On 28 March 2025, the Steering Committee of the National Working Group for benchmark reform in Poland (NWG SC), appointed in July 2022, accepted an updated Roadmap for replacing WIBOR and WIBID benchmarks. 

The adoption of the updated Roadmap is a consequence of the review and analysis of risk-free rate (RFR) alternatives to WIBOR – a process finalised in December 2024 and concluded with the decision to select the Polish Short-Term Rate (POLSTR®), a proposed index based on unsecured overnight (O/N) deposits made by credit institutions and financial institutions, as the ultimate interest rate benchmark to replace the WIBOR and WIBID benchmarks.

The updated Roadmap ensures that the benchmark replacement process complies with the Benchmarks Regulation (BMR)¹. The purpose of the benchmark reform in Poland is to allow a safe and efficient transition to a new type of benchmark, which is to be applied from the end of December 2027. 

The key milestones for 2025 include formal adoption of the entire documentation required by the BMR in relation to the proposed POLSTR® index, and the launch of POLSTR® publication. The achievement of the second milestone, scheduled by GPW Benchmark S.A. for the second quarter of 2025, will allow the application of the proposed POLSTR® index to be commenced in the Polish financial market. Parallel activities will be carried out to update the analytical documents and recommendations prepared by the NWG so far. Those documents and recommendations will define the standards for the application of the proposed POLSTR® index in banking products, debt instruments, and derivatives, including a recommended list of interest rate conventions for financial instruments and financial contracts (including the ones already concluded). The major tasks for financial institutions will include the adaptation of IT systems, operational procedures and legal solutions related to the application of the POLSTR® index. 

As regards popularisation of the proposed POLSTR® index, the key moment will be the first issuance of POLSTR-referenced PLN treasury bonds, planned for December 2025. The event will be an impulse for financial market participants to begin in the first half of 2026 of introducing POLSTR index to their offer of all types of financial products. In particular, banks will begin offering mortgage products as well as other loans for consumers, corporate and institutional clients at a compound interest rate based on the ultimate POLSTR® reference rate, while the market segment of mortgage loans with fixed or temporarily fixed interest rate will be growing further.

In 2026, the debt market will see the launch of issuances of own bonds, including bank bonds, corporate bonds, and municipal bonds, based on the POLSTR® index or a fixed interest rate. National and foreign clearing houses with the CPP status (KDPW_CCP, LCH, etc.) will achieve regulatory and operational preparedness and start to centrally clear OIS derivative transactions for which POLSTR® will be the interest rate benchmark. In consequence, the derivatives market will shift from the phase of bilateral transactions to the phase of centrally cleared transactions. The OIS market will gradually achieve the required liquidity, necessary to build the term structure for POLSTR®.

Activities have been planned for the entire duration of the benchmark reform to educate market participants about the implementation of POLSTR®. The NWG SC points out that the educational activities must be addressed to both consumers and professional counterparties. The fulfilment of conditions for a regulatory event as described in Article 23c(1) of the BMR will be verified in 2026. The occurrence of a regulatory event will initiate a statutory procedure resulting in the enactment of a Regulation of the Minister of Finance which will indicate the replacement of the WIBOR critical benchmark. The provisions of the Regulation of the Minister of Finance will also define the adjustment spread and the date from which the replacement applies. 

Regulation of the Minister of Finance will enter into force after vacatio legis period, which will guarantee an appropriate time for the adaptation to the Regulation. The replacement specified in the Regulation of the Minister of Finance will apply to financial contracts and financial instruments that meet the requirements laid down in the BMR. The replacement and the adjustment spread specified in the Regulation of the Minister of Finance will be applied in contractual interest rate clauses in such financial contracts and financial instruments (which have not been subject to contractual conversion, including as recommended by the NWG). The objectives of the NWG’s modified Roadmap provide for the preparedness to cease to determine and publish WIBID and WIBOR reference rates from early 2028.

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The NWG SC emphasises that the Roadmap had to be modified due to the results of the review and analysis of RFR alternatives to WIBOR. The benchmark reform in Poland is still based on the assumption that the financial sector must shift from the application of WIBOR and WIBID to newly concluded financial contracts and financial instruments being based on POLSTR® or a fixed or temporarily fixed interest rate. Therefore, the NWG SC confirmed the end of 2027 as the final deadline for conversion. The NWG SC will be monitoring the execution of the key elements of the Roadmap to ensure that the entire process is effective and that optimum conditions are created for the development of the financial market in Poland.

The key elements that guarantee the success of the reform include: creation of conditions for the development of a liquid market of spot instruments and derivatives using a chosen RFR benchmark for the Polish zloty (PLN), operational and technical preparedness of all financial market participants (issuers, investors, market infrastructure providers) for the replacement of WIBOR and WIBID benchmarks with RFR benchmarks, and implementation of necessary amendments to the Polish and EU legislation. It is also important to raise awareness of the reform and its consequences among financial market participants, particularly consumers, and to create conditions for the development of the financial market that reduce the exposure of certain financial contracts and financial instruments to interest rate risk. 

The NWG SC found that the current deadline for reform completion allows appropriate time for creating conditions for promoting and disseminating the application of RFR benchmarks in financial contracts and financial instruments, considering operational, technical, communication and legal aspects, which is a cornerstone of the development of the domestic financial market and its’ greater resilience.

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¹Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014.