Mortgage in Poland for Belarusians and buying a flat in 2026: EU sanctions

Can you get a mortgage in Poland as a Belarusian? In 2026 a Belarusian citizen can buy a new-build flat from a developer in Poland without an MSWiA permit (from the Ministry of the Interior and Administration), and a mortgage is realistic mainly for people with a residence card (karta pobytu) and income in złoty. The biggest difference comes not from property law but from EU sanctions against Belarus: without a residence permit in the EU, a bank will not accept deposits from you above EUR 100,000 and will not issue you a payment card. We explain what is allowed with each residence status, how banks approach it and how to plan the money for your purchase.
Key points
- Buying a self-contained residential unit does not require an MSWiA permit – this applies to Belarusian citizens too (Art. 8(1)(1) of the Act on the Acquisition of Real Estate by Foreigners), outside the border zone.
- Council Regulation (EC) No 765/2006 prohibits banks from accepting deposits from Belarusian citizens if their total value at a given bank exceeds EUR 100,000 (approx. PLN 437,500 at the NBP rate of 25 September 2026).
- The ban does not apply to people with a temporary or permanent residence permit in an EU or EEA country or in Switzerland, or to citizens of those countries (Art. 1u(4)).
- The Pole's Card (Karta Polaka) is not a residence permit (Art. 7(2) of the Act on the Pole's Card), but it lets you apply for permanent residence (Art. 195(1)(9) of the Act on Foreigners).
- You can get a loan in złoty if most of your income is in PLN (Art. 6 of the Mortgage Credit Act); for a flat costing PLN 553,000 with a 20% down payment, the monthly instalment is approx. PLN 2,870 (25 years, 6.07%).
Can a Belarusian buy a flat in Poland?
Yes. The Act on the Acquisition of Real Estate by Foreigners has no separate rules for Belarusian citizens – it treats them the same as other foreigners from outside the European Economic Area. As a rule, acquiring real estate requires a permit from the minister of the interior, but Art. 8(1)(1) exempts the purchase of a self-contained residential unit. So you can buy a flat from a developer with its own land and mortgage register (księga wieczysta) without applying to the MSWiA. The same applies to a parking space or storage room linked to the flat (Art. 8(1)(1a)).
A permit is, however, required to buy a house with a plot or land on its own. The exemption in Art. 8(1) does not apply in the border zone (Art. 8(3)) – this matters if you are considering towns near the border with Belarus. Warsaw and Wrocław are not in the border zone. 5 years after obtaining a permanent residence permit, you can also buy a house or a plot without a permit (Art. 8(1)(2)). We describe the MSWiA procedure in detail in our guide buying a flat in Poland as a foreigner.
A separate exception covers people and companies on sanctions lists – the EU list (Annex I to Regulation 765/2006) or the national list kept by the MSWiA. Their assets are frozen and no funds may be made available to them (Art. 2 of the Regulation, Art. 1–2 of the Act of 13 April 2022). In practice such persons cannot complete a purchase. These lists do not affect other Belarusian citizens.
EU sanctions and your bank account – what the EUR 100,000 limit means
The restrictions you will feel most come from Art. 1u of Council Regulation (EC) No 765/2006 (consolidated version of 24 July 2026). It prohibits:
- accepting deposits from Belarusian citizens and people living in Belarus if the total value of a person's deposits at one credit institution exceeds EUR 100,000 (para. 1),
- providing them with payment instruments (e.g. cards), acquiring and payment initiation services, issuing electronic money, and crypto-asset services (para. 2).
Neither ban applies to citizens of EU and EEA countries and Switzerland, or to people who hold a temporary or permanent residence permit in one of those countries (para. 4). Banks apply these rules in practice. PKO Bank Polski has announced that clients from Belarus and Russia who opened an account after 24 October 2025 without a residence card must show a residence card or another document entitling them to stay at a branch – without it they lose access to online and mobile banking, and their account card is blocked. BNP Paribas Bank Polska says that once the EUR 100,000 threshold is exceeded, it will stop accepting new deposits and transfers into the accounts.
The Regulation also allows derogations: the competent national authority may authorise accepting a deposit, among other cases, when it is necessary to meet basic needs, including rent or mortgage repayments (Art. 1v(1)(a)). This is, however, an individual procedure, not a solution you can rely on at the start of a purchase.
Example: a cash purchase without a residence card
You want to buy a 2-room flat (living room + 1 bedroom) in Wrocław for PLN 662,405 – the median price of such flats in our listings (based on TM Invest listing data as of 27 September 2026). The EUR 100,000 limit is approx. PLN 437,500 (NBP average rate of PLN 4.3750 on 25 September 2026). If you do not have a residence permit in the EU, you will not be able to hold the full amount in an account at one bank – the price exceeds the limit by approx. PLN 225,000. Before you sign the developer agreement (umowa deweloperska), agree with your bank how to make the payments in line with the sanctions, or get a residence card first. Do not try to get around the limit, e.g. through other people's accounts – the Regulation prohibits knowingly taking part in activities whose object or effect is to circumvent its prohibitions (Art. 1m). A 20% down payment for a mortgage (approx. PLN 132,000) fits well within the limit.
Residence status – purchase, bank account and mortgage in one table
The table below shows how a Belarusian citizen's options change in practice depending on their residence document. The "mortgage" column describes the typical approach of banks, not a guaranteed decision.
| Status | Buying a flat | Bank account | Mortgage |
|---|---|---|---|
| No residence permit (visa, resident of Belarus) | Yes, without an MSWiA permit (outside the border zone) | Deposits up to EUR 100,000 at one bank, no payment card | Very difficult in practice – no PLN income and no stable residence |
| Pole's Card + national visa | Yes, as above | As above – the Pole's Card is not a residence permit | Difficult until you obtain a residence card |
| Temporary residence permit (residence card, up to 3 years) | Yes | No EUR 100,000 limit, payment card available | Possible – the bank looks at the card's validity, your employment contract and your history in Poland |
| Permanent residence permit (e.g. based on the Pole's Card) | Yes; after 5 years also a house and a plot without a permit | No EUR 100,000 limit | The strongest position among non-EU foreigners |
| Polish or other EU citizenship | Yes, no restrictions for foreigners | The Art. 1u sanctions do not apply | On the same terms as for Polish citizens |
Do you have a different document, e.g. refugee status, subsidiary protection or an EU long-term resident permit? Ask your bank how it classifies it – PKO BP's notice refers to "a residence card or another document entitling you to stay", but each bank makes the final assessment itself.
The Pole's Card and permanent residence – the safest route
Many Belarusians hold the Pole's Card. The law, however, is clear: the Pole's Card does not entitle you to cross the border or to settle in Poland (Art. 7(2)). For the bank and the EU sanctions, it therefore does not replace a residence card. It does allow you to work and run a business (Art. 6(1)) and, above all, to apply for a permanent residence permit – Art. 195(1)(9) of the Act on Foreigners provides for one for the holder of a valid Pole's Card who intends to settle in Poland permanently. The permit is granted for an indefinite period.
Once you obtain permanent residence, the Pole's Card expires by operation of law (Art. 20(1a) of the Act on the Pole's Card) – this is normal and does not mean you lose your rights. From the point of view of buying a flat, permanent residence is the best status: it removes the sanctions deposit limit, and the bank does not have to worry about when your stay ends when granting a 25–30-year mortgage. Whether buying a flat itself helps you obtain residence is covered in our article does buying property give you residence in Poland.
Mortgage in Poland for Belarusians – how banks approach it
Lending law does not divide customers by nationality. The bank assesses your borrowing capacity (how much you can borrow; Art. 21 and 23 of the Mortgage Credit Act) and grants a loan in złoty to a person who earns most of their income in PLN or holds most of their assets in that currency (Art. 6). Internal requirements usually concern residence status, a PESEL number (Polish national identification number), Polish income and your history in BIK (the Polish credit bureau). We have not found any official bank rules that explicitly exclude Belarusian citizens from mortgages – so what matters most is your residence document and the sanctions rules on running an account.
In practice, with a temporary residence card the bank looks at how long the permit was issued for and on what grounds (work, business, family), as well as how long you have been working in Poland. The down payment is at least 10–20% – Recommendation S of the KNF (Polish Financial Supervision Authority) allows an LTV of up to 80%, or up to 90% with additional security. We cover the general rules of mortgages for foreigners, including income in several currencies, in our article mortgage in Poland for foreigners, and compare the situation with that of Ukrainian citizens in mortgage in Poland for Ukrainians.
What will the monthly instalment be – examples from our listings
Below are calculations for the median prices of 2-room flats (based on TM Invest listing data as of 27 September 2026), a 20% down payment and an interest rate of 6.07% – the average interest rate on new PLN housing loans in July 2026 according to the NBP (new agreements excluding renegotiated ones, NBP MIR). Equal instalments, excluding insurance costs.
| Location (2 rooms, median) | Price | 20% down payment | Loan | Instalment – 25 years | Instalment – 30 years |
|---|---|---|---|---|---|
| Warsaw, Białołęka | PLN 553,358 | PLN 110,672 | PLN 442,686 | approx. PLN 2,871 | approx. PLN 2,674 |
| Wrocław – whole city | PLN 662,405 | PLN 132,481 | PLN 529,924 | approx. PLN 3,437 | approx. PLN 3,201 |
| Warsaw – whole city | PLN 755,824 | PLN 151,165 | PLN 604,659 | approx. PLN 3,922 | approx. PLN 3,652 |
A cheaper alternative in Wrocław is Fabryczna – the median for 2 rooms there is PLN 511,792 (see new homes in Fabryczna). If you are choosing a district with schools and commuting in mind, have a look at our guide Wrocław for families from Ukraine and Belarus.
Want to check whether your residence card and income are enough for a mortgage? Book a consultation with our mortgage expert – we will compare offers from several banks and tell you which documents they will require.
Transfers from Belarus and the source of funds
Money for the down payment or a cash purchase often comes from selling assets in Belarus. Two layers of rules apply here. The first is sanctions: Regulation 765/2006 prohibits any transactions with the banks listed in Annex XV – Belagroprombank, Bank Dabrabyt, the Development Bank of the Republic of Belarus and Belinvestbank (Art. 1zb). A transfer from an account at such a bank will not be accepted. It is also prohibited to sell or export to Belarus banknotes denominated in the currencies of EU countries (Art. 1za).
The second layer is anti-money laundering law. The bank and the notary handling the transfer of ownership of the property are obliged institutions – they must establish the source of funds and may ask for the sale agreement for a flat, income certificates or bank statements. For transfers linked to Belarus, checks can take longer, so plan for them before you sign the developer agreement. We explain how to prepare the documents and the currency conversion in our article transferring money from abroad to buy a flat, and the formalities to handle before the purchase (PESEL, NIP, bank account) in our checklist for foreigners.
Frequently asked questions
Do I need an MSWiA permit to buy a flat in Poland as a Belarusian?
No, if you are buying a self-contained residential unit outside the border zone – Art. 8(1)(1) of the Act on the Acquisition of Real Estate by Foreigners exempts you. A permit is required, among other cases, to buy a house with a plot or land, unless 5 years have passed since you obtained permanent residence.
Can a Belarusian get a mortgage in Poland?
Yes, but in practice mainly with a temporary or permanent residence permit, income in złoty and a down payment of at least 10–20%. Without a residence card the bank will not even issue you a payment card, and borrowing capacity based on income from Belarus is very hard for banks to accept.
How much money can a Belarusian citizen keep in a Polish bank?
Without a residence permit in the EU, EEA or Switzerland – up to EUR 100,000 in total at one bank (approx. PLN 437,500 at the NBP rate of 25 September 2026). People with a temporary or permanent residence card are not subject to this limit, but they have to show the bank their residence document.
Does the Pole's Card lift the sanctions restrictions at the bank?
No. The exception in the Regulation covers temporary or permanent residence permits, and under the law the Pole's Card is not a document entitling you to settle. You can, however, use it to apply for permanent residence – once you obtain it, the restrictions no longer apply to you.
Can I transfer money from Belarus to buy a flat in Poland?
Not from banks under sanctions (Annex XV to Regulation 765/2006). From other sources a transfer is possible, but the receiving bank will check the source of funds and may ask for documents, and without a residence card it is bound by the EUR 100,000 deposit limit.
Summary
In 2026 a Belarusian citizen can buy a flat in Poland without an MSWiA permit, and a mortgage is available on similar terms as for other non-EU foreigners. The barrier is banking sanctions: without a residence card, the EUR 100,000 deposit limit and the lack of a payment card make both a cash purchase and servicing a mortgage harder. The safest route is a temporary or permanent residence permit – including one based on the Pole's Card – and documenting the source of your funds in advance.
Looking for a flat in Warsaw or Wrocław? We will help you choose a new-build flat from a developer and guide you through the purchase – usually no commission for you, as our fee is normally paid by the developer. If you need financing, book a consultation with our mortgage expert – we will compare offers from several banks.
Legal status as of September 2026 (Regulation 765/2006, consolidated version of 24 July 2026). EU sanctions change often – before any transaction, check the current wording of the rules and your bank's requirements. The calculations are indicative and do not constitute an offer, a credit decision or legal advice.
Sources
- Council Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus – consolidated version of 24 July 2026 (Art. 1m, 1u, 1v, 1za, 1zb, 2, Annex XV).
- Act of 24 March 1920 on the Acquisition of Real Estate by Foreigners – consolidated text, Journal of Laws (Dz.U.) 2017 item 2278, as amended (Art. 1, Art. 8(1) and (3)).
- Act of 7 September 2007 on the Pole's Card – consolidated text, Dz.U. 2026 item 76 (Art. 6, 7, 20(1a)).
- Act of 12 December 2013 on Foreigners – consolidated text, Dz.U. 2025 item 1079, as amended (Art. 98, Art. 195(1)(9)).
- Act of 13 April 2022 on special measures to counteract support for aggression against Ukraine – consolidated text, Dz.U. 2025 item 514 (Art. 1–2).
- Act of 23 March 2017 on Mortgage Credit – consolidated text, Dz.U. 2025 item 720 (Art. 6, 21, 23).
- Act on Counteracting Money Laundering and Terrorist Financing – consolidated text, Dz.U. 2025 item 644 (Art. 2(1)).
- KNF, Recommendation S – LTV and rules for assessing borrowing capacity.
- NBP, interest rate statistics (MIR) – July 2026; NBP average EUR exchange rate of 25 September 2026 (table 187/A/NBP/2026).
- PKO Bank Polski – information for citizens of Belarus and Russia (3 December 2025); BNP Paribas Bank Polska – information on deposit restrictions.
- Flat prices: TM Invest catalogue of new developments, as of 27 September 2026.
















