Global FinTech Guide
Country Name
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.


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. However, clients are still quite reluctant towards such solutions.

The Financial Supervisory Authority (Komisja Nadzoru Finansoweego) 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.

Legal affairs

Obligations and requirements to provide InsurTech-services

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

(1) Insurance distributon
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 Financial Supervisory Authority.

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

There are no requirements regarding running costs and financial reserves.

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

  1. having full legal capacity – that requirement is usually confirmed by written declarations of individuals;

  2. having a clean criminal record regarding wilful commission of:

    1. a) an offence against life and health,
      b) an offence against a system of justice,
      c) an offence against protection of information,
      d) an offence against credibility of documents,
      e) an offence against property,
      f) an offence against economic trading,
      g) an offence against trading in money and securities,
      h) a fiscal offence,

    - those criteria are confirmed by the criminal record certificate issued by the Ministry of Justice (cost around EUR 10 per person);

  3. giving a guarantee of due performance of agent-based activities

  4. - 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;

  5. having at least secondary or vocational education – fulfilment of that criterion is confirmed by an adequate certificate;

  6. having passed an exam conducted by an insurance undertaking – insurance undertaking engaging agents have to conduct the exam and issue a results certificate.

  7. 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 not quite easy to be fulfilled and constitute a 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. 

(2) 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 (Ustawa o dzialalnosci ubezpieczeniowej i reasekuracyjnej)
  • The Communication from the Financial Supervisory Authority office on information processing by supervised entities using public or hybrid cloud computing services of 23 January 2020.

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


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 insurances (but not only) in the online channel via comparison websites.

There are a couple of multi-agents running comparison websites producing quite significant turnovers (according to the statutory financial reports for 2020 or 2019):

Multi-agent (website adress)   2020 net income (PLN) – statutory reports (Ubezpieczenia Rankomat sp. z o.o. sp.k.)  PLN 61,140,797.89 (CUK Ubezpieczenia sp. z o.o. sp.k.)  PLN 124,511,467.13
(includes turnover produced in traditional channel of distribution) (Punkta sp. z o.o., formerly mFind sp. z o.o.)  PLN 8,308,602.98 (Internetowy Agent Ubezpieczeniowy sp. z o.o.)  no financial report for 2020 available yet 2019 (first year) net income = PLN 1,214,088.06 

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.



© 2022, WKB Wiercinski, Kwiecinski, Baehr. All rights reserved by WKB Wiercinski, Kwiecinski, Baehr as author and the owner of the copyright in this chapter. WKB Wiercinski, Kwiecinski, Baehr has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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