Name
Global FinTech Guide
Country _ Name
Poland
SectionTitle
Asset and portfolio management
Body
FinTechs belonging to this category offer asset and portfolio management services via an internet platform or software programs and usually manage and dispose of the assets of their customers long or short term according to their specifications without actually holding the property or the possession of those assets. FinTechs, which provide information about and access to overnight or time deposit accounts at national and foreign banks and which execute the transactions to these accounts, also belong to this category. Some FinTechs however only act on request of the customer.

Aside from that some FinTechs offer software or internet solutions enabling users to manage and plan their personal finances on their own by providing graphics, overviews and compilations of their financial data and sometimes indicating financial risks or opportunities, but without actually managing the assets.

Introduction

Attitude of the country towards modern asset and portfolio management services

Compared to developed foreign markets, companies operating in this category are characterized by a small scale of operations. So far, this has been due to relatively high levels of operating costs and much lower personal wealth of Polish people than those in Western Europe. The median net household wealth in Poland is about 55–60% of the euro area median, and average assets per person are markedly lower than in Western European countries. The Polish economy, like the economies of other countries in the Central and Eastern Europe, is still characterized by a relatively low level of financial intermediation compared to the euro area countries. Polish households still prefer bank deposits over investments in capital markets, contributing to the dominance of banks and lower market-based intermediation.


Legal affairs

Obligations and requirements to provide asset and portfolio management, or ancillary services described above

In Poland, asset management services, understood as management of cash or financial instruments, may be provided by brokerage houses and investment fund companies (depending on the exact type of asset management services provided by a given entity).

The Act on Investment Funds and Alternative Investment Fund Management (Ustawa o funduszach inwestycyjnych i zarzadzaniu alternatywnymi funduszami inwestycyjnymi) provides the legal basis for the granting of permits and the rules of operation of investment fund companies (TFI)

An investment fund company may only be a joint-stock company with its registered office in Poland, which has been authorized by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego) to conduct business. The license to conduct business activity as an investment fund company is subject to a fee of EUR 4,500. The basic value of the initial capital of the company must be at least EUR 125,000, in some cases the initial capital must be higher and amount to EUR 730,000.
Consent for the extension of the scope of activities of an investment fund company to include (i) investment advice - is subject to a fee of EUR 2,000, (ii) management of portfolios that include one or more financial instruments - is subject to a fee of EUR 2,500, (iii) reception and transmission of orders to buy or sell financial instruments - is subject to a fee of EUR 1,000.

To enable a joint-stock company to commence operations as an investment fund company (TFI), it must simultaneously apply for a permit to establish an open-end investment fund (FIO). Conversely, if the company intends to manage alternative investment funds (AFI), it must concurrently apply for a permit to manage AFI.

Brokerage activities may be conducted based on a permit granted by the Financial Supervision Authority (Komisja Nadzoru Finansowego). The legal basis for granting authorizations and rules of conducting brokerage activity is the Act on Trading in Financial Instruments (Ustawa o obrocie instrumentami finansowymi). Brokerage activities may be conducted, among others, by brokerage houses. The amount of the fee for brokerage activity permits depends on the scope (types) of brokerage activity for which the permit is granted. The maximum amount of fees charged may not exceed EUR 4,500. The initial capital of a brokerage house for conducting brokerage activity is, as a rule, at least EUR 125,000.

If the FinTech offers ancillary services involving the initiation of a payment transaction (Payment Initiation Service, 'PIS') or access to account information (Account Information Service, 'AIS'), its activities are regulated by the provisions of the Payment Services Act (ustawa o uslugach platniczych).

Activity as an AIS provider is a regulated activity and requires prior registration in the register of payment service providers and electronic money issuers kept by the Financial Supervision Authority (Komisja Nadzoru Finansowego). The entry in the register is subject to a fee of PLN 616 (approx. EUR 130).
In the case of PIS and AIS services, a Financial Supervision Authority permit to operate as a domestic payment institution ('KIP') is required. The cost of the licensing process is EUR 1,250.

The initial capital required to operate as a domestic payment institution is subject to the scope of services to be provided (ranging from EUR 20,000 to EUR 125,000). In order to provide PIS and AIS services, the KIP needs to obtain an initial capital of EUR 50,000. AIS-only services are not subject to minimum capital requirements. The initial capital cannot be encumbered in any way, therefore it is prohibited for KIPs to use debt financing in order to expand their services.

Additionally, under the European Union’s Regulation on Markets in Crypto-assets (‘MiCA’) regime, among others, providing investment advice regarding crypto-assets, management of crypto-assets portfolio and execution of crypto-related orders on behalf of clients will be regulated as crypto-assets services (‘CAS’). Under the MiCA regulation, as of 31 December 2024, businesses willing to providing these services will be subject to the supervision of the Financial Supervision Authority (Komisja Nadzoru Finansowego
) and will need to obtain a license (as a ‘CASP’). The wording of MiCA precises that the minimal capital required for businesses providing the services described above will be EUR 50,000. According to the draft Crypto-Assets Market Act (Ustawa o rynku kryptoaktywów) submitted to the Polish parliament on June 26, 2025, the maximum fee for a permit to conduct a public offering of asset-linked tokens is not to exceed EUR 4,500. Similarly, the fee for a permit to operate as a crypto-asset service provider is also not to exceed EUR 4,500.

Additional comments regarding the legal situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

N/A


Economic conditions

Market size for asset and portfolio management services and biggest companies in this business area

The value of household financial assets has doubled from 2013 to 2023 - from PLN 1.523 trillion to PLN 3.072 trillion (i.e. to approximately EUR 707 billion in total). Deposits and cash constitute 51.9% of household financial assets in Poland. No official statistics have yet been published for the full year 2024 or for 2025, so the most recent verified figure remains at the end of 2023. Nevertheless, the structure of assets remains conservative, with deposits and cash prevailing.

The value of investment fund assets in Poland increased in May 2024 by nearly 2.4% compared to the previous month, reaching PLN 350.4 billion (approx. EUR 66 billion).

Additional comments regarding the economic situation for asset and portfolio management services or what FinTech’s must be aware of in this business area

Personal Finance Manager applications are offered in Poland both by non-banks, such as Kontomierz, and by banks, (for example Millennium - Manager Finansów) for several years now. Banks are still developing and promoting their own PFM modules within banking apps (mBank mobile app, IKO offered by PKO Bank Polski S.A.).

Among their investments, Polish people in 2023 most often indicate their own education, and besides - metals, treasury bonds, cryptocurrencies and deposits in PLN. A recent study confirmed that Polish people value traditional secure investments, even if it may bring less financial benefits.

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