Name
Global FinTech Guide
Country _ Name
Poland
SectionTitle
Loan services/factoring/loan broking/finetrading
Body
FinTechs belonging to this category act as a loan creditor (even short and very short-term loans), are broking loans or receivables or conduct factoring of loans, which were given to private or business customers. In this business area you also find “peer-to-peer” (P2P) services, in which FinTechs enable a multitude of users to give loans (and brokered by the FinTech-platform) to other users or companies.

Finetrading is hereby a financial service of FinTechs, where they buy due receivables and grant the debtor an extension of payment time. 

As an ancillary service some FinTechs offer alternative credit assessment services to check the solvency of a borrower.

Introduction

Attitude of the country towards loan-giving-, factoring-, brokerage-, finetrading- and ancillary services

Poland maintains a generally positive attitude towards loan-giving, factoring, brokerage, and ancillary financial services, recognizing their importance for business financing and economic growth. The sector is largely unregulated, with most of these services not requiring specific licenses or permits, which creates a favorable environment for market development and competition. The primary regulatory requirements focus on Anti-Money Laundering (AML) obligations, ensuring compliance with international standards for financial crime prevention. This positive regulatory stance is significantly influenced by the fact that these services are primarily offered to business entities rather than retail consumers, which reduces the need for extensive consumer protection measures. The relatively light regulatory framework allows for innovation and flexibility while maintaining essential safeguards against financial crime through AML compliance requirements.


Legal affairs

Obligations and requirements to provide loan-giving-, factoring-, brokerage-, finetrading, and ancillary services described above

Under the currently applicable Act of 12 May 2011 on consumer credit (ustawa o kredycie konsumenckim), if a FinTech is not a bank or a cooperative savings and credit union, it must have the status of a loan institution if it wishes to enter into consumer loan agreements.

A consumer loan agreement is understood to be a loan agreement in an amount not exceeding PLN 255,550 (approx. EUR 54,040), which the creditor, within the scope of its activities, grants or promises to grant to the consumer. For example, loan agreements or Buy Now Pay Later services fall into this category. If the same services are offered to business entities rather than consumers, loan institution status is not required.

Loan institutions wishing to start legal activity should be registered as limited liability companies or joint stock companies with at least PLN 1000,000 (approx. EUR 235,500) share capital. Loan institutions must be entered in the Register of Loan Institutions kept by the Financial Supervision Authority (Komisja Nadzoru Finansowego). Filing an application for entry costs PLN 600 (approx. EUR 140).
If, in its operations, the FinTech will offer services such as, for example, execution of payment transactions, money transfers, initiation of a payment transaction or access to account information (and others listed in the Payment Services Act (ustawa o uslugach platniczych)), it will be necessary to obtain a relevant license.

Factoring is not a regulated activity in Poland. Therefore, running such activity by FinTech is associated with low barriers to entry.
If P2P-services are addressed to consumers and not the entrepreneurs and such platform receives remuneration, it will need to be registered as a credit intermediary maintained by the Financial Supervision Authority. The cost of an application for entry of a credit intermediary into the register of credit intermediaries is PLN 600 (approx. EUR 140).

It should be noted that, in the context of the services mentioned above, there may be an obligation to apply the provisions of the Directive (EU) 2023/2225 on consumer credit agreements („CCD2”), which is currently being implemented into national legal systems, including Polish law. The Polish version of the implementation draft was published on 7 July 2025. This directive introduces and refines a number of obligations related to the provision of consumer credit, in particular with regard to pre-contractual information, creditworthiness assessment, the form in which contracts are concluded, and the transparency of digital interfaces. It also broadens the scope of application compared to the previous 2008 Consumer Credit Directive, extending coverage to a wider range of credit products. These obligations apply in situations where financing is provided to a consumer, i.e., a natural person entering into a credit agreement for purposes not directly related to their business or professional activity.

However, it should be emphasized here that on 7 July 2025, a draft of a new Consumer Credit Act was published on the website of the Government Legislation Centre. The new act aims to fully implement the Directive (EU) 2023/2225 on consumer credit agreements („CCD2”) which means replacing the existing polish act of 2011 and harmonising regulations with other EU countries. It is scheduled to enter into force on 20 November 2026.

This is a key piece of legislation that will be of significant importance for the consumer targeted fintech sector in Poland . This means adapting their business models, user interfaces and verification processes to more stringent consumer protection standards and transparency requirements.

The new draft act removes the maximum credit amount thresholds,
which will result in the proposed act covering the entire consumer credit market. Also the material scope of the current Act of 2011 will be significantly expanded, e.g.: in addition to traditional loans and credits, it will also cover rental and lease agreements with an option to purchase, as well as, in principle, deferred payments (so-called “BNPL”), credit lines in savings and current accounts and even interest-free loans. The new regulations also introduce strict rules on advertising since it will be prohibited to suggest that taking out a loan will improve the consumer's life situation, and all advertisements will have to include a clear warning that taking out a loan involves costs.
In addition, the legislator emphasizes transparency as the information forms will be simplified (key data must be included on the first page), and lenders will be required to accurately assess the customer's creditworthiness.  Failure to do so may result in a so-called free credit sanction.

The draft law also implements EU Directive 2023/2673 on distance financial services contracts, imposing additional requirements on online interfaces and withdrawal procedures. It mandates that online financial service providers present key information clearly before contract conclusion and prohibits "dark patterns" that mislead users or hinder contract withdrawal. The draft will undergo public consultation, though changes are likely to be minor since it primarily implements EU directives, limiting legislative flexibility.

Additional comments regarding the legal situation for loan-giving-, factoring-, brokerage, finetrading-, and ancillary services or what FinTech’s must be aware of in this business area

As with offering most services in the FinTech category, companies must comply with AML and RODO regulations.


Economic conditions

Market size for loan-giving-, factoring-, brokerage-, finetrading- and ancillary services and biggest companies in this business area

In 2024, the number of loans granted by lending companies reached approximately 14.4 million (specifically 14.463 million), representing a significant increase compared to 2023. For instance, the number of cash loans granted rose by 31.6%, and purpose-specific loans by 52.4% compared to 2023.

The total value of financing provided in 2024 exceeded PLN 21.7 billion (approx. EUR 4.9 billion), marking a 49% growth compared to 2023. The value of granted cash loans amounts to PLN 15.034 billion (approx. EUR 3.546 billion) increased by 49.6% year-on-year, and purpose-specific loans amounts to PLN 6.135 billion (approx. EUR 1.447 billion) and increased by 52.4% compared to 2023.

Currently, over 30 entities operating in the Polish factoring market are members of the Polish Factors Association (Polski Zwiazek Faktorów). This group includes both bank-affiliated institutions and specialized financing companies. Beyond these members, numerous other factoring providers also operate in Poland.

The P2P lending market is only moderately developed in Poland compared to other countries.
Finetrading market practically does not exist.

Additional comments regarding the economic situation for loan-giving-, factoring-, brokerage-, finetrading- and ancillary services or what FinTech’s must be aware of in this business area

Poland has recently seen a consistent decrease in the reference rate set by the National Bank of Poland (NBP), which contributes to a gradual reduction in the cost of financing. This development is expected to support increased lending activity, provided that overall market conditions remain stable.

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