Poland: AML/CFT Strategy 2026 — Council of Ministers adopts Resolution No. 75
The Council of Ministers adopted the AML/CFT Strategy (M.P. 2026 item 247). A policy-direction document — it imposes no new obligations directly on firms.
- Jurisdiction
- 🇵🇱 Poland
- Authority
- Council of Ministers (document prepared by GIIF)
- Instrument type
- resolution / strategic document
- In force from
- 27.02.2026
The Strategy imposes no new obligations directly on non-financial firms. It does, however, set the direction for GIIF's supervisory activity and for inspection authorities — firms covered by the AML Act can expect heightened inspection activity aligned with the Strategy's priorities.
In brief
- What: the Council of Ministers adopted the Strategy for countering money laundering and terrorist financing.
- Who issues it: the Council of Ministers (document prepared by GIIF) (Poland).
- Status / timing: in force from 27 February 2026 (published in M.P. on 26 February 2026).
What changes
By Resolution No. 75 of 10 February 2026, the Council of Ministers adopted the AML/CFT Strategy prepared by the General Inspector of Financial Information. The act fulfils the statutory obligation under Art. 31(1) of the Act of 1 March 2018 on counteracting money laundering (consolidated text: Journal of Laws 2025 item 644). The Strategy is based on the National Risk Assessment and sets out an action plan to mitigate the risk of money laundering and terrorist financing in Poland. The resolution was published in the Polish Official Gazette (Monitor Polski) on 26 February 2026 (M.P. 2026 item 247) and entered into force the following day — 27 February 2026.
Who is affected
The Strategy is addressed to the entire national AML/CFT system: GIIF, the authorities supervising obliged entities, and cooperating units. It is a state planning document that does not directly change the content of the provisions imposing obligations on specific entities. Obliged entities within the meaning of the Act of 1 March 2018 (banks, accounting offices, law firms, real-estate agents and others) are named as addressees of the policy — not as subjects of new legal norms.
What it means for non-financial firms
The Strategy imposes no new, direct obligations on firms. It does not change thresholds, does not widen the circle of obliged entities, and does not modify procedures or penalties.
Its indirect significance is nevertheless real: the document sets the inspection priorities of GIIF and the supervisory authorities for the years ahead. If the Strategy flags specific sectors as areas of elevated risk or signals more intensive inspections, firms in those industries can expect inspector visits or requests for explanations more often. This applies especially to entities that formally belong to the obliged entities but rarely review their own obligations — such as accounting offices, law firms or real-estate agents.
If your firm is wondering whether it falls under the AML Act at all, it is worth starting by checking the basic sanction screening obligation — regardless of what GIIF’s Strategy plans for the future.
Assessment: indirect impact. This is a directional signal for compliance, not a mandate to act.
What’s next
The full text of the resolution is available in M.P. 2026 item 247 (ELI Sejm). GIIF published additional information in Communication No. 105. It is worth following subsequent GIIF communications — the detailed action plans flowing from the Strategy may take the form of more concrete guidelines or updates to implementing regulations.
AML Radar is an informational monitor, not legal advice. The content is based on publicly available government sources (links above) as of the update date. Facts and dates may change — verify the current status at the source before acting and consult a lawyer where needed.