Director Kowalska has led the newly created Non-Bank Lending Institutions Department at the UKNF since September 2023. From January 2024 the Department has been in charge of the supervision of more than 100 non-bank lending institutions. 

‘I look at the market of non-bank lending institutions from a broad perspective. I can see that you are looking for ways to optimise your business, also using the latest technologies which are often at the interface of several regulatory frameworks: in particular the lending and the payments framework. We want to support you in these efforts. We all care about the development of the market of non-bank lending institutions and of the payments market. We want this market to develop in a sustainable manner, securing the interests of customers and those of entities providing financial services in the best possible manner. 

The staff of the Department which I manage take part in the work of the EBA working groups, including a working group dedicated to consumer protection. We have noted an increased interest from the EBA in the issues related to the method of creditworthiness assessment by non-bank lenders. This results from the new adopted creditworthiness assessment rules under the CCD II and from the problem of over-indebtedness  of consumers, identified by the EBA in the latest consumer trends report for the years 2022/2023, resulting from improper creditworthiness assessment, among other reasons.

We are following the work on the AI Act  where systems used for evaluating creditworthiness have been classified as high risk systems. We expect that in the near future the EBA will take interest in the issues of creditworthiness assessment also in the context of the use of the latest technologies, including artificial intelligence. It is our ambition to participate in this work on an ongoing basis, so that our supervisory and regulatory approach takes account of all the current developments.

With the new regulations we are approaching a revolution in the area of open finance. Our traditional scope of competence as financial supervisor is now expanding and covering new areas. We are already looking at the FiDA package which is waiting for its turn to have a supervisory authority designated. The UKNF may become the competent supervisory authority under FiDA for financial market entities. The question of whether it will be entrusted with the supervision over a new type of entity, the Financial Information Service Provider (FISP), remains open. However, given that the data which are going to be used will come mainly from financial institutions and also judging by the fact that the Regulation provides for the EBA’s mandate to mediate, if necessary, between competent authorities, a possible scenario of the UKNF being designated as the competent authority for the FISPs has to be taken into consideration.

Ultimately, we can be perceived as the supervisor of data or supervisor of access to data. And we are preparing for that. We have built the Regulated Data Analysis Centre. We want to be ready for new challenges dictated by the needs of the market.

I would like to know how non-bank lending institutions orientate themselves in the payments market, how they make use or want to make use of open finance. I would like to emphasise that this issue is of interest to me also in the context of consumer protection and benefits to the consumer. In this area I can see the opportunity for increased competitiveness and transparency in the offers of entities which propose their products and services in the financial market, for the effective use of data from different sources for the purpose of creditworthiness assessment or customer needs identification. 

The Polish financial market, as seen both by entities and customers, is a leader in innovation. We are open to new solutions, we not only follow new trends but often are the ones to set them. A good example here is the BLIK system. This project has shown that we have to think and act boldly – a bold plan to create our own domestic payment system independent of global card institutions has proven to be a great success and is a proof, in my opinion, that bold plans are worth realising. Currently we are keeping our fingers crossed for a global expansion of our solutions. This technological and business openness of the Polish market means also that open finance has plenty of opportunities for growth in our market’, Director Kowalska said.