Fintech 2025

CZECH REPUBLIC Law and Practice Contributed by: Ondřej Mikula, Jan Šovar and Markéta Klabouchová, FINREG PARTNERS

more trading venues, with the result of providing liquidity on a regular and frequent basis to the overall market. In this case, authorisation under the CMBA is required. Specific rules, such as carrying out the market-making continuously during a specified proportion of the trading venue’s trading hours and entering into a binding written agreement with the trading venue, apply. 7.3 Regulatory Distinction Between Funds and Dealers Unlike dealers, investment funds are only sub - ject to the applicable AT and HFT legislation if they are members or participants of regulated markets and MTFs. The main difference between an investment fund and a dealer is that a fund manager makes collective investment decisions for multiple investors according to a common strategy of the fund, whereas a dealer typically invests according to individual customer circum - stances. 7.4 Regulation of Programmers and Programming Programmers who develop and create trading algorithms and other electronic trading tools are not subject to any specific regulation in the Czech Republic, unless they also engage in a regulated activity (eg, HFT).

requires a CNB licence, while the latter only needs registration. Insurtech companies, regardless of their struc - ture, must adhere to the rules set out in the Insurance Act, including acting in the customer’s best interest and fulfilling information obligations before and during the contract. Furthermore, for online underwriting processes, commonly used by insurtechs, where the insured person is a consumer, the consumer protection provi - sions containing specific information obligations apply. 8.2 Treatment of Different Types of Insurance In the Czech Republic, life and non-life insurance products face different regulatory requirements, with the strictest rules applying to investment- based products (eg, pre-contractual obligations, appropriateness tests, conflict of interest rules, and remuneration policies). The life and non-life insurance markets are large - ly dominated by major insurers like Kooperativa (part of Vienna Insurance Group) and Generali Česká pojišťovna , who together hold about half of the market share. However, the insurtech segment is a key player in the growing fintech market in the Czech Republic, focusing mainly on non-life insurance products, such as sports equipment or property insurance products. 9. Regtech 9.1 Regulation of Regtech Providers Regtech providers in the Czech Republic are not specifically regulated but may fall under existing regulations depending on their activities. Since they primarily offer technical solutions to help regulated entities meet legal obligations rather

8. Insurtech 8.1 Underwriting Processes

The underwriting process for insurtech com - panies in the Czech Republic follows the same regulations as traditional insurance compa - nies. Insurtechs typically function as independ - ent intermediaries or tied agents. The former

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