Name
Global FinTech Guide
Country _ Name
Poland
SectionTitle
Crowdfunding/crowdinvesting/crowdlending
Body
FinTechs belonging to this category operate crowdfunding, crowdinvesting and crowdlending platforms on which money is raised to invest in various projects, mainly start-up companies and real estate projects.

Crowdfunding is not a defined financial service, but generally used to describe donation-based crowdfunding (the investor donates the money to the project), reward-based crowdfunding (the investor receives an often symbolic consideration for his investment), equity-based crowdfunding (crowdinvesting: the investor participates in the profits of the financed project or acquires shares or debt instruments) or lending-based crowdfunding (crowdlending: the investor is reimbursed at the end of the project with or without interest).

Introduction

Attitude of the country towards crowdfunding, crowdinvesting and crowdlending platforms

The crowdfunding market in Poland experienced a significant slowdown after its 2021 peak, mainly due to high inflation and economic uncertainty. However, by 2025, the market has stabilized, with investors gradually regaining interest, although many still prefer safer instruments such as bank deposits..


Legal affairs

Obligations and requirements to provide crowdfunding, crowdinvesting and crowdlending platforms described above

The main act regulating equity-based and lending-based crowdfunding is Regulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European crowdfunding providers for business ventures (“Regulation 2020/1503”). In Poland, Regulation 2020/1503 has been implemented through the Act of 7 July 2022 on crowdfunding for business ventures and assisting borrowers (‘Crowdfunding Act’).

Regulation 2020/1503 and the Crowdfunding Act provide for the need to obtain a license, therefore adhering the supervision of crowdfunding platforms to the Financial Supervision Authority (Komisja Nadzoru Finansowego). Since July 2022, all businesses willing to provide investment-, loan- or hybrid model of crowdfunding services need to apply to the Financial Supervision Authority  for a license to provide these services.

As a result of Regulation 2024/1624 (AML Regulation), crowdfunding platforms operating in Poland are now subject to directly applicable, EU-wide AML/CFT obligations. These include, among others, the implementation of AML policies, the identification and verification of clients and beneficial owners, risk assessment, ongoing monitoring and reporting of transactions, record-keeping, and the verification of sanctions lists and politically exposed persons (PEP). The new rules, fully applicable from July 2027, will have a significant impact on the day-to-day operations of crowdfunding platforms. As a result, platforms will need to update and expand their compliance systems, invest in new KYC and transaction monitoring tools, and ensure staff are adequately trained to meet these heightened regulatory requirements.

Additionally, concerning “loan crowdfunding”:
  • where providers of crowdfunding provides credits directly to consumers - the Directive (EU) 2023/2225 on consumer credit agreements („CCD2”) applies ,
  • where providers of crowdfunding facilitate granting of credit between lenders and consumers - the obligations for credit intermediaries under CCD2 applies.
According to the provisions of CCD2, by 20 November 2025 the Commission will assess the need to protect consumers borrowing and investing through crowdfunding platforms where these platforms do not act as lenders or credit intermediaries, but facilitate credit between consumers.

This means that the crowdfunding service providers acting as a lender as well as a credit intermediary are  covered by the detailed obligations under CCD2. Member States have to adopt legislation implementing CCD2, until 20 November 2025 and the provisions must enter into force by 20 November 2026. On 7 July 2025, a Polish draft implementation of CCD2 was published and is scheduled to come into force in November 2026.

From a consumer law perspective (irrespective of the scope of Regulation 2020/1503), when practices are used that mislead or distort the consumer's decision-making process, a provider may be found liable for misleading or misselling and therefore in breach of the collective interests of consumers or unfair commercial practice subject to high financial penalty.

The activities of crowdfunding platforms are monitored on an ongoing basis by the Financial Supervision Authority, which pointed out the necessity to construct advertisements in a reliable and accurate manner, as ‘running an advertisement that misleads an investor may be qualified as an act of unfair competition or unfair market practice’. The authority points to the great need for investor protection and makes it clear that if basic principles - such as providing clear and transparent information needed to make a given decision - are not respected towards them, providers of funding services can be held liable under legislation designed to protect consumers.

Also the Polish Financial Ombudsman is active in the crowdfunding sector. In June 2023, he addressed letters to the Financial Supervision Commission and the Polish consumer protection authority (the President of the Office of Competition and Consumer Protection), in which he pointed out a number of concerns regarding the company ‘Skarbiec Palikota’, on the crowdfunding platform.

Additional comments regarding the legal situation for crowdfunding, crowdinvesting and crowdlending platforms or what FinTech’s must be aware of in this business area

Crowdfunding platforms should operate on the basis of adopted regulations, which include regulations referring directly or indirectly to the provisions of the Act on Rendering Electronic Services (ustawa o swiadczeniu uslug droga elektroniczna). This applies, in particular, to general and specific information obligations, such as clear identification of the service provider or ensuring that the recipient of the service has access to information about risks associated with using the service and its function and purpose.
As an aside, we point out that entrepreneurs operating their business on platforms should examine whether and to what extent the provisions of the Digital Services Act of 19 October 2022 apply to them.


Economic conditions

Market size for crowdfunding, crowdinvesting and crowdlending platforms and biggest companies in this business area

Donation-based crowdfunding is estimated to be worth PLN 1.1 billion in 2023, approximately 10% less than in 2022. Internet users contributed over PLN 250million (approx. EUR 59 million) to Zrzutka.pl in 2024.

Only four companies in Poland (Finansowo.pl, Crowd Real Estate, Europpa, Emiteo) have necessary license for operating as European crowdfunding services provider.

Additional comments regarding the economic situation for crowdfunding, crowdinvesting and crowdlending platforms or what FinTech’s must be aware of in this business area

The high level of awareness of the market itself and of the mechanisms operating on it, as well as the involvement of a large group of Internet users in online promotion, especially in social media, can be considered a new trend in the crowdfunding market in Poland.


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