Skiba, former CEO of Pekao, issued a report calling for the demonopolization of Poland’s credit information market. Similar proposals come from the Polish Financial Enterprises Association and the National Debt Register (KRD). The Polish Financial Supervision Authority (KNF) has also weighed in, noting in its comments that the original draft legislation threatens business freedom by making the operations of certain lenders dependent on a private entity – BIK.
3. UOKiK adjusts its position partially. UOKiK has agreed to a partial shift: lenders will now report not only to BIK but also to business information bureaus (BIGs). However, the regulator remains cautious regarding full demonopolization, stating that the proposal falls outside the scope of the current legislation. UOKiK president Tomasz Chróstny admits that a model in which sensitive data are held by BIK – controlled by banks – raises concerns. His suggested solution is the creation of a state-run central register.