The Shareholder Who Writes the RulesThin moat

PKO Bank Polski (PKO) — moat facet

The State Treasury holds 29,43 percent of the bank and one hundred percent of the tax code.

The State Treasury holds 367 918 980 PKO shares — 29,43% of the capital and of the votes1, the largest single holding by a wide margin, with two Polish pension funds holding a further 13,3%2.

Ownership, FY2025State Treasury — 29%Nationale Nederlanden OFE — 7%Allianz Polska OFE — 6%Free float and others — 57%367 918 980 of 1 250 000 000 shares - one class, so votes match economics
Not a majority, and more than enough. The largest shareholder also writes the tax code the bank pays under.

That is a large minority rather than control, and PKO is run as a listed commercial bank. What it means in practice is that the largest shareholder is also the party that sets the tax rate on bank profits, the asset levy, the supervisory framework and the policy environment for the energy-transition lending PKO has targeted3.

In 2026 those roles pointed in different directions. A shareholder wanting dividends would not raise the corporate income tax on its own bank from 19% to 30%4; a government financing defence spending would. The government chose, and the first-half accounts show the result: profit before tax up 19,9%, net profit up 3,1%5.

The alignment argument still exists and is worth stating. A state shareholder is a stable one, it has no interest in the bank failing, and it directs PKO toward lending the country needs.

The rest of the register is worth knowing for contrast. Nationale Nederlanden's pension fund holds 7,32% and Allianz Polska's 6,01%6 — Polish pension money, with an ordinary shareholder's interest in dividends and none of the state's other objectives.

Grade this on the effective tax rate rather than on anything the bank does. It is scheduled to fall to 26% in 2027 and 23% in 20287, and those two steps are worth more to PKO's earnings than any commercial decision available to management.

Moat trajectory: Narrowing

The State Treasury's 29,43% did not change. What changed is that the same shareholder legislated an eleven-point rise in the bank's tax rate, which is a demonstration rather than a risk.

The number that tests this moat
Reported
State Treasury holding
367 918 980 shares - 29,43% of capital and votes

Not a majority, and more than enough. There is one share class, so the votes and the economics match. The reason this is the number to watch is that the same shareholder legislated an eleven-point rise in the bank's tax rate in November 2025 - the conflict is demonstrated rather than theoretical.

Source: PKO Bank Polski S.A. Group Directors' Report for 2025 ↗
⚠ Threats to the moat
⚠ THREAT 01
A Government Has Uses for a Bank That Are Not Returns
A controlling shareholder that is also the government has objectives no minority holder shares.
References
  1. ReportedThe State Treasury holds 367 918 980 PKO shares — 29,43% of the capital and of the votes, the largest single holding by a wide margin, with two Polish pension funds holding a further 13,3%.
    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. ReportedThe State Treasury holds 367 918 980 PKO shares — 29,43% of the capital and of the votes, the largest single holding by a wide margin, with two Polish pension funds holding a further 13,3%.
    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. ReportedWhat it means in practice is that the largest shareholder is also the party that sets the tax rate on bank profits, the asset levy, the supervisory framework and the policy environment for the energy-transition lending PKO has targeted.
    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 ↗
  4. ReportedA shareholder wanting dividends would not raise the corporate income tax on its own bank from 19% to 30%; a government financing defence spending would.
    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 ↗
  5. ReportedThe government chose, and the first-half accounts show the result: profit before tax up 19,9%, net profit up 3,1%.
    PKO Bank Polski S.A. Group Directors' Report for the six months ended 30 June 2026, published with reviewed financial statements (profit before tax of 8 319m złoty up 19,9%, income tax of 3 029m up 67,4%, net profit of 5 290m up 3,1%, return on equity of 19,3%, cost-to-income of 31,4%, interest margin of 4,47% against 4,91%, cost of risk of 0,29%, total assets past 608 448m, 12,6 million customers, common equity tier 1 of 15,55%, and a further 685m złoty of convertible-currency legal risk) — H1 2026 · publ. 13 August 2026 · source ↗
  6. ReportedNationale Nederlanden's pension fund holds 7,32% and Allianz Polska's 6,01% — Polish pension money, with an ordinary shareholder's interest in dividends and none of the state's other objectives.
    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 ↗
  7. ReportedIt is scheduled to fall to 26% in 2027 and 23% in 2028, and those two steps are worth more to PKO's earnings than any commercial decision available to management.
    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 ↗
Sources
Generated September 24, 2026