2026 Financial Market Amendment: Changes for Currency Exchange Offices, Currency ATMs, and Payment Service Providers 

22 June 2026, the Ministry of Finance published a draft act amending certain acts in order to develop the financial market and increase financial stability in this market. This is a broad sectoral amendment that covers, among others, credit institutions, the Bank Guarantee Fund (BFG), Currency Exchange Offices and automated currency exchange machines, bCurrency Exchange Offices agents, payment service providers, cooperative savings and credit unions (SKOK), and regulations concerning reference benchmarks.

What changes does the 2026 Financial Market Amendment introduce?

The draft amends over 20 acts regulating the financial market. The largest block of changes concerns the BFG, i.e., the institution responsible, among other things, for the deposit guarantee scheme and the resolution of specific financial market entities.

The draft strengthens the BFG’s tools related to assessing the resolvability of domestic entities. The Fund is to be authorized to oblige an entity to cooperate on resolution plans, conduct inspection visits, request documents and explanations, and gain access to ICT systems and other information carriers.

A significant part of the draft also concerns Currency Exchange Offices activity. The proposed definition determines that Currency Exchange Offices activity is a regulated economic activity consisting in the buying and selling of foreign exchange values, including by means of an automated currency exchange machine. This means bringing automated currency exchange machines under the regime of Currency Exchange Offices activity, which entails registration, record-keeping, and information obligations.

The draft also specifies the requirements for individuals performing activities directly related to Currency Exchange Offices activity. Completing a course covering legal and practical issues related to bureau de change activity is still intended to be one of the methods to confirm qualifications, but the certificate of course completion will have to come from an entity whose scope of business includes conducting training activities in this area. Until now, the regulations did not formulate this requirement explicitly.

Another novelty is the explicit regulation of bureau de change agents. Currency Exchange Offices activity may be performed by an entrepreneur through an agent acting on their behalf. The basis is to be an agency agreement concluded in writing under pain of nullity. Only an entrepreneur who meets the statutory conditions and is entered into the register may act as an agent. Currently, the register maintained by the National Bank of Poland has not included such data.

Significant changes also apply to the Payment Services Act. The draft provides that Article 106a of the Banking Law shall apply mutatis mutandis to specific payment service providers, i.e., electronic money institutions and their branches, payment institutions, and small payment institutions.

In practice, this means extending to these entities the mechanism for responding to a reasonable suspicion that funds may originate from or be linked to a crime. This involves, among other things, notifying a prosecutor, the Police, or another competent authority, the possibility of freezing funds for up to 72 hours, and further actions by the authorities regarding suspending transactions or freezing accounts.

This is not an entirely new requirement imposed on payment service providers, as they already hold the status of obliged entities under AML/CFT frameworks, which entails the necessity of taking analogous measures when suspicions regarding transactions arise.

Payment institutions (including small payment institutions) and the electronic money institutions covered by the amendment should review their internal procedures, in particular the rules for identifying suspicious funds, making freezing decisions, documenting the grounds for such decisions, and communicating with law enforcement authorities.

The draft also organizes the methods for determining reference benchmarks, which is particularly important for credit agreements and financial instruments. In the case of mortgage loans, a mechanism is provided to replace the existing benchmark with a substitute along with a spread adjustment, and with respect to certain variable-rate agreements, an obligation to present the borrower with an offer to change the method of interest rate calculation.

The amendment aims to mitigate legal risks associated with replacing a discontinued reference benchmark with a new index along with a spread adjustment.

How can you prepare for changes in currency exchange operations?

Currency Exchange Offices should verify whether their adopted operating model corresponds to the draft requirements. This applies particularly to entities using automated currency exchange machines or agents. On the other hand, entrepreneurs who already perform bureau de change activity through agents or by means of automated currency exchange machines should prepare to implement the changes during the transitional period.

The draft provides for 6 months from the entry into force of the act to submit an application for entering agents or machines into the register of bureau de change activity.

Due to the broad and multi-threaded scope of the draft, it is crucial to determine which of the proposed changes actually apply to your business and which operational areas may require alignment.

How can a company prepare for financial market reforms?

We assist financial institutions, payment service providers, currency exchange offices, ATM operators, and entities subject to AML/CFT obligations in assessing the impact of the proposed amendment on their operations. We help translate the new requirements into specific implementation measures, including the review and update of internal procedures, documentation, reporting policies, and operational processes.

For payment service providers, we analyze procedures for identifying suspicious funds, making decisions to freeze funds, and communicating with law enforcement agencies. We also assist lending institutions, lenders, and other entities that use reference benchmarks in determining which contracts or financial instruments may require adjustment.

Contact us to find out which proposed changes affect your business and how to prepare your procedures, documentation, and operational processes before the new regulations take effect.