POLAND Law and Practice Contributed by: Wojciech Ługowski, Lawarton Lugowski Kapica Spolka Komandytowa
1. Fintech Market 1.1 Evolution of the Fintech Market The Evolution of the Fintech Market in Poland in 2025 Over the last 12 months, the Polish fintech market entered a phase of regulatory consolidation and execution. While 2024 was largely characterised by legislative design and policy debate at the EU level, 2025 marked the moment when key regulatory frame - works began to produce tangible operational, organi - sational and cost-related consequences for market participants. This shift has been driven primarily by three interre - lated regulatory developments: the application of the EU Digital Operational Resilience Act (DORA), the first full year of the EU Markets in Crypto-Assets Regula - tion (MiCA) in practice, and the gradual entry into force of the EU Artificial Intelligence Act. Together, these regimes are reshaping how fintechs in Poland design products, manage technology risk and structure their internal governance. Outlook: What Will Shape the Market in the Next 12 Months Looking ahead, the Polish fintech market is expected to be shaped primarily by the deepening practical application of existing regulatory regimes rather than by new legislative initiatives. AI governance will become a central compliance topic as firms prepare for the next phases of the AI Act’s application, including more extensive obligations related to high-risk systems and general-purpose AI models. At the same time, supervisory practice under DORA is likely to intensify, with greater attention paid to inci - dent handling, testing outcomes and third-party risk management. In the crypto-asset space, much will depend on whether and how the Polish legislature revisits the national framework following the presidential veto. The resolution of this issue will be critical for determin - ing Poland’s long-term position within the EU crypto- asset market.
Overall, if 2024 was the year of regulatory architec - ture, 2025 can be seen as the year in which regula - tion began to meaningfully shape fintech operations in Poland, with the next 12 months likely to test the resilience, governance maturity and strategic flexibility of market participants.
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
Polish fintech companies operate through various models. Payments are the dominant sector, followed by online currency exchange and alternative lending. Banks also integrate fintech solutions, driving innova - tion. Poland’s fintech landscape spans digital payments, alternative lending, wealth management, insurtech, regtech and blockchain-based financial services. Digital Payments Fintech firms develop infrastructure for seamless pay - ment processing, mobile transactions and banking services. The sector is dominated by digital wallets, contactless payments and online banking. Lending and Alternative Financing Alternative lending platforms provide financing for consumers and SMEs using AI-driven risk assess - ment and alternative credit scoring. Peer-to-peer (P2P) lending, marketplace lending and buy now, pay later models enhance financial flexibility and reduce dependence on traditional banks. Wealthtech and Investment Solutions Wealth management platforms utilise automation, robo-advisers and algorithmic trading to optimise investment strategies. Retail investors gain access to diversified portfolios, fractional investing and alterna - tive assets with lower entry barriers. Insurtech and Digital Insurance Models AI and data analytics enhance underwriting, claims processing and risk assessment. Insurance models adapt to consumer needs with personalised, usage-
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