As of 13 February 2026, financial institutions will operate under new rules regarding the acceptance and handling of customer complaints. The changes result from the amendment to the act on the handling of complaints by financial market entities, on the Financial Ombudsman and on the Financial Education Fund (the “Amendment”) dated October 17^th, 2025.

The Amendment is primarily intended to streamline the complaint handling process and place greater emphasis on electronic forms of response.

New Rules for Submitting Complaints (art. 3 section 2 of the act)

The Amendment exhaustively specifies the permissible forms of submitting complaints, which include:

1. In writing:
   a. in paper form – submitted in person or sent by post, or dispatched at a branch of an entity providing correspondence delivery services within the European Union; or
   b. in electronic form – via a means of electronic communication or sent to an electronic delivery address (e-Delivery);
2. Orally – by telephone or in person for the record during a customer’s visit to a branch.

Regarding electronic communication, the legislator refers to the definition of an electronic delivery address and to the database of electronic addresses as the reference register.

A financial market entity is required to provide customers with access to specified electronic communication channels for handling complaints and to clearly indicate these channels in its internal procedures and customer communications.

New Rules for Responding to Complaints (art. 5 of the act)

The Amendment introduces a mechanism for providing responses in writing, distinguishing the medium depending on the form in which the complaint was submitted and the customer’s request:

a. Complaint submitted electronically

• the response is provided electronically as a rule,
• paper form only at the customer’s explicit request.

b. Complaint submitted in paper form

• the response is provided in paper form as a rule,
• electronic form only at the customer’s request.

c. Complaint submitted orally

• the response is provided in paper or electronic form, according to the customer’s choice,
• providing a response exclusively orally is not permitted.

Rules for delivering electronic responses (Art. 5 section 2 of the act)

In the case of electronic responses:

• if the complaint was submitted via a means of electronic communication, the response should be delivered through the same channel or another channel indicated by the customer.
• if the complaint was sent to an electronic delivery address, the response shall be delivered to the address entered in the database of electronic addresses.

The remaining provisions of the Act on the Handling of Complaints remain unchanged.

Entry into force and transitional provisions

The Amendment enters into force on February 13 th, 2026.

Complaints submitted and not yet resolved before that date will be subject to the previous regulations.

Recommendations

In connection with the entry into force of the Amendment, we recommend adjusting internal procedures within institutions and reviewing documents provided to customers (agreements and terms and conditions).

Should you have any questions or require support in implementing the new regulations, we remain at your disposal.