Country _ Name
Asset and portfolio management
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.


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. Poles have up to four times less financial assets in relation to GDP than residents of other European countries.

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. 

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 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.

Brokerage activities may be conducted based on a permit granted by the Polish 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 Polish 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 Polish 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 providing PIS and AIS services is EUR 50,000. AIS-only services are not subject to minimum capital requirements.

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


Economic conditions

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

The value of household financial assets has more than doubled from 2010 to 2020 - from PLN 1.2 trillion to PLN 2.5 trillion (i.e. to approximately EUR 550 billion in total). Deposits and cash constitute about 52 per cent of household financial assets in Poland.

The value of investment fund assets in Poland increased in the first three quarters of 2021 by nearly 12 per cent, reaching the highest ever level of PLN 314 billion (approx. EUR 66 billion).

Personal Finance Manager applications are offered in Poland both by non-banks, such as iFin24, Kontomierz and Money Zoom, and by banks, (for example Meritum Bank - Meritum Planner, and then Alior Bank - Manager Finansów, Millennium - Manager Finansów, ING Bank - Finansometr) for several years now. 

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

The recent trend of the National Bank of Poland to raise interest rates could significantly impact the asset management market. In early 2022, there was a reduction in the maximum amount of fees charged by investment fund companies. The purpose of the regulatory changes was to increase the level of protection of investors' interests, allowing investments in participation units to be made on fair and attractive terms.




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