National rules on AVMs in mortgage lending in Slovakia, Czechia, Poland and Hungary

The rules compared

The last row is from EBA's compliance table for the guidelines, updated on 22 July 2025.

Slovakia

The rules sit in the Act on housing loans (90/2016) and in NBS Measure 10/2016 on assessing a consumer's ability to repay, which sets the collateral rules in Sections 7 and 8.

When the loan buys the home, the collateral value is "the lowest of the values ... equal to the purchase price, the price set by an expert and the price set on the basis of the internal valuation" (Section 7(7), our translation). For a home under construction it is the lower of the internal valuation of the finished home and the price in the construction contract (Section 7(8)). For other homes it is the internal valuation, or an expert's price no older than three years (Section 7(9)).

For the internal valuation, Section 8(2) allows two routes, an internal valuer's expert estimate of the price "that would be achieved on sale under usual conditions", or "a procedure involving monitoring of the property value, identification of the property that needs revaluation and revaluation of the property". Within that procedure, a statistical method monitors and identifies; material differences from general market prices are checked by the internal valuer (Section 8(4)). The internal valuer must be independent of the credit decision and hold a university degree in civil engineering with two years of practice (Section 8(3)).

Section 8(5) lists what the statistical data set must show, in particular properties from the bank's own contract documents, each property only once, three different characteristics that matter for value, a large and homogeneous enough sample, and a long enough time series.

The internal valuer revalues the book at least every three years, and within a year of a significant change in market conditions or of signs that a property's value may have fallen materially (Section 8(1)).

The loan-to-value ratio "cannot exceed 0.9" (Section 7(1)). Loans above 0.8 may not exceed 22 percent of new lending in the previous quarter and 20 percent in the previous half year (Section 7(2)).

On 28 September 2026 NBS adopted Measure 3/2026, which amends Measure 10/2016 from 1 January 2027 "to respond to the growing share of financing of investment purchases of real estate through housing loans" (official notice 251/2026 Z. z.). Public summaries of the NBS explanatory report describe a 90 percent limit for first-time buyers up to 35 and a 70 percent limit for a third and further property. Check the published measure before relying on the figures.

Czechia

The Consumer Credit Act (257/2016) requires the collateral for a housing loan to be valued "at the usual price or at market value under the law governing the valuation of property" (Section 113(3), our translation). The valuation must be impartial and objective and recorded on paper or another durable medium, and the people doing it must be trustworthy, professionally competent and sufficiently independent of the lending process.

We found no Czech statute or ČNB rule that names statistical valuation of collateral. CRR Article 208(3a) applies directly, and ČNB told EBA it intends to comply with the loan origination guidelines.

ČNB sets loan-to-value limits as a recommendation to lenders. Its decision of November 2025 kept 80 percent for homes and 90 percent for applicants under 36. For investment purchases it recommended, from 1 April 2026, an LTV of at most 70 percent and a debt-to-income ratio of at most 7. ČNB treats a purchase as an investment when the applicant buys a third or further residential property, or buys it to let.

Poland

Recommendation S of the Polish supervisor KNF (amended June 2023) covers mortgage lending. The LTV at disbursement "should not exceed" 80 percent, or 90 percent where the part above 80 percent has extra security such as insurance or blocked funds (15.5). Collateral is monitored at least every three years where the current LTV is below 80 percent, and yearly otherwise (16.1). A footnote ties monitoring to CRR Article 208 and its permission to use statistical methods.

Recommendation J (March 2023 version) covers the data behind valuation. It applies to banks whose mortgage exposures exceed 10 percent of their loan book. It lists reliable sources, among them notarial deeds, appraisal reports, the bank's own collateral assessments, mortgage lending values, land and building registers, land and mortgage registers, local plans, local transaction prices, statistics and construction cost catalogues (point 2.3). Banks with at least 2 percent of the national mortgage market should use statistical models built on reliable databases to assess the risk of changes in collateral value (recommendation 10), and should take part in an interbank database, which in Poland is AMRON.

Since 13 February 2026 the Polish register of property prices is free to use. That gives Polish banks and model providers a public benchmark the other three markets lack (our page on [asking and sale prices](/guides/asking-vs-transaction-prices-cee) has the details).

Hungary

For a new loan, Annex 5, point 2, of PM Decree 25/1997 lets a lender set the mortgage lending value from a statistical valuation report when all of these hold:

A land register extract no older than 30 days must also be submitted. The text of the annex was set in 2021 (PM Decree 4/2021) and amended in 2023 (GFM Decree 39/2023).

On top of the decree, MNB Recommendation 15/2021 asks lenders to write down which properties can be valued statistically, the data quality required and the role of the validating independent valuer (section 5.2, point 2). "In the case of a valuation model based on AVM (automated valuation model) technology", it also asks for written requirements for the model, the responsibilities and up-to-date documentation. It recommends statistical valuation only for properties held in a single 1/1 share (point 6), and it expects lenders to compare statistical values with the prices achieved when collateral is later sold (point 8).

The MNB accepts statistical revaluation of residential collateral. An individual valuation is needed when the index shows a fall beyond the bank's threshold, or when the bank wants to recognize a rise beyond it; the MNB considers a threshold of no more than 20 percent good practice (points 25 to 27). The index rules are covered in our page on [collateral revaluation and indexation](/guides/collateral-revaluation-indexation-crr3).

For a forint mortgage the exposure "may not exceed 80 percent of the market value" of the property (MNB Decree 32/2014, Section 3(1), our translation).

What this means for a lender using a model

• In all four countries, a model may monitor collateral and flag properties for revaluation under CRR Article 208(3a), with the six conditions met.
• At origination, only Hungary's national rules expressly let a statistical value carry a loan, and only up to 60 percent LTV for a defined set of flats.
• Slovakia's internal valuation can rest on a statistical procedure, with the internal valuer checking material differences and the data set meeting Section 8(5).
• In Poland, the source of the data is regulated as closely as the model.

Where Bytero Engine fits

Bytero Engine values flats from the inputs a lender holds at monitoring time: address, floor area, year of construction, floor and number of storeys. In the Bytero app, each value is shown with the inputs it used and the comparable flats behind it. That is the kind of record the national rules above ask a lender to keep. A bank remains responsible for the model it uses and for meeting its supervisor's conditions.