Evolving financial services regulation in Poland: Key developments and implications
Financial services regulation Poland is changing quickly as EU reforms, stricter consumer protection and increased supervisory scrutiny reshape the market for firms operating in the country.
The introduction of new EU financial regulations is driving increased demand for legal support as clients navigate the complex regulatory landscape.
This trend is particularly evident in Poland, one of the most dynamic financial markets in Central and Eastern Europe. While the Polish regulatory framework is largely aligned with that of the EU, the market does demonstrate some quirks which impact the implementation and enforcement of financial services regulation. These nuances require careful consideration by both external law firms and in-house legal teams seeking to advise clients on market entry, operations and compliance in the region.
Impact of EU-level developments
Poland’s regulatory landscape is heavily influenced by their Financial Supervision Authority, known as the Komisja Nadzoru Finansowego or KNF, which operates within broader EU regulatory frameworks. The introduction of the Data Act, MiCA (the EU regulatory framework for crypto assets) and the AI Act at EU level therefore impacts frameworks in Poland:
“Implementation of new EU financial regulations involves the phased application of MiCA, DORA, and PSD3/PSR, which will necessitate ongoing legal support to interpret technical standards, update governance and contractual frameworks, and ensure operational compliance across the organisation.”
– Polish market participant
In light of Poland’s approach to GDPR, which is seen by some as particular stringent in comparison to other EU countries, some market observers anticipate a similar approach in relation to AI regulation. In parallel, anti-money laundering continues to be a key topic for regulators. FSR companies are subject to Poland’s two-tier system for preventing money laundering and terrorism financing, in the form of the GIIF, Poland’s financial intelligence unit, alongside the KNF, reflecting an enhanced emphasis on AML and counter-terrorism financial compliance. At the same time, the rapid growth of the FinTech sector has prompted heightened regulatory scrutiny in relation to financial institutions and e-payment services. The significant growth in transaction volumes processed by these entities has, in turn, driven increased supervisory attention and enforcement activity.
Consumer protection
Consumer protection continues to be a critical area of regulatory focus, especially in light on the recent regulatory changes in this area, namely the introduction and implementation of the revised CCD2, the EU’s updated Consumer Credit Directive, which is expected to significantly impact the lending market. Poland’s consumer protection authority is known for being particularly active and has had the financial services sector in its sights for some time now. Non-compliance in this area carries the risk of significant fines and reputational damage, meaning that law firms are seeing increasingly complex cases as financial institutions consider their compliance frameworks and operational risk:
“We have an extremely active consumer protection authority which has been focused on the financial services sector in terms of reviewing the terms of the products, terms relating to liability for unauthorised payments, and they've taken a very harsh view of what the obligations of the financial services institutions are.”
– Dr Marcin Olechowski, Managing Partner at Sołtysiński Kawecki & Szlęzak
Cross-border implications
Geo-political dynamics continue to shape the regulatory environment for cross-border financial service providers. Poland’s proximity to Ukraine means it is acutely impacted by the instability in the region. Furthermore, evolving regulation relating to foreign direct investment and cross-border licenses will influence foreign companies operating in Poland. While Polish regulators are generally perceived as applying a lighter supervisory touch to institutions operating on a purely cross-border basis, the risk of inclusion on the KNF’s public warning list for non-compliance remains a significant concern. Consequently, legal advisers are frequently engaged to support clients in navigating these risks.
Key takeaways
Over the next 12–18 months, the Polish regulatory landscape is expected to undergo significant further development, driven by both EU-level initiatives and domestic enforcement priorities. Increased supervisory scrutiny and enforcement activity are anticipated, particularly in relation to AI, payment services and consumer protection. Against this backdrop, law firms and in-house legal teams will continue to play a critical role in supporting clients as they address regulatory complexity, mitigate risk, and ensure ongoing compliance in a rapidly evolving environment:
“I would expect enforcement to grow. I would expect the product related work to continue to be fairly important, the CPA does not seem to be letting anyone off the hook, and there will be a lot of uncertainty related to the new consumer rules, that will impact the structuring of work. Obviously, AI related work will be playing a significant part because we see it at various levels.”
– Dr Marcin Olechowski, Managing Partner at Sołtysiński Kawecki & Szlęzak