Fintech 2026

POLAND Law and Practice Contributed by: Wojciech Ługowski, Lawarton Lugowski Kapica Spolka Komandytowa

6.5 Order Handling Rules Order handling rules apply to regulated financial markets, including securities and derivatives trading under MiFID II regulations. These rules ensure execu - tion under the best terms, transparency and fair client treatment. Brokers must prioritise price, speed and cost while avoiding conflicts of interest. KNF also sets specific order-handling rules for regu - lated markets, MTFs and OTFs. 6.6 Rise of Peer-to-Peer Trading Platforms P2P trading platforms are growing but remain smaller than traditional exchanges. They are mainly used by individual traders and offer privacy and diverse pay - ment methods but have lower liquidity. P2P trading reduces intermediaries, prompting fin - techs to adopt hybrid models. Regulators face AML/ CFT and investor protection challenges, as many P2P platforms lack KYC oversight, increasing risks. While P2P crypto-trading influenced DeFi regulations, its market impact remains limited. As regulations evolve, its remit may expand. 6.7 Rules of Payment for Order Flow Payment for order flow (PFOF) is restricted under MiFID II regulations, as it conflicts with best execution principles. Recent amendments introduce a complete phase-out by 30 June 2026. PFOF has never been widely adopted in Poland, as KNF strictly enforces best execution rules. Polish bro - kers generally avoid PFOF, meaning the 2026 ban will have little impact on the domestic market. 6.8 Market Integrity Principles Market integrity and market abuse regulations fall under the European Market Abuse Regulation (MAR), which is enforced alongside the Act on Trading in Financial Instruments and the Penal Code. KNF over - sees compliance and sanctions. Prohibited practices include insider trading and mar - ket manipulation, such as inflating volumes or spread - ing misleading price signals. UOKiK also monitors abuses affecting retail investors.

Poland has not yet adopted national implementing legislation for MiCA, as the crypto-assets bill passed by parliament was vetoed by the president. See 10. Blockchain . 6.3 Impact of the Emergence of Cryptocurrency Exchanges The emergence of cryptocurrency exchanges, both centralised and decentralised, has led to significant regulatory developments in Poland and the EU more broadly. As mentioned in 6.2 Regulation of Different Asset Classes , the EU introduced MiCA to regulate emerg - ing cryptocurrency exchanges, both centralised and decentralised. However, Poland is still working on the legislation to implement national rules and pro - cedures. See 10. Blockchain . 6.4 Listing Standards Listing standards for shares, bonds and crypto-assets differ significantly. Listing financial instruments on trading venues is highly regulated mainly by the Act on Public Offering, Conditions Governing the Intro - duction of Financial Instruments to Organised Trad - ing and on Public Companies, the Act on Trading in Financial Instruments and the Act on Supervision of the Securities Market. Polish legislation requires trading venue operators to have transparent rules for trading, admission of finan - cial instruments to trading and access to the trading venue. The criteria used on their systems must be objective. Furthermore, the trading rules must ensure fair and orderly trading. While traditional financial instruments are subject to well-established regulatory frameworks, crypto-assets are governed under the EU’s MiCA, which introduces a new set of listing requirements. As Poland has yet to finalise the national implementation of MiCA, crypto- asset listing standards remain in transition, with fur - ther details expected upon full regulatory adoption.

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