ESG – a regulatory imperative and a new dimension of risk management

Sustainable development has ceased to be an element of financial institutions’ image strategies. ESG has become firmly embedded in the language of regulation, supervision and risk management, emerging as one of the key factors influencing banks’ stability, access to capital and the assessment of portfolio quality. What only a few years ago functioned as an area of voluntary commitments and good practices, now constitutes one of the foundations of the banking sector’s operation in the European Union. ESG has ceased to be an add-on to strategy – it has become an integral part of it.

What ESG is and why it matters for the financial sector

The ESG acronym refers to three interrelated areas used to assess business and financial activity. E stands for environmental factors, including climate impact, energy consumption, greenhouse gas emissions, buildings’ energy efficiency and the exposure of assets to physical and transition risks. S, the social dimension, includes, among others, the quality and safety of the surrounding environment, access to public infrastructure, the impact of investments on local communities, as well as living and working conditions. G represents corporate governance, understood as the way an organisation is managed, the transparency of decision-making processes, the quality of internal controls and the ability to identify and manage risk. In banking, all of these elements translate directly into financial stability, client credibility and the long-term value of collateral.

The EU regulatory revolution as a turning point

A turning point for the banking sector was the intensification of legislative action at the European Union level. The EU Taxonomy, the SFDR Regulation and the CSRD Directive have clearly shifted ESG from the realm of good practice into the sphere of hard legal obligations. Banks have been required to report not only their own impact on the environment and society, but also the risks and exposures arising from clients’ financed activities. This means the need to analyse entire credit and investment portfolios in terms of alignment with climate objectives and sustainable development standards. Complementing this regulatory landscape is the Omnibus Package, the purpose of which is not to reduce ESG requirements, but to organise and harmonise them. The emphasis has been placed on regulatory coherence, comparability of indicators and the quality of the data used in reporting. For banks, this means moving away from fragmented, manual processes and building unified, resilient information systems capable of supporting both supervisory requirements and management needs.

ESG as an integral part of risk management

In this context, ESG has ceased to be solely a reporting area and has become an integral element of risk management. Climate, environmental and social risks are increasingly materialising within classic banking risk categories – credit, market and operational. ESG risk on the client side, in practice, becomes the bank’s risk, affecting creditworthiness, collateral values and long-term portfolio stability.

Real estate and ESG data

Within banks’ ESG activities, the real estate market has gained particular importance, as it is one of the largest components of credit portfolios, while also being one of the key sources of energy consumption and greenhouse gas emissions in the economy. Real estate largely determines the environmental profile of a bank’s portfolio and its alignment with the European Union’s climate objectives, which in practice means the need to systematically obtain and integrate data on buildings’ energy efficiency, technical characteristics, functional standard and exposure to physical and transition climate risks. This information is necessary not only for reporting alignment with the EU Taxonomy or calculating financed emissions, but also for a realistic assessment of the long-term value of credit collateral, because banks must now take into account the risk of value decline for energy-inefficient properties, the costs of future upgrades and the impact of regulatory changes on asset liquidity and attractiveness.

At the same time, one of the greatest challenges of the ESG transformation remains the quality and availability of data, especially with regard to older property stock and historical portfolios, which the Omnibus clearly identifies as a key element in assessing the credibility of reporting, promoting an approach based on a smaller number of precisely defined, comparable indicators and the growing role of specialised external data sources.

The ESG report prepared by the AMRON Centre as a response to banks’ needs

A response to these needs is the ESG report developed by the AMRON Centre, comprising 46 attributes dedicated to residential buildings in Poland. The scope of the report was preceded by a needs assessment of the banking sector, which clearly indicated demand for reliable data on environmental risks and the quality of the property’s surroundings. The report provides standardised, comparable and auditable information on all residential buildings in Poland, covering both the building itself and its immediate surroundings. The collected data include, among others, energy efficiency, CO₂ emissions, heating sources, sustainable construction certificates and the availability of social and transport infrastructure. They are complemented by information on potential nuisances and environmental risks. The entire solution has been designed so that it can be used directly in banks’ reporting, analytical and decision-making processes.

The use of ESG data in the banking and financial sector includes, among others:

  • assessing the exposure of the real estate portfolio to climate and environmental risks,
  • identifying properties eligible for green financing,
  • supporting compliance processes with regulatory requirements such as the EU Taxonomy, CSRD or EBA guidelines,
  • building credit risk assessment models that incorporate ESG factors.

ESG as a competitive advantage for the financial sector

Under conditions of growing regulatory pressure, ESG ceases to be solely a cost of compliance and becomes a lasting element of banking’s regulatory and management landscape. For financial institutions, this means not only the need to meet supervisory requirements, but above all the opportunity to improve risk management, build stakeholder trust and develop sustainable financial products. Banks that already invest in data quality and the integration of ESG factors into decision-making processes gain a tangible competitive advantage and greater balance-sheet resilience over the long term. In this context, access to reliable, up-to-date and comparable ESG information ceases to be support and becomes a condition for the effective and stable functioning of the financial sector in the years ahead.

Klaudia Jastrzębska
Buildings Database Project Coordinator

Poland – an European housing market perspective

The European housing market is a complex organism, responding to shared impulses – decisions of the European Central Bank, shifts in inflation, global economic crises or demographic trends, yet in practice it remains a mosaic of several dozen highly diverse national markets. Differences between them are visible not only in price levels and rent rates, but also in investor activity and housing affordability. These disparities stem from a range of factors, the most obvious of which is the wealth of societies. High housing prices in countries such as Luxembourg, Switzerland, Denmark or the Netherlands are not merely the result of speculation or limited supply – above all, they reflect high wages and stable demand. In these countries, housing is something society can afford, even if purchasing it requires a mortgage spanning several decades. By contrast, in South-Eastern Europe, where incomes are much lower, housing prices are also lower in absolute terms, yet homes remain difficult to access.

Income differences, of course, do not explain everything. Regulatory and institutional factors are extremely important as well. European countries apply very different approaches to residential real estate markets. In some states the market is strongly regulated, particularly with regard to renting, tenant protection and rent controls. Germany and Austria are examples: while regulations stabilize the market, they can also limit investors’ willingness to build new housing. In other countries, such as Ireland or Spain, regulations are more liberal, which supports investment but increases the risk of rapid rises in prices and rents.

Central and Eastern European countries operated for decades under centrally planned economic systems, where a real estate market practically did not exist and housing was allocated through administrative decisions. The political and economic transformation of the 1990s created a market almost from scratch, often without adequate regulations, institutions or experience. As a result, many states in the region are still catching up in terms of infrastructure, urban planning and institutional frameworks, while a high share of owner-occupied housing, a low level of institutional rental supply and a strong role of individual investors remain characteristic features of those markets. Such conditions make them much more prone to sharp price increases during boom periods and more sensitive to changes in credit policy.

An important factor differentiating European housing markets is demographic structure. Ageing societies in Western and Southern Europe have different housing needs than the younger populations of Central and Eastern Europe. In countries with a high share of elderly people, demand for new housing is weaker and the market more often focuses on renovating the existing stock. Conversely, where the population is growing or where migration to cities is intense, demand pressure is much stronger. Internal and international migration is today one of the most important drivers of regional differences. Large cities attract young people, students and foreign workers, which pushes up prices and rents, while smaller towns and peripheral regions often struggle with depopulation and price stagnation. This is closely linked to urbanisation – another element that significantly affects European housing markets. In countries such as France, the United Kingdom or Spain, population concentration in a few major metropolitan areas is very high, creating enormous pressure on the housing markets of Paris, London or Madrid. In countries with more polycentric settlement structure, such as Germany or Italy, demand is distributed more evenly, limiting extreme price growth in individual cities. This helps explain why Munich, Hamburg or Frankfurt are expensive, but price differences between them and other major German cities are not as dramatic as in France.

When listing the most expensive European capitals, one cannot ignore the role of foreign investors. Housing in many European cities has become a global investment asset. International capital flows into London, Paris, Barcelona or Lisbon, treating real estate as a safe haven. This phenomenon affects Central and Eastern European markets to a much smaller extent, although in Poland’s largest cities a significant inflow of foreign capital during the 2006 – 2008 boom was clearly observed. External capital increases competition for a limited number of homes, raises prices and worsens availability for local residents.

Another factor differentiating housing markets is the role of tourism and short-term rentals. In cities such as Barcelona, Lisbon, Venice or Dubrovnik, a significant share of the housing stock has been converted into short-term rental apartments. This has reduced the supply of homes available to residents and contributed to rising prices and rents. In response, many cities have introduced regulations limiting this segment of the market, but their effectiveness varies. In countries, where tourism plays a smaller role, this factor is far less important, showing how local conditions can shape market dynamics.

Finally, differences between housing markets stem from varying social expectations of housing as a good. In some countries, housing is primarily a place to live, while in others it is a key element of wealth building and financial security. Where real estate is treated as a long-term investment, demand is more resistant to economic fluctuations and prices rise faster. Where renting and mobility play a larger role, the market is more flexible and less prone to sudden surges.

So what are the real differences between the housing markets of European countries and cities? To answer this question, it is worth looking at the Deloitte Property Index report. The report is based on data from local Deloitte offices and official national sources. As a result, the analyses cover not only general trends, but also local markets and the comparison includes thirty countries and more than seventy of Europe’s largest cities.

One of the key elements of the report is an analysis of construction intensity, i.e. the number of completed homes per 1 000 inhabitants. In 2024, the clear leader in this area was Turkey, where nearly seven homes per 1 000 inhabitants were delivered (6.85). This result was almost twice as high as the average across the surveyed countries, which stood at 3.61. Interestingly, the next places were taken by Ireland (5.62) and Poland (5.33), which also maintained strong momentum in housing construction, driven by population growth and ongoing urbanisation. Israel recorded the same developer output ratio as Poland. At the other end of the ranking are Bosnia and Herzegovina, Hungary and Spain. In all of these countries, less than two dwellings per 1 000 inhabitants were completed during the period – 1.04, 1.39, and 1.78 respectively.

In absolute numbers, Turkey also ranked first, with nearly 587 000 homes completed in a single year. That is more than 250 000 more than second-placed France (330.4k) and more than twice as many as Germany (252.0k). Poland, with nearly 200 000 completed homes, ranks fourth, ahead of the United Kingdom by 46 000 homes. The lowest construction volumes were recorded in Bosnia and Herzegovina – 3 400 new homes, as well as in Slovenia – 5,100. Interestingly, when viewed against earlier years, Bosnia and Herzegovina was the country with the strongest growth in housing construction. The year-on-year increase in completed homes between 2023 and 2024 amounted to 17.6%.

A comparison of housing prices across European countries also shows a very high level of market diversity. On one hand, there are countries with exceptionally high prices, led by Luxembourg, where the average price of a new home exceeded EUR 8.7k per a square metre. Prices are only slightly lower in Israel, the United Kingdom, Austria and Portugal, where they are close to EUR 5k per a square metre. Interestingly, this group also includes the Czech Republic, where the average price reached  EUR 5 030 per square metre – clearly higher than in countries such as Germany or the Netherlands. On the other hand, there are South-Eastern European countries such as Turkey or Bosnia and Herzegovina, where prices do not exceed EUR 1 500 per a square metre.

Despite the record growth dynamics at the level of 19.3% annual increase, the average housing price in Poland was clearly lower than in the most expensive European countries, reaching EUR 2 792 per a square metre, slightly above the average price recorded in Italy (EUR 2 741). This result places Poland roughly in the middle of the European ranking. However, what clearly sets Poland apart from most markets, is the pace of price growth. According to the report, Poland recorded the highest price increase among all surveyed countries – 19.3% year on year. This growth resulted from several overlapping factors: strong demand stimulated by a loan programme supporting the purchase of a first home (“2% Safe Mortgage”), insufficient housing supply in the largest cities and a noticeable appreciation of the Polish zloty against the euro, which raised prices when expressed in the European currency. Poland’s position in the European real estate market is therefore quite specific – it combines rapidly rising prices with a still relatively low price level compared with Western Europe.

AVERAGE HOUSING PRICE GROWTH (2024)

source: author’s own elaboration based on the Deloitte Property Index 

At the city level, the most expensive European capitals turned out to be Luxembourg and Paris, where average prices exceed the threshold of EUR 10 000 per a square metre. In Amsterdam, Inner London and Jerusalem, prices were slightly above EUR 8 000 per a square metre. The cheapest capital included in the study was Ankara, where a square metre of a new apartment can be purchased for approx. EUR 1 000. It should be noted, however, that this result was largely driven by a significant depreciation of the Turkish lira against the euro. Among European capitals, the lowest housing prices were recorded in Bucharest (EUR 1 757/sqm.) and Sarajevo (EUR 1 823/sqm.).

AVERAGE PRICE PER SQUARE METRE OF HOUSING IN EUROPEAN CAPITALS (AND ANKARA AND JERUSALEM)

source: author’s own elaboration based on the Deloitte Property Index

In most cases, capitals are also the most expensive cities on national housing markets. There are, however, exceptions to this rule. The most expensive German city included in the report was Munich, where the average price per square metre reached EUR 10 800 (i.e. by EUR 3 600 more than in Berlin). Housing prices in Barcelona were the highest in Spain (EUR 7 859 per square metre), while the highest average price per square metre in the entire ranking was recorded in Tel Aviv – an impressive EUR 13 970.

In the ranking of annual price growth across the surveyed city markets, a strong Polish accent appears once again. The city with the highest increase in the period analysed was Cracow, where prices rose by more than 28%. Authors of the report attribute this increase to strong demand and simultaneous limited supply, as well as the impact of the programme supporting the purchase of a first home. In Jerusalem, price growth exceeded 25%, driven primarily by high demand. In Albania, rising prices in Tirana and Vlorë result from a major inflow of foreign investors and the development of the tourism sector, which strengthens demand for housing both as an investment and as second homes. Several cities also recorded clear price declines, with the deepest drops observed in Turkey, especially in Izmir and Ankara. This was influenced by high interest rates and reduced credit availability, which weakened domestic buyers’ demand, as well as by changes in the exchange rate of the lira.

Housing affordability across individual cities is also very interesting. The report uses an indicator showing how many average annual salaries are needed to purchase a 70-square-metre apartment. The lowest affordability among the analysed cities was recorded in Amsterdam, where more than fifteen annual salaries were required for this purpose. A similar situation was observed in Athens and Prague. In many other Central European cities like Brno, Košice, Ljubljana or Budapest, buying an apartment requires nine to twelve average annual salaries. This group also includes Warsaw, where purchasing the model apartment would require 9.7 average annual salaries, as well as Wroclaw and Cracow (both at 9.3). The most affordable Polish city included in the report is Katowice, where the model apartment requires 7.1 average annual salaries. Across Europe, the most affordable markets turn out to be Scandinavian and British cities with relatively high wages, such as Odense, Aarhus or Manchester, where purchasing a 70-square-metre apartment requires only five to six annual salaries. The ranking is closed by Turin with a result of 4.9.

The most interesting aspect of the overall picture, however, lies in the conclusions that emerge from data on prices, supply and financing costs. In many countries, housing shortages persist, especially in large cities that attract residents thanks to jobs, education and services. High prices do not deter buyers, but they do change behaviour: the importance of long-term renting is growing, as is institutional rental housing, which in many countries is increasingly seen as an important market segment. Affordability will not improve significantly until construction activity increases and wages begin to rise faster than the cost of living and land prices. Importantly, many countries are introducing regulatory measures: restricting short-term rentals, offering incentives for social housing construction and reforming spatial planning. These actions will not solve all problems, however investments in infrastructure, demographic structure, labour migration and the broader macroeconomic situation also play a major role. Europe’s housing market is therefore a mosaic shaped by a set of historical, economic and cultural conditions. Differences between countries and cities are not a temporary phenomenon, but the result of long-term processes. Although Europe is currently facing similar challenges: housing shortages, rising living costs, and urbanisation pressure, responses to these problems will certainly differ from country to country. Each market will react in line with its structure, history and institutions.

Jerzy Ptaszyński
Research and Market Service Director

Cards on the table: how the year 2025 ended the age of secrecy on Polish residential market

The year 2025 has redefined the Polish residential market by introducing far-reaching transparency mechanisms. It is an unprecedented moment, when after years of lack of transparency, Polish lawmakers made this sector more translucent. This unparalleled level of openness is the result of not one, but three key pieces of legislation, which, in just a few months, have fundamentally reorganised the rules of data accessibility. Yet, revealing the data is only half of the success – genuine “total transparency” requires more than free access: it requires competence.

For many years, the Polish primary market was characterised by significant information asymmetry that favoured developers. A widespread problem was the strategy of not quoting the offer prices directly. To obtain information about the price, a potential buyer had to call, ask or arrange a meeting at the sales office – a deliberate mechanism for building informational advantage.

At the same time, access to transaction prices – essential for objective verification of the market value of a property – was limited. Data from the Real Estate Price Registers (RCN) were subject to fees and their disclosure was inconsistent, which hindered large-scale analytics and well-informed purchase decisions.

The year 2025 has brought a structural change by simultaneously strengthening transparency on two key levels:

  1. offer side – mandatory disclosure of offer prices on the primary market, including full price history;
  2. transaction side – abolition of fees for access to prices registers and the launching the government Residential Transactions Data Portal (DOM), which liberalises access to data on transaction prices.

With offer prices becoming public and transaction data being opened up, the market is moving from a model based on secrecy to full verifiability. This is a real source of power for buyers, but also a major challenge for the entire sector, which must adapt to the new reality.

Transparency of offer prices

The amendment to the Act on Protection of the Rights of a Buyer of a Residential Unit or Single-Family House and the Developer Guarantee Fund (the so-called “Developer Act”), which entered into force in stages starting from July 11, 2025, has radically increased transparency on the primary market by imposing on developers a strict obligation to publish complete and reliable information on each project. These provisions were introduced gradually: at first they covered new projects started after the Act’s entry into force, and from September 11, 2025 the obligation to disclose prices has applied to all apartments and houses offered for sale, regardless of the date when sales began.

This is the end of empty listings and negotiating in a vacuum. Developers now have a clearly defined list of information that they must disclose on their dedicated websites, namely:

  • the price per square metre of usable floor area and the full (gross) price for each residential unit or single-family house and for ancillary premises (parking space, storage unit),
  • all other monetary consideration that the buyer is required to pay to the developer, which aims at eliminating hidden costs that previously often surfaced only in the final stages of the transaction,
  • the price history of a given unit – the biggest change in the developer – buyer relationship. A potential buyer can now verify the developer’s pricing policy, which significantly strengthens the buyer’s negotiating position and protects against price manipulation.

The obligation to disclose offer prices significantly increases transparency and provides greater consumer protection. The new regulations have the potential to limit developers’ tendency to raise prices frequently and sharply. Public prices eliminate the possibility of differentiating prices based on a subjective assessment of the customer (for example, their market awareness or urgency to buy) – a practice regarded as unfair. Potential buyers gain the ability to easily compare offers, which shortens the property search process and reduces the need to contact the sales office just to find out the starting price. As a result, when price differences between projects are small, non-financial attributes, such as location, infrastructure or access to services become more important in the purchasing decision.

However, price transparency is not without its downsides. First, a client, who sees a high starting price, may decide not to get in touch at all, losing the opportunity to negotiate a discount or additional benefits directly. Second, the regulations do not define a single mandatory standard for presenting data. The client still has to analyse individual offers on his own, which is time-consuming and requires considerable effort. And third, full visibility of competitors’ price lists makes it easier for developers to monitor the market, which may lead to informal alignment of offers and, in some segments with limited supply, may paradoxically weaken competitive pressure and foster price increases.

Contrary to concerns articulated by some parts of the industry, the entry into force of the price transparency provisions in July and their extension in September 2025 did not trigger sudden, sharp changes in average offer prices. In most of the analysed cities, only small downward adjustments in offer prices of between 1% and 3% were recorded. This was not a direct effect of the Act itself, but rather of accelerated, preventive standardisation of price lists by developers, who wanted to avoid chaos and accusations of unfair practices once their prices became fully public.

Interestingly, this breakthrough in transparency coincided with a revival in demand in the third quarter of 2025, driven, among other factors, by a cycle of interest rate cuts. This means that growing demand is no longer “deaf” to prices. Clients with access to full price lists and transaction data are radically better informed, which has the potential to discipline the pace of price growth even in an environment of rising interest in buying homes.

Free RCN data

While price transparency is a revolution for the primary market, liberalising access to RCN data is a revolution for all market participants. The true market value of real estate is shown only by the transaction price – that is, how much was actually paid.

The amendment to the Geodetic and Cartographic Law, signed by the President on November 4, 2025, fully abolishes fees for the use of transaction data collected in county Real Estate Price Registers (RCN). Although it will not enter into force until February 12 next year, this change is a promise that the most valuable market data will become a universal, free public good. Removing fees is a change of fundamental importance. The previous model, based on paid access (with a fee for each transaction), limited the widespread use of these data to financial institutions, property valuers and professional analysts.

However, it must be remembered that RCN data does not always fully reflect the current market situation due to significant delays in entering data into the IT systems. Several months may pass between the date of signing the notarial deed and the moment this information is made available in the RCN. In addition, the registers do not store data from development agreements and prices from final transfer-of-ownership contracts on the primary market are the result of negotiations conducted even two years earlier. Therefore, data from RCN databases have limited value for people, who want to understand the current situation on the market. Moreover, errors and mistakes unfortunately occur in the registers quite frequently – for example, a missing zero in the price. For this reason, abolishing fees alone, without simultaneously improving data quality and speeding up the process of feeding the registers, may deliver mainly a reputational effect rather than real analytical benefits.

MAP 1: TIMELINESS OF ENTERING TRANSACTIONS INTO THE RCN

source: https://www.gov.pl/web/gugik/kontrola-bazy-rcn

The problem is also that instead of being a single central database, the RCN is in fact a mosaic of 380 separate registers, each maintained independently by a county or city with county rights. Although these data are collected in digital form, not all county offices provide information electronically. While the Regulation on Land and Building Records obliges counties to provide RCN data online via web services, at present only 95 counties comply with this requirement. That is barely one quarter of all county offices.

Regardless of the fact that the “data for zero PLNs” principle will soon be in force, the question of how access to the RCN will actually be delivered remains unresolved. If the current model based on submitting individual requests is maintained, in the face of mass interest it risks significantly slowing down the work of offices and generating delays. On the other hand, making resources available exclusively via WMS/WFS services, although desirable for analysts, would restrict access to information for non-professional users, who do not have advanced visualisation tools.

The DOM Portal

In parallel, the government is working on launching the DOM Portal. The creation of a central, government-run and free-of-charge tool providing access to data on actually concluded residential property sale transactions, both on the primary and secondary market, is a key element of another amendment to the Developer Act, signed by the President on November 27, 2025. The launch of the portal is planned within 16 months from the promulgation of the Act.

The information collected by the DOM Portal will come from three sources: the Developer Guarantee Fund records, data supplied by developers and other professional entities involved in property sales, as well as notarial deeds provided by the National Revenue Administration (KAS). The portal will therefore show sale prices not only from notarial deeds, but also from development agreements.

The new tool will operate in two access models:

  • for all users (it will allow browsing statistics of transaction prices with filtering options by location, property type, usable floor area or number of rooms),
  • for public entities (extended access, crucial for analysing market turnover in the context of designing housing policy support instruments).

The effectiveness of the DOM Portal depends not only on how quickly data are updated, but above all on data quality, completeness and presentation. To protect personal data, individual users will not have access to information on specific transactions, but only to aggregated statistical results (based on at least six transactions). This makes it particularly important how the data are presented – whether they are understandable for end users. The greatest risk for the market does not lie in lack of access, but in insufficient interpretation of the data. Simple information on the average price per square metre is not enough. We need indicators that make it possible to assess the distribution and reliability of the data – so that the users knows whether they are dealing with a homogeneous market or with a set of transactions with high variability, where averages may deviate significantly from individual prices.

The trap of free data

The key issue, regardless of the platform (RCN or DOM Portal), is the origin, quality and timeliness of the data. Even the most advanced technological solution will not fulfil its role if the data are delayed, incomplete or difficult to interpret.

Opening up access to the RCN is a milestone, but free access to data does not mean free knowledge. For the average “Kowalski”, raw transaction data – even structured within the DOM Portal – will remain just statistics and medians. This is because they lack context. Analysing transaction prices requires specialist skills that makes it possible to account for key differences:

  1. transaction context: Was the transaction a “bargain” (e.g. a family sale, a sale by a receiver or trustee, a quick distress sale)? Raw data will not reveal this.
  2. condition and standard of the property: the RCN records the price, but will not tell us whether the flat required immediate investment, was in shell condition or after a full renovation. The difference in price per square metre between these states can be enormous. Or perhaps the property was subject to legal encumbrances?
  3. GDPR-driven aggregation: to protect privacy, transaction data in the DOM Portal must be aggregated (for example at neighbourhood level). This aggregation blurs details – the difference in value between a flat overlooking a park and one overlooking the bins, although crucial for the final valuation, is invisible in aggregated statistics.

For this reason, the transparency revolution does not make experts obsolete – it forces them to evolve. They must change their business model and move from being mere data providers to advanced analysts and contextual experts. Their added value will now lie in interpreting the data, comparing public list prices with transaction data and making precise valuation adjustments based on experience and context.

The next step – the Electronic Property Card

Despite the huge leap made in 2025, to achieve total transparency comparable with markets that have the highest standards, such as Sweden or Norway, we must combine price data with full information on the legal and physical status of the property.

This is where the postulate of introducing an Electronic Property Card (EKN) comes in. Although the EKN was not part of the 2025 legislative package, it is a logical consequence and the next key step in the market’s digital revolution. The EKN would be a digital “passport” for a property, integrating all key information in one easily accessible place – price data, legal status from the land and mortgage register and complete technical data – eliminating the need to repeatedly search multiple official registers.

Such a card would eliminate hidden legal and technical risks, which are often a bigger problem than the price itself. Only when the buyer has not just free information on the price, but also easy access to a full picture of the legal and technical status, will we be able to speak of the end of information asymmetry and true transparency.

Price transparency and market stability

It is worth looking at fully transparent markets such as Sweden and Norway, where property sale prices are publicly available. Similar rules also apply in Western European countries including Finland, Denmark, the Netherlands, Germany, Switzerland and the United Kingdom. In these countries, price information is usually easily accessible in public registers, often free of charge or for a small fee.

Analysing such markets provides valuable insights into the impact of transparency on price dynamics. Despite full transparency of transaction prices, the Swedish housing market experienced its deepest crisis in decades in 2022 – 2024, with house prices falling by almost 20% and flat prices by more than 10% compared with the 2022 peak (based on HOX Sweden Price Index reports). The price fluctuations were driven by rapid interest rate hikes by the Riksbank to curb inflation and the high share of variable-rate mortgages, which left many households exposed to rising costs. This example proves that price transparency does not protect the market from declines triggered by macroeconomic factors. On the contrary – it can accelerate market correction. Negative information is immediately absorbed by all participants, allowing the market to reach equilibrium more quickly. Full transparency eliminates price inertia, making the market more efficient and quicker to respond to economic realities.

Conclusions

Poland is becoming a market of prices transparency. Three legislative changes are creating a powerful foundation that enforces discipline on developers and empowers buyers.

  • For buyers, this will be a good time to purchase, because they have never before had so much knowledge and bargaining power. But they must remember: data without proper interpretation are just numbers.
  • For developers, it is a signal that they need to switch to a business model based on trust and discipline rather than on withholding information. The legal risks associated with errors in price lists are too great to ignore.
  • For professionals, it means the end of being “the gateway to data” and the beginning of being “experts in data interpretation”. Those, who fail to adapt, will disappear from the market.

Liberalising access to the RCN and introducing transparency of list prices is a key foundation – but only integrating these data with information on the technical condition (for example via the EKN) and developing the skills needed to use them will give us genuine transparency.

Agnieszka Pilcicka
Senior Real Estate Market Analyst

The Shelter Act and its impact on new construction projects

Poland’s current geopolitical situation has prompted the government to intensify efforts related to national defence. One of the key steps aimed at preparing society for potential threats, such as war, natural disasters or terrorist attacks, was the adoption, in December 2024, of the Act on Civil Protection and Civil Defence, commonly referred to as the “Shelter Act.” This legislation defines in detail, how civil protection and civil defence are to be organized, including the obligation to prepare suitable infrastructure known as collective protection facilities. The Act distinguishes three types of such facilities:

  • Shelter – a protective structure or part of a structure with a closed, airtight design, equipped with air filtration and ventilation systems or regenerative absorbers.
  • Hideout – a protective structure or part of a structure that is not airtight.
  • Temporary sheltering places – collective protection facilities adapted for the temporary protection of people.

The planning and establishment of such crisis infrastructure are primarily the responsibility of public administration authorities. To this end, they must designate existing or planned buildings (like schools, hospitals or government/ municipal offices) to serve as collective protection facilities. The Act specifies in detail the rules for their use, registration and technical conditions.

However, the private sector, particularly developers, will also play an important role in creating collective protection facilities. According to Article 94 of the Shelter Act: “The underground storeys of public utility buildings or multi-family residential buildings, as well as underground garages, if not designed as protective structures, shall be designed and constructed in such a way as to enable their use as temporary sheltering places.”

This provision therefore imposes an additional obligation on developers to design and build structures that can serve, at minimum, as temporary shelters in the event of an emergency. Multi-family buildings and underground garages, in addition to their regular functions, will thus be usable during crisis situations.

This requirement will come into force soon — it will apply to investments stated from 1 January 2026. According to Article 206 of the Shelter Act: “Articles 93–95 shall apply to any construction project for which, after 31 December 2025:

  • an application for a building permit or for the approval of a site development or architectural design has been submitted;
  • a construction notice has been filed in cases where a building permit is not required.”

From the developers’ perspective, the key concern is the technical requirements for temporary shelters, as they directly affect both construction costs and project timelines. Such facilities must, among other things:

  • have adequate structural strength,
  • provide effective ventilation, acoustic and thermal insulation,
  • ensure fire safety,
  • include evacuation routes and backup power systems,
  • be equipped with utilities,
  • include wastewater disposal systems.

Detailed technical requirements for temporary sheltering places are specified in the Regulation of the Minister of Interior and Administration of July 9, 2025 on organization and requirements of temporary sheltering facilities.

The introduction of mandatory temporary shelters will extend and complicate the investment planning process and increase construction costs. However, under Article 106 of the Act, building owners or managers may apply for targeted grants to adapt their buildings for use as temporary shelters. These subsidies may cover up to 100% of the additional costs incurred due to the protective requirements, but such financing will be optional, not guaranteed. Consequently, in the event of a refusal, there is a significant risk that property prices will rise, as developers will likely pass on the additional costs to buyers.

From the developers’ standpoint, this obligation represents a costly new challenge. Yet, under normal circumstances, such spaces could also be used as utility or service areas, which may enhance the overall value and attractiveness of the property. From the buyers’ perspective, the combination of residential and protective functions in a single building could also significantly improve the sense of safety and security.

Monika Kubisz
AMRON System Coordinator

Suburbanisation – escape from the city or a road to nowhere?

Just a decade ago, buying a house outside the city was perceived as a compromise. Today, it has often become an end in itself – a symbol of comfort, independence and living closer to nature. Suburbanisation, once regarded mainly as a social phenomenon, has become one of the driving forces of the real estate market. It has changed how we think about space, investment, and what truly constitutes a “good place to live.”

What exactly is suburbanisation? Suburbanisation is nothing more than the spreading of cities – the migration of residents from city centres to their outskirts and neighbouring municipalities. The phenomenon is not new, but in Poland it gained momentum after 2000 and the COVID-19 pandemic further accelerated this process. As remote work became a daily reality rather than an exception, many people realised that they no longer needed to live in the city centre to function comfortably in their professional lives. Cities such as Warsaw, Cracow, Wroclaw and Poznan are expanding towards their surrounding municipalities. As a result, entirely new “towns” are emerging, like Lesznowola near Warsaw, Zabierzów near Cracow or Długołęka near Wroclaw. These areas are becoming the new hubs of housing and investment growth.

The reasons why Poles are leaving cities are complex. The simplest one is economic. For the price of a two-room flat in a major city, one can buy a plot and build a house just a few kilometres away. This is followed by the growing desire for space, peace, privacy and contact with nature – values that urban centres often lack. The shift in work culture has also played a major role. The hybrid office model means many people now commute to the city only two or three times a week rather than on a daily basis. In such circumstances, a 30-minute commute is no longer a major obstacle. Increasingly, families conclude that since they already work remotely, they can live where they truly want to. Data published by Statistics Poland (GUS) show that more and more residents are moving from city centres to suburban and rural areas, which is reflected in positive net migration rates in those regions.

What are the implications of suburbanisation for the real estate market? The suburbanisation process has profoundly reorganised the landscape of property development. In suburban municipalities, demand for land and single-family homes is increasing. Developers, who only recently focused on building apartment blocks in city centres, are now investing in small housing estates of terraced or semi-detached houses. These new projects often take the form of semi-urban enclaves – with internal streets, small recreational areas and well-developed infrastructure. Buyers expect not only floor space, but also functionality, accessibility and proximity to services such as nurseries and shops within walking distance. Consequently, self-sufficient micro-communities are emerging around major cities.

However, the phenomenon also has a darker side. The influx of residents to suburban municipalities puts immense pressure on local infrastructure – roads, water systems, schools and public transport. Local governments often struggle to keep up with spatial planning, resulting in chaotic development and losing the urban order. The uncontrolled sprawl of cities is a visible problem. Polish suburbs largely consist of houses built without consistency or coordination, often lacking proper planning and access to basic utilities. The absence of sewage systems, narrow roads and a lack of pavements are everyday realities in many new housing estates.

Suburbanisation also leads to increased car dependency. Each resident of a suburban enclave becomes almost bound to a private vehicle, which translates into traffic congestion, noise and pollution. In the long run, this may reduce the attractiveness of these areas – especially if no corresponding investment in public transport follows. There are also financial consequences. Dispersed development poses challenges for municipalities – higher maintenance costs for infrastructure, difficulties in operating public transport and rising administrative expenses. Without a coherent strategy, suburbanisation may become an economic burden.

In response to these challenges, new trends and directions in suburbanisation have begun to emerge. Fortunately, the concept of sustainable suburbanisation – so-called smart suburbs – is gaining attraction. This approach encourages municipalities and developers to plan space proactively, ensuring that roads, sewage systems, public areas and services are in place before houses are built. Modern suburban estates are meant to be more than just “bedroom communities” – they are designed as places, where social life can thrive. Ecological solutions such as solar panels, rainwater retention systems, community gardens and electric-vehicle charging stations are becoming increasingly common. Good examples include municipalities like Michałowice near Warsaw or Wieliczka near Cracow, where spatial policies aim to combine residential, recreational and service functions. This direction can reconcile market development with care for the environment and urban coherence.

What’s next for suburbanisation? For now, suburbanisation is unlikely to slow down. In the coming years, suburban areas will remain the main sites of residential investment. However, the profile of buyers is changing – fewer are seeking an “escape from the city” and more are consciously choosing a lifestyle that balances nature and infrastructure. Land prices in municipalities well connected to metropolitan areas are rising. There is also a growing share of premium projects – spacious houses with gardens built in standards applied in cities. Developers are learning that suburban clients expect quality, not compromise.

In the long term, however, suburbanisation may face limits. Rising transport and energy costs could encourage some residents to move back closer to city centres. Meanwhile, cities that invest in revitalisation and green spaces may regain much of their lost appeal. The real estate market will become increasingly diverse, encompassing both conscious suburban lifestyles and the return of some residents to urban cores.

Summary

Suburbanisation is now one of the key forces shaping the Polish real estate market. It is no longer a by-product of urban growth – it has become a deliberate life and investment strategy. It offers great potential, but also entails responsibility. If municipalities and developers act wisely, suburbanisation can enhance quality of life by providing more space, greenery and community. But if it continues chaotically, in a few years we may pay the price in congestion, pollution and spatial disorder.

Suburbanisation is no longer a marginal aspect of urban life – it is becoming its future. The key question is whether we will manage to plan the growth of suburbs wisely before they begin to overwhelm the cities themselves.

Karol Kacprzak
AMRON III Project Manager
Specialist in Analysis and System Development

Real estate agent – a helpful assistant or an unnecessary cost?

The real estate market in Poland is developing very dynamically and buying, selling, or renting an apartment or house is, for most people, the most important financial decision of their lives. In light of this, the question often arises: is it worth using an agent’s services or is it better to act independently and avoid additional costs? The answer is certainly not clear-cut – it is worth analysing both the advantages and disadvantages of working with a real estate agent.

Who is a real estate agent?

A real estate agent is a person or company that helps with buying, selling, or renting properties. The role of the agent is to find a suitable offer or client, conduct negotiations and provide formal and legal support throughout the transaction.

Advantages of working with a real estate agent

Experience and industry knowledge

An agent knows the realities of the market and can accurately “value” a property, avoiding situations when the price is set too high (and the listing “sits” for months) or too low (leading to financial loss). An experienced broker also understands local trends – he knows, which locations are developing and where prices may rise.

Not everyone feels confident in negotiations. An agent has experience in dealing with buyers and sellers, can find compromises and looks after their client’s interests.

Broad access to offers and clients

Real estate agencies have their own databases and extensive networks of contacts, enabling them to quickly find suitable properties. They also use paid listing services, allowing the offer to reach a larger audience. As a result, sales or rentals are usually faster and smoother than when handled independently.

Negotiations and transaction security

Real estate transactions are prone to formal errors or the signing of unfavourable contracts, which makes an agent’s support very important. A professional agent works with notaries, lawyers, and mortgage advisors, ensuring the client feels secure at every stage of the transaction.

It is often the case that an agent detects irregularities in documents, such as unresolved land ownership issues or hidden debts, protecting the buyer from serious future problems.

Saving time and reducing stress

Buying or selling an apartment requires lots of preparations: listings, photos, arranging viewings, verifying documents and conducting negotiations. It is a time-consuming and patience-demanding process. An agent takes over much of this workload, allowing the client to focus on work or private life.

If the purchase is financed with external institutions, an agent, working with a mortgage advisor, helps to select the most favourable and suitable loan offer. The agent also handles the collection and submission of all necessary documents – from the client to the advisor and then to the bank – ensuring that the entire process runs smoothly and without additional burden.

Disadvantages of using a real estate agency

Additional costs

A broker charges a commission for his services, usually between 1% and 3% of the transaction value. For some, this is a significant expense. In large cities, such as the capital, where a studio apartment can cost even one million PLN, a 3% commission amounts to PLN 30 000 – enough to buy a small used car for the new garage.

Risk of unprofessionalism – “give me the commission and I’ll set up a notary appointment”

Since the deregulation of the profession, many agents with varying levels of competence have entered the market. An unreliable agent may cause problems instead of helping. Often, their role is reduced to presenting the property and arranging a notary appointment, but the job should be much more than that.

An agent should thoroughly examine the property’s legal status, all its advantages and disadvantages, and pass this knowledge on to the client, who may not realize the obstacles involved in buying or selling (e.g. due to unresolved legal issues). Buying a property is a serious investment and when hiring an agent, we expect that their professional expertise will protect us from unpleasant surprises.

“I won’t show you the property until you sign an agreement”

This is something property seekers often hear. For potential buyers, it means a lack of access to key information – listings may include photos of a plot or apartment, but without the exact location.

After calling the agency, it turns out that details will only be disclosed after signing a brokerage agreement. For many buyers, this is a barrier – they do not want to formally commit to an agent just to view a single property, which may not even meet their expectations.

During the search for the ideal apartment, buyers often view many different listings. Does this mean they must sign a separate agreement with each agent for every showing? For many, this is unacceptable – especially when high commissions are involved, which effectively discourage potential clients.

Working “both sides”

It is still a common practice for agents to act “on both sides” – representing both the seller and the buyer (or landlord and tenant) at the same time. While this may seem beneficial for closing a deal efficiently, it raises serious ethical concerns and risks of conflicts of interest.

An agent is obliged to act in the best interest of their client, but when representing both sides, true impartiality is difficult. What becomes crucial, therefore, is transparent communication about such an arrangement and obtaining consent from both parties – only then the brokerage may be considered reliable and fair.

Possibility of selling independently

The development of modern online listing platforms has greatly facilitated private sales or rentals without an agent. With easily accessible services, posting an offer has become simple and intuitive. In many cases, no specialist skills are required – it is enough to prepare a clear description, attach good-quality photos and set a price. What’s more, property owners value the direct contact with potential buyers or tenants, the ability to conduct negotiations themselves and lack of extra costs associated with paying an agent’s commission.

Lack of full control over the process

Some sellers prefer to decide how their property is presented. Working with agents means relying on their style and approach, which may not be comfortable for everyone. This loss of control over the sales process can be frustrating, especially when the owner’s expectations differ from the agent’s methods.

Summary

For some, a real estate agent is an invaluable assistant for others – an unnecessary cost. It is worth perceiving such services as an investment: if an agent helps to secure a higher selling price, avoid legal mistakes and save time, the commission will definitively be worth paying. However, if we feel confident dealing with clients and have enough free time, selling or renting independently can also be a good solution. The final decision should reflect our needs, capabilities and level of comfort in the transaction process.

Joanna Woźniak
Maintenance and Development Specialist

Prisoners of their own luxury – the concept of Urban Senior Homes as a solution to the municipal housing problem

An aging society is increasingly confronted with new everyday challenges. Old age itself can at times be burdensome and public healthcare is unable to keep up with the needs of a rapidly aging patients. This confronts seniors with even greater challenges. Many elderly people live alone, barely make ends meet and are in clear need of support with daily routines, such as shopping. Mundane situations suddenly become so troublesome that they hinder daily functioning.

Seniors have access to several forms of support. These include, among others, social welfare homes, day-care centres, universities of the third age and intergenerational activity centres. All of these forms of support, apart from social welfare homes, require a certain level of activity from seniors, forcing them to leave their homes and interact with other people. Yet, there are individuals who lack the motivation, willingness or simply the ability to participate in such activities. What about them? They either remain within their four walls or spend the rest of their lives in social welfare homes.

From a demographic perspective, our society has undergone structural changes over the past few decades. According to data published by the Central Statistical Office, in 1990 approximately 30% of Poland’s population was of pre-working age, while just under 13% were of post-working age. By 2010, the number of people in pre- and post-working age had equalized and over time the number of those in post-working age increasingly exceeded those in pre-working age. According to 2024 data, as much as 23.8% of the population were people of post-working age (almost one-quarter of society), while the youngest accounted for barely 18%. This structure is not promising, as the overall population of Poland is systematically declining, while the number of retirees and pensioners remains at a similar level. According to Statistics Poland (GUS) data, the number of retirees and pensioners in the period from 1999 to 2024 decreased by only 0.72% and currently stands at 9 384 579 (yes, almost 10 million persons).

Recent months have been a time of political turbulence. We all witnessed the fight for the office of the President of the Republic of Poland. During the heated election campaign, all candidates raised the issue of social and municipal housing. An increased number of municipal apartments would certainly support also seniors, but it does not solve the problem of loneliness or equal access to opportunities for activeness among seniors. The pool of municipal apartments is distributed among various social groups, such as people with extremely low incomes, people with disabilities or graduates of care facilities. This is a form of aid targeted at those most in need, which means that seniors, who already own their own apartments, usually do not qualify. Is there, then, no solution for the large group of seniors who remain in the shadow of their daily needs, overwhelmed by the necessity of maintaining both their apartment and themselves at a minimally decent standard?

One of the currently available options is the so-called reverse mortgage. This solution involves transferring the ownership right to a property to a bank or institution in exchange for a lifetime financial benefit. The main providers of such contracts are mortgage funds, which by the end of 2024 administered only 403 contracts, with just 18 new ones added that year. However, concluding a reverse mortgage agreement with a non-bank institution involves risk, as this area is not regulated by the state. Over the long term, a contract with a bank would be a better solution, but none of the leading banks in Poland currently offer reverse mortgages.

In recent months, a draft law on senior tenancy has been introduced. The idea assumes that a senior owning an apartment located on the third floor or higher in a building with no elevator could apply for a municipal apartment situated on lower floors, or higher floors in a building equipped with an elevator. The condition would be to lease their apartment to the municipality, which would then temporarily sublet it to people waiting for social housing. This programme gives seniors the opportunity to improve their living conditions and reduce barriers that hinder participation in social life, but it does not increase the number of apartments available to the city or municipality. Occupying municipal apartments by seniors would generate longer queues for social housing. Moreover, there is the risk that a senior might want to return to their own apartment (since it would only be a rental agreement), which would create the need to relocate tenants and restore the senior’s apartment to at least its original condition.

A new initiative currently being tested is senior cohousing. This solution assumes housing several unrelated individuals in one municipal apartment. The idea is directed at elderly people who, for various reasons, are no longer able to function in their current place of residence. Shared housing may be a remedy for daily life problems, but it will not be an ideal solution for all seniors. A lack of privacy and indirect dependence on initially strangers may not inspire enthusiasm among many of them. The idea is worth considering, but only as a complement to social policy in situations, when a city or municipality has a sufficiently large pool of social housing. Otherwise, it is worth asking, whether such a large apartment would not be more urgently needed by a large family in a difficult situation.

All of the above-mentioned solutions do not increase the number of apartments available to the city/ municipality and present seniors with challenges on many levels.

The idea of Municipal Senior Homes (MSH) is an original concept directed at seniors, who own their own apartments but need help with daily life. This concept assumes that, as part of city/municipality initiatives aimed at increasing the number of municipal apartments, residential blocks for seniors would be built, where round-the-clock nursing and basic medical care would be available, as well as daytime activities would be organized for seniors. A block built under MSH would resemble those developed by private developers, except that common areas would be adapted for people with disabilities – nothing new, since public facilities such as clinics, offices and other such institutions are already built under such requirements. On the ground floor of the building, commercial and service premises would be located to meet the basic needs of elderly residents. This would generate rental income for the city or municipality. The building would include a primary care physician’s office, where any resident could go if needed. The areas designated for organized activities could be used by institutions such as universities of the third age or activity centres without the need to rent private space.

On what terms would a senior receive such an apartment? The calculation would be simple: an apartment for apartment. A senior, who owns his own apartment, could enter into an agreement with the city or municipality, under which he or she would have lifetime use of an apartment in the Municipal Senior Home in exchange for the property rights to the apartment they currently own.

What are the benefits of such a solution? There are several:

  • The city or municipality gains a pool of apartments (those vacated by seniors) that can be allocated for social purposes, including assistance for large families. Seniors often own multi-room apartments that are too large for their needs. As part of the “exchange,” they would receive a smaller apartment, but with a “support package,” i.e. with access to a physician, a nurse and educational and social activities all in one place. When building Municipal Senior Homes, a minimum and maximum usable area of such apartments would be set, e.g. between 30 and 50 sqm. Naturally, most apartments previously occupied by seniors will require renovation or refreshing, but the costs would be lower than constructing equally large new apartments within municipal housing projects. Moreover, the city or municipality becomes the owner of the property. According to forecasts by the Statistics Poland (GUS), by 2050 seniors will account for approximately 40% of the population. Such dynamics mean that the pool of social housing suitable for seniors should systematically increase. If the city or municipality were to build social housing under the current model, the pool of available apartments would be divided among various social groups requiring such assistance.
  • The city or municipality becomes directly involved in helping seniors, who are currently left in the shadows. This is support that genuinely improves the seniors’ quality of life, as they are not left without care, enjoy the comfort of living in their own apartment rather than a room in a social welfare home and therefore can retain their independence and autonomy in managing their time. Forms of activity available in community rooms could bring generations together and provide seniors with spaces that were previously beyond their reach. New opportunities would encourage seniors to engage in social events.
  • Providing round-the-clock basic medical and nursing care would give seniors a sense of security and ensure assistance in emergencies.
  • The cost of maintaining an apartment in a Municipal Senior Home would be lower than in their current residence, both due to the smaller floor area and lower rent compared to housing cooperatives or homeowners’ associations.
  • The apartments taken over by the city/municipality would be located in different parts of the city/district, thus avoiding exclusion and marginalization of people using municipal housing in a single concentrated area.
  • Within a single investment involving the construction of a Municipal Senior Home, support would be provided to both seniors (who would receive a lifetime right to use an apartment in the Municipal Senior Home) and people in need of municipal housing (who would be allocated the apartment previously owned by the senior).
  • Ultimately, a smaller percentage of elderly people would be excluded from social life, their quality of life would improve and this could translate into greater activity on their part and at the end – the better health condition.
  • An agreement concluded with the city or municipality would guarantee the security of such a solution, significantly reducing the scale of fraud against seniors.

Demographic changes occurring over the years translate into new aspects that need to be addressed in social life. Adapting to these new realities is not an easy task, particularly from an economic perspective. One issue that has so far been treated marginally is the situation of elderly people, who are unable to live with dignity while supporting themselves and maintaining a home on a modest pension. Another issue is the promise to build a larger number of municipal apartments that would support those most in need. A partial remedy to the above-mentioned problems could be the concept of Municipal Senior Homes. This concept would benefit both seniors, who would gain a more comfortable living space, and municipalities/cities, which would acquire apartments that could be used for communal purposes. The non-concentrated distribution of residents occupying municipal apartments taken over under an agreement between the city/municipality and the senior would blur social disparities among residents. Existing forms of support for seniors overlook those, who, for various reasons, are prisoners of their own apartments. Relinquishing the right to their property in exchange for a lifetime opportunity to use an apartment in a Municipal Senior Home would solve many of the problems elderly people face today.

Through a single investment, cities and municipalities would gain access to secondary-market apartments with a larger floor area than newly built municipal apartments under current practices. The secondary use of apartments within Municipal Senior Homes over time would allow the city/municipality to manage a greater number of apartments than the actual number and size of those built under the programme. A simple calculation illustrates, how cost-effective this solution could be. In 2024, a total of 2 293 apartments were completed in cooperative, municipal, social rental, and company housing. If we assume that 2 200 such apartments will be added annually, then by 2040 the pool will increase to 35 200 units. If the same number of apartments were built under Municipal Senior Homes (MSH), then in addition to 35 000 apartments, the city or municipality would also have access to additional apartments acquired from seniors. Assuming that in the initial phase of the project, half of the MSH apartments would be occupied by seniors, the pool of municipal apartments would increase by over 16 000 units.

The costs associated with a senior’s use of an MSH apartment (i.e. rent) would be determined by the municipality/city. Currently, the social rent rate in Warsaw is PLN 2 per 1 sqm. of usable floor space, while the base rate for apartments included in the city’s housing stock is PLN 13.08 per 1 sqm. For comparison, the average cost borne by an owner in a housing community amounts to PLN 16 – 20 per 1 sqm. of usable floor space. Senior would cover utility bills as in their own apartments and rent would be charged at the rate established by the city/municipality.

For seniors, the benefit of living in an MSH would be peace of mind about their future and personal safety, while for municipalities and cities, it would mean access to a greater number of apartments for social purposes. The above concept may raise many doubts and generate dozens of questions. The most important, however, is whether such a solution would spark interest among the beneficiaries.

Agata Wróblewska
Maintenance and Development Specialist
Certified Property Appraiser (License No. 8247)

Interest rate cuts – catalyst for boosting the housing market

The first half of 2025 brought a breakthrough on the Polish real estate and mortgage markets, ending a prolonged period of high interest rate policy. After a long wait for signs of monetary easing, the Monetary Policy Council (MPC) made decisions that set a new direction. Although the nominal interest rate cuts in May and July 2025 were moderate, their significance went far beyond a simple adjustment of values. The MPC’s resolutions acted as a catalyst, sparking optimism and a revival that may reshape the market.

Groundbreaking MPC Meetings

At its meeting on May 6-7, 2025, the Monetary Policy Council decided to cut the NBP reference rate by 0.50 percentage points, to 5.25%. This was the first such change since October 2023, interpreted as a strong signal that the rate-hiking cycle had definitively ended.

Two months later, at its meeting on July 1-2, 2025, the MPC took another, though smaller, step, reducing the reference rate by a further 0.25 percentage points, to 5.00%. A total reduction of 0.75 percentage points within just two months was interpreted by the market as the beginning of a new, systematic easing cycle that would unlock the “dormant” demand. These decisions, supported by forecasts of falling inflation, acted not only as a nominal adjustment, but above all as a psychological impulse that influenced the expectations of borrowers and banks. On September 3, 2025, the MPC decided on yet another rate cut of 0.25 percentage points. The reference rate now stands at 4.75%.

The following analysis presents calculations based on the first two cuts: those of May and July.

Key effects for borrowers

The MPC’s decisions translated into tangible savings for holders of variable-rate loans, primarily indexed to WIBOR. Although the effects of cuts appear with a delay due to the setting periods of reference indices (WIBOR 3M or 6M), relief for household budgets is already noticeable.

A simulation for a sample loan of PLN 500 000 taken for 30 years perfectly illustrates the scale of change. Before May 2025, with the reference rate at 5.75%, the monthly instalment amounted to approx. PLN 3 382. After the May cut, which reduced the rate to 5.25%, the instalment fell to PLN 3 171 (a decrease of over 6%), meaning a saving of PLN 211 per month. After the July cut to 5.00%, the instalment dropped further to PLN 3 100, i.e. less by 8.3%. The combined saving thus amounted to PLN 282 per month, or nearly PLN 3 400 annually.

Equally important, or perhaps even more significant, is the improvement in creditworthiness. Falling interest rates lower the critical threshold a potential borrower must meet to obtain financing. A reduction in rates by 1 percentage point can increase credit capacity by as much as 10-12%.

The creditworthiness of a person, who in April could qualify for a PLN 500 000 loan, rose by approx. PLN 26 000 after the May cut and by a further PLN 14 000 after the July cut, resulting in a total increase of more than PLN 40 000, i.e. 8%. This change is the most fundamental mechanism driving current demand, as those previously excluded from the market have now gained the access to mortgage loans. Meanwhile, those, who already had such capacity, can now look for larger or better-located properties.

TABLE 1: IMPACT OF NBP INTEREST RATE CUTS ON LOAN INSTALMENTS AND CREDIT CAPACITY

Period Reference rate Monthly instalment Total instalment change Credit capacity Total capacity increase
Before May 2025 5.75% PLN 3 382 PLN 500 000
After May cut 5.25% PLN 3 171 – PLN 211 PLN 525 997 + PLN 25 997
After July cut 5.00% PLN 3 100 – PLN 282 PLN 540 221 + PLN 40 221

Assumptions: mortgage granted in March 2025 for 30 years, LtV = 80%, equal instalments

source: own elaboration

Clear growth on the mortgage market

Interest rate cuts have revived the mortgage market. According to AMRON Centre data, in Q2 2025, 55.5 thousand new housing loans worth PLN 25.607 billion were granted, i.e. more respectively by 22% and nearly 29%, compared to the same quarter of the previous year. Meanwhile, data from the Credit Information Bureau (BIK) show that between March and June 2025, the number of mortgage loan applications reached 111.74 thousand, exceeding 100 thousand for the first time since Q4 2023. This represents a 29% increase year to year.

The surge in demand was already visible in May, when 38.63 thousand people applied for mortgage loans, i.e. more by 8.4% month to month and more than 43% year to year. In July, the number of applications rose again – by 9.3% month to month and 33.6% year to year, up to 40.93 thousand. Such a high figure had not been recorded since September 2021.

TABLE 2: DYNAMICS OF DEMAND FOR MORTGAGE LOANS IN Q1 AND Q2 2025

Period Number of loans granted (thousand units) Value of loans granted (PLN billion) y/y change in number of loans granted y/y change in value of loans granted Number of applications (thousand units) acc. to BIK y/y change in number of applications acc. to BIK
Q1 2025 48.1 20.397 -25.41% -24.10% 98.36 +24.68%
Q2 2025 55.5 24.607 +22.20% +28.71% 111.74 +28.73%
July 2025 no data no data no data no data 40.93 +33.63%

source: AMRON-SARFiN Report 2/2025, BIK

Price stabilization

Housing prices in major cities stopped rising dynamically and in some locations small declines, long awaited by potential buyers, even appeared. According to AMRON Centre data, in Q2 2025, the average transaction price per square meter in Cracow fell by almost 3% compared to Q1 2025, in Warsaw by 1.7%, and in Poznan by 1.3%. In the remaining three of the six largest agglomerations, only symbolic increases were recorded. Year to year, housing prices still rose, but at a much slower pace than in previous periods.

However, the decline in average prices was mainly driven by the secondary market. In Q2 2025, prices of “second-hand” flats in the six largest cities collectively fell by 1.7% quarter to quarter. This indicates that private sellers on the secondary market are becoming more flexible in their price expectations, reacting to weaker demand from previous months. Meanwhile, on the primary market, a 2.4% increase was recorded. This is surprising, as in 2024 this segment grew more slowly than the secondary market. However, price changes are selective and often result from the introduction of more expensive new projects rather than across-the-board increases. Despite the rise on the primary market, overall housing price growth in Poland in Q2 2025 was the slowest among Central and Eastern European countries.

In July, housing offer prices also showed only minor fluctuations. According to data from the Morizon portal, both primary and secondary markets in the six largest agglomerations recorded minimal monthly changes, within the range of +/- 1%.

As can be seen, after a period of high volatility, the housing market is finally stabilizing. Prices have stopped rising, making homeownership more attainable than before.

Increased developers’ activity

Developers remained cautious in Q2 2025, still struggling with high construction costs and maintaining conservative strategies. However, July data from Statistics Poland (GUS) show a clear rebound. Developers started construction of almost 12 000 dwellings (+35% month to month) and obtained nearly 17 000 building permits (+50% month to month). They also completed 11 500 dwellings, i.e. 13% more than in June.

The halt in declines in July suggests a shift in developers’ approach. It seems their earlier concerns about future sales have given way to renewed investment activity in anticipation of higher demand on the primary market in autumn.

DEVELOPER SECTOR PERFORMANCE

source: GUS

Unlocking frozen demand

On the primary market, July 2025 was a time of a dynamic rise in sales activity on the seven largest housing markets. According to data from the Otodom portal, 4 000 dwellings were sold that month, up by one third month to month and nearly 60% year to year. Supply also increased – the number of housing units launched for sale reached 4 300 (+86% m/m), while the total number of dwellings on offer hit a record hight of almost 63 000 (+28% y/y).

The July revival also extended to the secondary market, where buyer activity exceeded seasonal norms. On the seven largest markets, the number of responses to listings on Otodom rose by 14% month on month, reaching 87 000 inquiries. Supply on these markets remained stable. Some owners are holding back from selling, anticipating further rate cuts and higher valuations, which explains the lower year-to-year supply.

The surge in demand stems from a unique combination of factors. Beyond seasonality, which usually drives higher activity in Q2, and the direct impact of rate cuts that improved financing conditions, two other factors proved to be of a key importance. First, the continued growth of real wages. In H1 2025, real purchasing power rose by 4.2% year on year. Second, paradoxically positive, was the lack of a new support programme, such as “0% Loan.” Previously, many potential buyers had postponed decisions, waiting for government subsidies. When it became clear that no new state-funded programme would be introduced, buyers were forced to act based on current market conditions. This shift in expectations from “waiting for support” to “acting under better market conditions” unlocked dormant capital.

Summary

The interest rate cuts of May and July 2025 were a crucial psychological impulse for the Polish market. The MPC’s cautious decisions confirmed the return to a disinflationary path and sent a clear signal that financing conditions will gradually improve.

The current situation represents a unique combination of stable prices and better lending conditions, creating a “window of opportunity” for buyers. The growing number of loan applications, increased traffic on property listing sites and rising sales are clear signs that the market has responded to changes, while forecasts of further rate cuts suggest that demand is only beginning to gain momentum. Importantly, this is happening with no government subsidy programmes for housing loans. Although it is still too early to declare a lasting revival, recent data are highly promising.

Agnieszka Pilcicka
Senior Real Estate Market Analyst

AI in the real estate market

The origins of artificial intelligence date back to the 1950s – to the work of Alan Turing and the Dartmouth Conference (1956), during which the very concept of AI (Artificial Intelligence) was defined. However, it is only in the past several years, with the growth of computing power, machine learning methods and most importantly, access to vast datasets, that AI has reached a level enabling it to significantly influence reality. Today, AI is present in many areas of our lives: in medicine it supports diagnostics and treatment, in the automotive industry it powers autonomous driving systems, in finance it manages investment portfolios and detects fraud attempts, in logistics it is used to optimize deliveries, in the creative sector it can generate texts, images and music, in education it enables personalized learning paths, in retail it provides precise customer targeting. AI is thus already a tangible tool reshaping the world’s functioning and its potential for future transformation appears inexhaustible. The AI revolution will not bypass the real estate market, a sector often regarded as slow to adopt technological change. In the coming years, artificial intelligence may revolutionize virtually every element of this market – from the valuation process to property management, brokerage and even the development process.

One of areas within the real estate sector, where AI is already being increasingly applied, is the automation of property valuation. AI enables quick estimation of property value using large datasets and advanced machine learning algorithms. The most commonly used models are so-called Automated Valuation Models (AVMs), which rely on analysing property attributes such as location, area, number of rooms, year of construction and so on. Methods employed include linear regression, decision trees, random forests and neural networks, capable of including complex and non-linear relationships between variables. The advantages of using AI in property valuation lie primarily in speed, scalability and the ability to analyse large, complex datasets, which helps to reduce subjectivity and human error. In the future, valuations may also incorporate satellite images, drone data, IoT (Internet of Things) sensors monitoring building conditions, or even weather data to reflect the impact of climate on property values. Naturally, for various reasons (including regulatory ones), these models will not fully replace expert appraisals, particularly in case of properties with atypical characteristics or in unique locations.

Property management, particularly of commercial properties, is becoming increasingly complex due to the growing number of facilities, the intricacy of infrastructure and the high expectations of both tenants and owners. AI-based solutions are increasingly being deployed to streamline and optimize management processes, minimize costs and maintain or improve service quality. AI is primarily used here to automate routine tasks – machine learning systems can automatically monitor the technical condition of buildings, analyse data from IoT sensors and devices, detect malfunctions and even predict them. Another significant application of AI in property management is energy consumption optimization. Intelligent Building Management Systems (BMS) using AI algorithms can analyse energy usage, regulate lighting, heating and air conditioning in real time, adapting them to users’ current needs. This results in substantial energy savings and improved comfort for building occupants. AI is also applied in lease management and tenant services. Chatbots and automated customer service systems can respond to tenant inquiries 24/7, log and track service requests and schedule maintenance visits. Moreover, these systems can analyse tenants’ preferences and behaviours, allowing better tailoring of additional services, thereby improving customer satisfaction. An important element is also the analysis of market and financial data. AI enables fast processing of information on property values, market trends, rent payments or operating costs. As a result, property managers can make more informed decisions regarding investments, leasing strategies or budget optimization.

Brokerage in real estate transactions also holds significant potential for AI-driven transformation. With substantial improvement in access to information (both in ease and speed), the role of brokers is likely to shift more toward advisory services and transaction facilitation. The future will belong to those, who can leverage modern technologies, such as property presentation and showcasing its potential. One of the most important applications of AI in brokerage will be the personalization of property listings. Advanced algorithms will be able to analyse customer preferences, past behaviours and purchasing profiles to propose properties that best match their expectations. This will make the property search process more efficient and less time-consuming. Brokers will gain the ability to present clients with curated offers more quickly, increasing the chances of successful transactions. Additionally, generative AI is already able to create realistic visualizations of interiors or entire buildings even from floor plans. In the future, “virtual staging” may become the standard, enabling clients to view properties in multiple design or lighting variants. As technology develops and data accessibility increases, analytical tools supporting real estate agents’ work will gain in importance. AI, through machine learning algorithms and large-scale data processing, will enable automatic analysis of listings, verification of their value and forecasting of market trends. This will allow for more accurate property selection and recommendations of the most suitable offers to clients. Faster access to high-quality information may in practice mean that the concept of a “market opportunity” will fade, as the best offers will disappear almost instantly. This could significantly reduce the ability of so-called “opportunity hunters” and flippers, for whom the reaction speed has so far been a key advantage. AI may also support brokers by automating marketing activities. AI-based systems can generate property descriptions, optimize social media advertising campaigns and manage client communications. Such solutions will not only improve customer service quality, but also reduce the workload of agents, enabling them to focus on more complex and demanding aspects of their work.

Transformation can also be expected not only in sales, but also in the rental housing market. Thanks to AI, landlords and brokers will be able to set rents in real time based on current demand, seasonality or events in a given city. This may lead to greater price volatility and reduced predictability for tenants, while at the same time enabling landlords to maximize profits. AI can also support the tenant verification process, contract signing and payment monitoring, which increases security, but also brings greater automation into the landlord – tenant relationship.

These are, of course, only the fundamental aspects of AI implementation in the real estate market. Beyond market participants, such as appraisers, brokers or managers, AI’s impact will certainly extend to all related professions and industries – developers, who will be able to more accurately forecast demand and design investments suited to client preferences, while also facing rising competition and likely margin reductions, architects, for whom AI brings the potential for a true revolution, as well as banks, insurers and the construction sector. Over the next 5 – 10 years, AI will become an integral part of the real estate market, influencing every segment – from investment planning, through sales and rental, to property management. Companies that implement these technologies early may gain an advantage, but success will require combining technological innovation with an ethical and transparent approach to clients. These areas hold the greatest challenges of AI adoption. Data monopolization, flawed data, algorithmic errors excluding or disadvantaging certain market participants, or privacy issues are just some of them. Therefore, AI is – and should remain in the future – merely a tool to enable more effective work for professionals operating on this market, and additionally subject to critical oversight. After all, property valuation or sales are not only about hard data, but also about soft factors – emotions and subjective perceptions.

Jerzy Ptaszyński
Research and Market Service Director

Planning reform 2026: new rules for zoning decisions and the role of the general plan

As of early 2026, the Polish spatial planning system will undergo a significant transformation. The currently used “studies of conditions and directions of spatial development” (SUiKZP), which have so far been informal in nature, will be replaced by a new act of local law. The reform is intended to bring order to local spatial policy, curb chaotic development and eliminate speculative practices related to obtaining zoning decisions (WZ). As a result, investors and landowners will face an entirely new system, in which decisions will only be issued for areas designated by the municipality as suitable for development and their validity will be limited to five years.

The general plan will become the sole fundamental planning document for each municipality. According to current legislation, it must be adopted no later than on June 30, 2026 (this deadline was extended to provide a transitional period and avoid legal chaos). The general plan formalizes the division of a municipality’s territory into functional zones: residential (single-family and multi-family), service, agricultural, green and recreational. Most importantly, it designates the “development completion areas” (OUZ) – the only areas where WZ decisions may be issued. Since the general plan constitutes local law, its provisions are binding without the need for local zoning plans. This gives municipalities significant authority in shaping spatial policy and deciding, where development may or may not take place.

Starting from January 1, 2026, all new zoning decisions (WZ) will be issued exclusively for development completion areas (OUZ) designated in the general plan and their validity will be limited to five years from the date they become final. This marks the end of indefinite WZ decisions, which had given investors the certainty that a project could be implemented on a given site, even if construction was delayed. In practice, investors who manage to submit an application before the end of 2025 may still receive a decision with unlimited validity. However, all decisions issued after the new regulations take effect will be valid for only five years. New WZ decisions will only be obtainable, if the plot lies within an OUZ and the planned project aligns with the land use set out in the municipal general plan. Municipalities will gain tools to define development parameters such as minimum plot size, number of storeys and development intensity.

The method for defining development completion areas (OUZ) is detailed in the Regulation of the Minister of Development and Technology dated May 2, 2024 on the method of designating development completion areas in the municipal general plan. According to the regulation, an OUZ may include a group of at least five buildings (industrial buildings classified under KŚT code 101, retail and service buildings – 103, office buildings – 105, hospitals and other healthcare facilities – 106, educational, scientific, cultural, and sports buildings – 107, other non-residential buildings – 109, residential buildings – 110), with each building located no more than 100 metres from the next. The boundary of the area is initially marked by a curve drawn 50 metres from the outline of the buildings. Then, the areas with a surface not exceeding 5 000 sqm. limited by this curve are enclosed. The final step involves drawing a curve 40 metres inward from the previously marked boundary. This inner section is then subtracted from the total area, resulting in the final OUZ designation. This procedure means that not every dense grouping of buildings will automatically qualify as an OUZ – municipalities will independently decide, where to establish them. If a municipality fails to designate an OUZ, this may result in a situation, when the owner of a given plot will be unable to construct any buildings, even if the plot lies within a municipality without a local plan.

The reform paves the way for clearer, yet more restrictive rules. For plots that previously relied on standard WZ decisions (areas without an adopted local spatial development plan), the change could mean that from mid-2026, new WZ decisions will not be obtainable if the municipality has not designated an OUZ. In regions with limited local plan coverage, many plots may lose their investment potential. Moreover, the five-year validity limit will mean that multi-stage developments will require more precise scheduling. Once a WZ decision expires, a new application will have to be submitted, even if the project has not changed.

The best way to secure an investment is to act already in 2025 by submitting a WZ application as soon as possible, so that the request may be processed under the current regulations and benefit from indefinite validity. It is equally important to monitor progress on the general plan – it is advisable to participate in public consultations and express interest to ensure that your plot is included in an OUZ.

The general plan will not replace the Local Spatial Development Plan (MPZP), but it will complement it. The general plan is a new strategic planning document that outlines the broad directions of a municipality’s spatial development. The MPZP will remain a tool used to define precisely, what can be built on a specific site. The key difference between the general plan and the MPZP is that the general plan is mandatory for all municipalities and defines planning zones and development frameworks, whereas the MPZP is an act of local law containing detailed provisions for specific areas. The MPZP will have to comply with the provisions of the general plan.

Summary

The planning reform means that as of January 1, 2026, new WZ decisions will only be possible within OUZ areas and will be limited to five years. By July 1, 2026, municipalities will have to adopt general plans, without which no new WZ decisions may be issued for areas not covered by OUZ. The reform places municipalities in the role of decision-makers, but also requires investors to be more proactive and strategic in their planning. Those, who take advantage of the transition period and submit applications under the old rules, will gain an advantage – especially in case of large, long-term investments.

Klaudia Jastrzębska
Buildings Database Project Coordinator