Global Legal Insights – Fintech 2026: Poland’s map of innovation and regulation
We have authored the Polish chapter of the eighth edition of Global Legal Insights Fintech 2026.
The publication offers a comprehensive analysis of the most significant regulatory developments and market trends in fintech – from the growth of digital payments to the rapid expansion of RegTech and InsurTech.
There is good reason why the Polish perspective should be of particular interest to European and global players.
Poland is currently one of the most innovative payment markets in Europe, with exceptionally high adoption rates for mobile and digital payments. A prime example is BLIK – simple to use and deeply embedded in everyday life.
Poles have developed models of effective cooperation between banks, regulators and fintechs that are now becoming a benchmark for building European payment sovereignty.
Having rapidly transitioned from traditional to mobile payments, Poland now offers unique expertise in scaling innovation through infrastructure, building trust in digital financial tools and striking the right balance between market dynamics and regulatory requirements.
For companies planning to expand into the CEE region or seeking inspiration to build their own payment ecosystems, Poland’s fintech landscape is a valuable source of insight.
A mature digital market and the B2B2C model
By 2026, Poland has become a digitally mature market, where mobile banking, remote onboarding and cashless payments are now the standard.
The best evidence of this maturity is BLIK’s performance: in 2025, the system processed nearly 3 billion transactions worth EUR 101.5 billion, with the number of active accounts reaching 20.7 million. Poland demonstrates that a shared payment infrastructure can be a powerful driver of change.
The market is moving towards partnerships and embedded services. As a result, fintech companies provide technological solutions such as payment services, analytics, AML tools and cloud infrastructure, with their clients ranging from regulated banks to non-financial platforms. The B2B2C model is becoming dominant, whereby the institution maintains the client relationship while a specialised partner provides the technological layer.
“The Polish fintech sector today is full of contrasts. On the one hand, Poland is at the forefront of digital payments in Europe, but on the other, it is a country where, in the area of crypto-assets, EU harmonisation has outpaced the creation of the national framework needed for the full application of MiCA. This tension between innovation and the capacity of the regulatory apparatus is currently the greatest challenge facing our financial sector clients,” notes Robert Brodzik, Counsel at Kochański & Partners and co-author of the publication.
Fintech – why Poland’s innovation market deserves attention
Payments and digital banking
These are by far the strongest segments of Polish fintech. This is why we examine the BLIK ecosystem, the PolishAPI standard for open banking and the upcoming obligations under the Instant Payments Regulation. In 2027, these obligations will extend to further categories of Polish payment service providers – covering both the receipt and the sending of instant credit transfers in euro.
We also track BLIK’s expansion across Europe, including its interoperability with other European mobile payment systems, which is being developed through the EuroPA alliance.
RegTech – technology and compliance
Polish financial institutions face increasing pressure from the DORA Regulation, EBA/ESMA supervisory reporting requirements and AML/CFT obligations. This creates a natural environment for robust RegTech solutions.
We therefore analyse the key tensions arising in contracts between technology providers and, for example, banks, and seek answers to questions such as who is responsible for ensuring that the implemented tools remain ‘regulatorily up to date’.
We also examine the growing role of e-KYC solutions and the Innovation Hub programme run by the Polish Financial Supervision Authority (UKNF), which serves as a channel for dialogue with the market.
InsurTech – the current state of innovation in insurance
As Poland is the largest non-life insurance market in the EU part of Central and Eastern Europe, our report discusses InsurTech business models, including telematics, claims automation, embedded insurance and cyber insurance.
We highlight the challenges associated with the processing of special categories of personal data (Article 9 GDPR) and cybersecurity requirements, particularly those arising from the DORA.
Crypto-assets – what does the landscape look like after MiCA?
This is currently the most pressing topic in the Polish fintech sector.
Although the MiCA Regulation has been fully applicable across the EU since 30 December 2024, Poland still lacks a national competent authority empowered to grant CASP licences.
On 15 May 2026, the Sejm adopted the Crypto-Assets Market Act, however, the President referred it back for reconsideration. The transitional period expired on 1 July 2026, meaning that registration in the register of virtual currency activities no longer entitles an entity to provide crypto-asset services. Polish customers can be served by entities authorised in another EU Member State operating in Poland on a cross-border basis, but Polish entities are still unable to obtain a CASP licence domestically.
This means that the availability of a service on the market must not be confused with the right to provide it.
What is Global Legal Insights?
Global Legal Insights is a renowned series of international publications by Global Legal Group, authored by lawyers from around the world. It serves as an up-to-date and practical guide to applicable regulations, supplemented by expert commentary on specific areas of law and jurisdictions.
GLI combines legislation and practical know-how in one resource.
Authors:
- Natalia Kotłowska-Wochna
- Robert Brodzik
- Magdalena Róża Petrow-Ganew
- Zuzanna Kielak
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