Name
Global FinTech Guide
Country _ Name
Poland
SectionTitle
InsurTech
Body
InsurTech is composed of the words “insurance” and “technology”. It is used as a collective term for the application of modern technologies in the domain of insurance services.

Digital and mobile brokers: FinTechs belonging to this category mostly act as digital insurance brokers and provide users with an overview of their insurance contracts with their respective conditions. Some FinTechs offer very short-term insurance contracts to cover specific cases which can be concluded often spontaneously via mobile devices. Oftentimes additional consulting services are offered.

Internet of things: FinTechs belonging to this category collect data by measuring for example the driving style of the customers or through wearables the customers wear to consult on, offer and/or manage the customer’s insurances.

Introduction

Attitude of the country towards InsurTech-services

The social and political climate towards InsurTech is quite neutral. Many entities on the market are trying to attract clients to InsurTech solutions e.g., apps used in loss adjustment or vehicle telemetric for motor insurance (e.g. https://payhowyudrive.pl/ in cooperation with Yanosik app for drivers)., Clients are still quite reluctant towards such solutions, however things are changing as new generations of young adults are entering the market.

The Financial Supervisory Authority (Komisja Nadzoru Finansowego) officially promotes InsurTech solutions. However, the regulatory environment is not well prepared for InsurTech services. InsurTech start-ups are bound by the same regulatory framework as typical insurance intermediaries. There are no dedicated exclusions for InsurTech companies.


Legal affairs

Obligations and requirements to provide InsurTech-services

InsurTech services in Poland must be divided into two main groups: (1) insurance distribution and (2) outsourcing services supporting insurance undertakings:

Insurance distribution

Polish regulation of insurance distribution implements the EU directive on insurance distribution (IDD). Polish regulation provides for 4 categories of insurance distributors: insurance undertakings, insurance brokers, insurance agents, insurance agents offering ancillary insurances.

Many domestic insurance undertakings use the InsurTech solutions. There are also branches of foreign insurance undertakings from other EU countries and EU based insurers acting in Poland on the basis of EU freedom of services (FoS) -latest entry to the Polish market is redclick.pl online insurance platform provided by Italian insurance undertaking Genertel S.p.A. (Generali group).

Insurance brokers in Poland typically do not offer InsurTech services as their activity is usually focused on mediation regarding sophisticated insurance programmes for corporate clients. Insurance brokers on the Polish market practically do not act for typical consumers.

InsurTech entities typically offer client comparison websites or apps. If such a website or app offers the possibility to conclude an insurance contract the entity should be registered as an insurance agent. Comparison websites are usually insurance agents acting for multiple insurance undertaking: so-called multi-agents. Insurance agents are regulated entities which should be registered in the register kept by the Polish Financial Supervisory Authority.

The registration of and insurance agent is possible after executing agency agreement with insurance undertaking.

There are no requirements regarding running costs and financial reserves of an insurance agent.

There are also some statutory fit and proper requirements which should be met by board members of the insurance agency company and every physical person performing agency activities - those requirements are the following:

  • having full legal capacity – that requirement is usually confirmed by written declarations of individuals;
  • having a clean criminal record regarding willful commission of:
    • an offence against life and health,
    • an offence against a system of justice,
    • an offence against protection of information,
    • an offence against credibility of documents,
    • an offence against property,
    • an offence against economic trading,
    • an offence against trading in money and securities,
    • a fiscal offence,
      • those criteria are confirmed by the criminal record certificate issued by the Ministry of Justice (cost around EUR 10 per person);
  • giving a guarantee of due performance of agent-based activities
– that is a criterion which is, in a sense, fit and proper but does not need to be confirmed by a document. The PFSA may question particular individuals who have 'a wrong history with the PFSA. In typical cases, fulfilment of that criterion is not questioned;

  • having at least secondary or vocational education – fulfilment of that criterion is confirmed by an adequate certificate;
  • having passed an exam conducted by an insurance undertaking – insurance undertaking engaging agents have to conduct the exam and issue a results certificate.
In practice, the authorised employee of insurance undertaking who submits electronically the applications to the Financial Supervisory Authority register of insurance intermediaries kept by the Financial Supervisory Authority is obliged to verify the documents provided by the candidates for agents, board members and natural persons performing agency activities. There is a small administrative fee paid for registration (less than EUR 25).
Multi-agent is also obliged to take out a mandatory third-party liability insurance, however such insurances are not expensive.
The legal requirements to become an insurance agent in Poland are quite easy to be fulfilled and do not constitute a significant regulatory barrier.
It must be noted that there are also some InsurTech related services which do not constitute insurance distribution and do not require registration as an insurance agent. Those are services of promoters and business introducers acting under the exclusion set forth in the Insurance Business Act.

Outsourcing services supporting insurance undertakings

There are many InsurTech outsourcing services providers supporting insurance undertakings e.g., cloud services providers, loss adjusters etc.
Such service providers are not regulated entities, however indirectly they are bound by the legal requirements regarding outsourcing services.
Such requirements include i.a.:

  • Article 274 of Commission Delegated Regulation (EU) 2015/35 of 10 October 2014 supplementing Directive 2009/138/EC of the European Parliament and of the Council on the taking-up and pursuit of the business of Insurance and Reinsurance (Solvency II);
  • Provisions of the Polish Insurance and Reinsurance Business Act of 11 September 2015 (Ustawa z dnia 11 wrzesnia 2015 r. o dzialalnosci ubezpieczeniowej i reasekuracyjnej)
  • Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector and amending Regulations (EC) No 1060/2009, (EU) No 648/2012, (EU) No 600/2014, (EU) No 909/2014 and (EU) 2016/1011 (DORA) DORA entering into force since January 17, 2025 has significantly changed the regulatory environment for InsurTech companies as couple of national regulations / guidelines regarding ICT standards has been withdrawn. DORA to insurers and to insurance intermediaries (except those intermediaries which are SMEs (Small Medium Entreprises).
  • Q&As published by EIOPA.

Additional comments regarding the legal situation for InsurTech-services or what InsurTech’s must be aware of in this business area

N/A


Economic conditions

Market size for InsurTech-services and biggest companies in this business area

The market for InsurTech-services is still in the phase of organic growth. As mentioned above, most of Polish InsurTech companies are active insurance agents selling mostly motor and travel insurances (but not only) in the online channel via comparison websites or mobile apps.

There are a couple of multi-agents running comparison websites producing quite significant turnovers (according to the statutory financial reports for FY2024):
Multi-agent (website adress) net income (PLN) – latest available statutory reports
cuk.pl (CUK Ubezpieczenia sp. z o.o. ) PLN 253,262,722.48 (FY2024)
(includes also turnover produced in  retail channel of distribution)
rankomat.pl (Ubezpieczenia Rankomat sp. z o.o.) PLN 127,343,948.38 (FY2024)
mubi.pl (Internetowy Agent Ubezpieczeniowy sp. z o.o.) PLN 107,501,434.20 (FY2024)
punkta.pl (Punkta sp. z o.o.) PLN 18,017,797.78 (FY2024)

Additional comments regarding the economic situation for InsurTech-services or what InsurTech’s must be aware of in this business area

Competition between InsurTech companies in insurance distribution is fierce. However, there is still room for new market players. InsurTech companies often engage in collaborations with Instagrammers and Youtubers to promote their services – usually via ref-links or promo-codes.

It seems that there is still room on the market for InsurTech companies in the area of supporting insurance undertakings as outsourcing services providers – e.g. in loss adjustment.

Authors

Close

Choose country