Today, 19 October 2026, there is exactly one month left until a hard EU deadline: from 20 November 2026, the new consumer credit rules under Directive (EU) 2023/2225 (known as CCD2) must be applied across the European Union. Yet the Polish law meant to implement them has effectively stalled since May 2026, after the government stripped the head of the Office of Competition and Consumer Protection (UOKiK) of the lead on the project and withdrew it from further legislative work. For anyone taking out a cash loan, using 0% instalment plans in online shops, or relying on "buy now, pay later" services, this is not an abstract legislative dispute - it is a direct question about which consumer protections will actually apply to them a month from now, and which will not.
What actually happened
The draft of the new consumer credit act, listed in the government's legislative schedule as UC82, was prepared by UOKiK. It reached the Government Legislation Centre in July 2025, went through public consultations and inter-ministerial coordination, and a revised version incorporating some of the feedback was published on 13 March 2026. UOKiK President Tomasz Chróstny said at the time that the government stage of the process would be completed by July 2026, after which the bill would move to the Sejm (the lower house of parliament).
Things turned out differently. On 18 May 2026, Prime Minister Donald Tusk revoked the UOKiK President's authorisation to lead the implementation of the EU's CCD2 directive and the directive on distance marketing of financial services. As a result, according to a letter from the Secretary of the Standing Committee of the Council of Ministers reported in late May 2026, the draft act was withdrawn from further work by the Committee for European Affairs. No official reason was given beyond the decision itself - what is known is that UOKiK lost its role as legislative lead on the file.
This is not just a bureaucratic footnote. It means that right before the EU rules start applying, Poland does not even have a government-approved draft bill in place - let alone an act that would still need to pass through the Sejm, the Senate, and receive the President's signature. Poland has already missed the directive's transposition deadline of 20 November 2025. Now a second, more consumer-relevant date is approaching: 20 November 2026, when the CCD2 rules are due to actually start applying.
What the bill would have changed, and why it was controversial
A higher threshold for consumer credit
Today, consumer credit rules - including the mandatory creditworthiness assessment, a clear pre-contract information form, and the right of withdrawal - apply to loans up to PLN 255,550. The UC82 draft would have raised that ceiling to the equivalent of EUR 100,000, roughly PLN 433,000 at the NBP reference rate. In practice, that would bring more expensive car loans or home-renovation loans fully under consumer protection, something they currently lack once they exceed the existing threshold. This was one of the few changes that consumer organisations broadly welcomed.
Three tiers of the "free credit" sanction
The second major element was a redesign of the so-called "free credit sanction" - the penalty under which a lender who breaches the rules can only recover the principal, without interest or fees. The draft would have made the penalty proportionate to the severity of the breach: a full sanction (principal only) for the most serious violations, a softer version (principal plus half of the contractual interest) for lesser information failures, and a separate sanction for cases where credit was granted without the consumer's application or consent at all. The Polish Financial Supervision Authority (KNF), however, called the consultation process "illusory" and argued that some of the proposed solutions went further than the directive itself requires. The Polish Bank Association (ZBP) added that too short an implementation window would not give banks enough time to properly adapt their lending processes.
BNPL left out of full protection
Perhaps the most surprising - and most criticised by consumer groups - feature of the March 2026 draft was that it left "buy now, pay later" (BNPL) services outside the definition of consumer credit. Market estimates based on data through the end of October 2025 put the full-year 2025 value of BNPL transactions in Poland at roughly PLN 14 billion (up from PLN 10.7 billion the year before), and more and more online shoppers use these services, often without realising they are taking on debt. Leaving BNPL outside the full consumer-credit definition would mean it is not automatically covered by safeguards such as a mandatory creditworthiness check or the same right of withdrawal that applies to an ordinary cash loan.
What this means for your wallet right now
Until the new act is passed, the existing 2011 Consumer Credit Act remains in force, with its lower PLN 255,550 threshold and today's single-tier free-credit sanction. If you are planning a cash loan, financing a larger purchase, or using deferred payments in an online shop, the terms you are offered will not change overnight on 20 November - any change depends on when, and in what form, the Polish parliament actually passes the new rules. While you wait, it is worth comparing current offers: compare cash loans by their real annual percentage rate rather than just the advertised instalment.
The BNPL dispute is also a good moment to look at your own deferred payments: if lawmakers cannot agree on whether it counts as credit, you should treat it as if it does - with a repayment date in your calendar and a limit you do not cross. A sensible complement is a cash buffer set aside for emergencies; check current savings account rates before reaching for another deferred payment. If you rely on an overdraft on your current account, it is also a good habit to check regularly whether your personal account still makes financial sense - variable-rate clauses in revolving limits were themselves the subject of a separate, widely reported Polish consumer-protection case against one of the country's largest banks this year.
What happens next
As of the publication of this article, there is no confirmed information that work on the draft has formally resumed under new legislative leadership, nor that a new timetable for the Sejm has been set. That creates a real risk that, on 20 November 2026, Poland will enter the period when the EU's CCD2 rules apply without its own adapted legislation in place - creating legal uncertainty for banks and lenders as well as for consumers, who in a dispute might try to invoke the directive's provisions directly. It is worth watching announcements from UOKiK and the Government Legislation Centre over the coming weeks, since they will show whether, and in what shape, Poland catches up.
What you should do
- Do not wait for the new law to check the terms of a loan you already have - the existing Consumer Credit Act still applies, and it still gives you the right to early repayment or to challenge unfair clauses.
- If you are planning a cash loan in the coming months, compare the APR of several offers rather than focusing on the monthly instalment - a cash loan comparison lets you do this quickly.
- Treat deferred payments (BNPL) as real debt, regardless of whether they end up fully covered by the consumer credit definition or not.
- Build or top up your financial cushion before reaching for another deferred payment or overdraft limit.
The consumer credit act will eventually be passed - the question is whether that happens before, or long after, the EU deadline. Until then, your best protection remains reading the contract carefully and comparing offers before committing to one.
Sources: the CCD2 Directive 2023/2225 transposition and application deadlines (osborneclarke.com/pl/ccd-ii); Prime Minister Donald Tusk's 18 May 2026 decision to revoke UOKiK's authorisation and the withdrawal of the UC82 draft (bankier.pl - UOKiK odsuniety, Sejm interpellation no. 17249 of 19.05.2026, money.pl - Minister Berek ostro do prezesa UOKiK); the proposed EUR 100,000 (approx. PLN 433,000) threshold, the KNF's "illusory" assessment of the consultations, the ZBP's position and the three-tier free-credit sanction (finwire.pl/artykuly/ustawa-kredyt-konsumencki-2026-uokik-pod-ostrzalem-knf-deadline-20-listopada); the 2025 BNPL turnover estimate for Poland (dudkowiak.pl/blog/platnosci-odroczone-bnpl-pod-kontrola-nowe-przepisy-juz-w-2026-roku); UOKiK's DOZIK-1/2026 decision against PKO BP over variable-rate clauses in revolving credit-limit annexes (bank.pl - UOKiK nałożył 79,3 mln zł kary na PKO BP).