Pavel Latushka Submitted an Appeal to the Polish Financial Supervision Authority Requesting Clarifications Regarding the Blocking of Mobile Banking Applications for Belarusians by Polish Banks

Photo source: inwestycje.pl

In connection with the recently emerging situation of Polish banks blocking mobile banking applications for citizens of Belarus who are staying in Poland without valid residence permits, Deputy Head of the United Transitional Cabinet and Head of the National Anti-Crisis Management (NAM), Pavel Latushka, informed the Polish Financial Supervision Authority (hereinafter – KNF) about this situation on 19 November 2025 by submitting an appeal requesting clarifications on the justification of such actions by Polish banking institutions.

At the same time, on 4 December Pavel Latushka sent a request for a meeting with the management of PKO Bank Polski in order to discuss the situation that has arisen.

In his appeals, Pavel Latushka explained that thousands of Belarusian citizens are legally staying in Poland and are awaiting further legalization on the basis of a residence permit. The legality of their stay follows from Article 108 of the Act on Foreigners:

"A foreigner’s stay on the territory of the Republic of Poland shall be considered legal from the day the application is submitted until the day the decision on granting a temporary residence permit becomes final".

The appeal also emphasizes that references by Polish banking institutions to EU sanctions as grounds for refusing to service bank accounts of Belarusian citizens who do not hold a valid residence permit are unfounded and constitute excessive compliance with banking requirements (overcompliance) and cannot serve as grounds for measures such as blocking mobile banking applications (accounts) for Belarusian citizens legally staying in Poland.

At the same time, Pavel Latushka sent appeals to the Polish Financial Ombudsman, as well as to the European External Action Service and the European Commission’s Directorate-General for Financial Stability, Financial Services and Capital Markets Union (FISMA).

It should be noted that previously, in its responses, the KNF emphasized that Belarusian citizens may be classified as a group of clients with increased risk; however, refusal to establish business relationships or a decision to terminate them cannot be justified solely by classifying a client as high-risk. Therefore, before taking such decisions, banks must ensure that they have considered all possible risk-mitigation measures. Each decision to refuse to establish or to terminate a business relationship must be justified and documented. It is not permissible to automatically consider all clients from one group as equally high-risk without an individual assessment. Such an approach may be deemed unjustified by the KNF.

In view of the fact that in some Polish banking institutions there have been cases of refusal to open or extend accounts on the basis of a Temporary Foreigner’s Identity Certificate (hereinafter – TZTC), Pavel Latushka once again submitted an inquiry to the KNF.

Previously, in response to an appeal by Pavel Latushka, the KNF provided written clarification stating that the TZTC is an identity document on the basis of which a bank account may be opened (KNF letter of 17 June 2025). Following this, Belarusian citizens who had applied for international protection began to have bank accounts opened on the basis of the TZTC.

It should also be noted that Belarusians living in Poland had previously faced problems with opening and blocking bank accounts. These problems arose due to overcompliance by banks with regard to citizens of countries subject to EU or Polish restrictive measures.

In particular, Belarusian citizens who were clients of Santander Bank faced restrictions on the use of mobile banking applications and bank accounts in the spring and summer of 2024.

At that time, Santander Bank required clients to hold a residence permit in any EU country with a validity period of at least 12 months. In the absence of such a residence permit, the bank blocked mobile applications and online banking.

From the letter received from the KNF in response to Pavel Latushka’s inquiry, it followed that the bank’s actions were not a requirement of the Polish authorities or a consequence of European sanctions.

Decisions on additional requirements imposed by the bank on its clients were taken by the bank itself. As explained by the KNF, such decisions depend on many factors based on risk management principles.

The KNF also recommended at that time that the bank’s clients seek advice from the Financial Ombudsman or regional consumer rights ombudsmen. Ultimately, the problem with the blocking of banking applications and accounts at this bank was resolved.

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