A Levy on Assets, Owed Whether or Not You EarnThin moat

PKO Bank Polski (PKO) — moat facet

1,35 billion złoty a year on assets rather than profit — a quarter of the entire fee income, charged for existing.

Poland's tax on certain financial institutions cost PKO 1 349 million złoty in 2025, up 6,2%1. It is charged on assets, not income.

The asset levy against what it consumes (zl m)5 243Fee and commission income1 349Tax on financial institutionsA quarter of everything PKO earned in fees, charged on the balance sheet rather than the profit
The levy is owed in a loss-making year exactly as in a record one. It is a tax on being large, not on being profitable.

That distinction is the whole point. An asset levy is a fixed charge against the size of the balance sheet, so it is owed in a bad year as readily as a good one — and it grows automatically as the bank lends more. PKO's assets rose 11,0% in 20252, so the levy rose with them.

It is also a tax on exactly the activity policy elsewhere encourages. A bank that expands lending to the Polish economy increases its levy; one that shrinks reduces it.

The rate is scheduled to fall — from 0,0366% to 0,0329% in 2027 and 0,0293% in 20283 — as part of the same package that raised corporate income tax, so the state is shifting from taxing the balance sheet to taxing the profit.

Against a net profit of 10 682 million złoty4 the levy is material without being decisive: roughly an eighth of what the bank earns.

For scale, the levy of 1 349 million złoty5 is roughly equal to a quarter of the bank's entire net fee and commission income of 5 243 million6 — a charge the size of a substantial business line, incurred simply for having a balance sheet.

The measure is the levy against assets. A falling rate on a growing balance sheet should hold the charge roughly flat, and any deviation would mean the rate schedule changed again.

Moat trajectory: Narrowing

1 349 million złoty in 2025, and the levy rate falls to 0,0329% then 0,0293% - but only because the income tax rate rose to replace it. The total burden went up.

The number that tests this moat
Moat Explorer calc
Tax on certain financial institutions
1 349m zł, against 5 243m zł of fee income

The asset levy took a quarter of everything PKO earned in fees, and it is owed on the balance sheet rather than on the profit. The rate falls to 0,0329% in 2027 and 0,0293% in 2028 - but only because the income tax rate rose to more than replace it.

Source: PKO Bank Polski S.A. Group Directors' Report for 2025 ↗
⚠ Threats to the moat
⚠ THREAT 01
A Fixed Charge Meets a Falling Margin
An asset-based levy takes a larger share of profit every year the margin narrows.
References
  1. ReportedPoland's tax on certain financial institutions cost PKO 1 349 million złoty in 2025, up 6,2%.
    PKO Bank Polski S.A. Group Directors' Report for 2025 - capital, shareholders and levies (the State Treasury holding 367 918 980 shares or 29,43% of the capital and votes, Nationale Nederlanden at 7,32% and Allianz Polska at 6,01%, own funds of 50 122m złoty, a total capital ratio of 17,10%, the 75% dividend payout from the 2025 profit, and the 1 349m złoty tax on certain financial institutions) — FY2025 · publ. 12 March 2026 · source ↗
  2. ReportedPKO's assets rose 11,0% in 2025, so the levy rose with them.
    PKO Bank Polski S.A. Group Directors' Report for 2025 - capital, shareholders and levies (the State Treasury holding 367 918 980 shares or 29,43% of the capital and votes, Nationale Nederlanden at 7,32% and Allianz Polska at 6,01%, own funds of 50 122m złoty, a total capital ratio of 17,10%, the 75% dividend payout from the 2025 profit, and the 1 349m złoty tax on certain financial institutions) — FY2025 · publ. 12 March 2026 · source ↗
  3. ReportedThe rate is scheduled to fall — from 0,0366% to 0,0329% in 2027 and 0,0293% in 2028 — as part of the same package that raised corporate income tax, so the state is shifting from taxing the balance sheet to taxing the profit.
    Polish corporate income tax on banks - the amendment signed by the president on 27 November 2025 and in force from 1 January 2026, raising the rate on commercial banks from 19% to 30% for 2026, then 26% in 2027 and 23% in 2028, with the asset-based bank levy falling from 0,0366% to 0,0329% and 0,0293%; framed by the finance ministry as social justice and as financing defence needs, criticised by the sector as discriminatory, and estimated to raise about 6,5bn złoty in 2026 — 2026-2028 · publ. November 2025 · source ↗
  4. ReportedAgainst a net profit of 10 682 million złoty the levy is material without being decisive: roughly an eighth of what the bank earns.
    PKO Bank Polski S.A. Group Directors' Report for 2025 - capital, shareholders and levies (the State Treasury holding 367 918 980 shares or 29,43% of the capital and votes, Nationale Nederlanden at 7,32% and Allianz Polska at 6,01%, own funds of 50 122m złoty, a total capital ratio of 17,10%, the 75% dividend payout from the 2025 profit, and the 1 349m złoty tax on certain financial institutions) — FY2025 · publ. 12 March 2026 · source ↗
  5. Moat Explorer calcFor scale, the levy of 1 349 million złoty is roughly equal to a quarter of the bank's entire net fee and commission income of 5 243 million — a charge the size of a substantial business line, incurred simply for having a balance sheet.
    Moat Explorer calculation - arithmetic on figures PKO reports: the Swiss franc charge as a share of net profit (4 365 over 10 682), financing per employee (315 953 over 26 252 against 247 572 over 25 657), current accounts as a share of customers (9 764 over 12 460), deposits less financing (460 722 less 315 953), and the levy against fee income (1 349 over 5 243), credit losses excluding legal risk (5 859 less 4 365 = 1 494), the income mix (24 223 and 5 243 over 30 370 = 79,8% and 17,3%), net profit growth (10 682 against 9 304 = 14,8%), financing per employee (315 953 over 26 252 = 12,0m), and customers against Poland's population (12,46m of 37,33m) — FY2021-FY2025 · publ. September 2026 · source ↗
  6. Moat Explorer calcFor scale, the levy of 1 349 million złoty is roughly equal to a quarter of the bank's entire net fee and commission income of 5 243 million — a charge the size of a substantial business line, incurred simply for having a balance sheet.
    Moat Explorer calculation - arithmetic on figures PKO reports: the Swiss franc charge as a share of net profit (4 365 over 10 682), financing per employee (315 953 over 26 252 against 247 572 over 25 657), current accounts as a share of customers (9 764 over 12 460), deposits less financing (460 722 less 315 953), and the levy against fee income (1 349 over 5 243), credit losses excluding legal risk (5 859 less 4 365 = 1 494), the income mix (24 223 and 5 243 over 30 370 = 79,8% and 17,3%), net profit growth (10 682 against 9 304 = 14,8%), financing per employee (315 953 over 26 252 = 12,0m), and customers against Poland's population (12,46m of 37,33m) — FY2021-FY2025 · publ. September 2026 · source ↗
Sources
Generated September 24, 2026