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The goal of the reportis to present the situation of the FinTech sector in Poland, review its recent development (based on the comparison of the current situation and the situation presented in the previous reports), investigate its specific problems and show its main challenges and opportunities.This report is based on the survey run in January 2020. The questionnaire containing 37 questions was sent to 233 firms, out of which 48 has responded. This study is a part of a bigger European survey addressed to the FinTechs in the post-communist countries. However, the findings presentedi n this report, refer exclusively to Poland
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FinTechs in Poland:
Insights, Trends and
Perspectives
May 29, 2020
FinTechs in Poland: Insights, Trends
and Perspectives
Prepared by:
Agata Kliber (Principal Investigator, Poznan University of Economics and Business, PUEB),
Barbara Będowska-Sójka (PUEB),
Aleksandra Rutkowska (PUEB),
Katarzyna Świerczyńska (PUEB),
Wojciech Zdunkiewicz (QuantFin Foundation)
in co-operation with Quantify.
Preface
The goal of the report is to present the situation of the FinTech sector in Poland, review its recent
development (based on the comparison of the current situation and the situation presented in the
previous reports), investigate its specic problems and show its main challenges and opportunities.
This report is based on the survey run in January 2020. The questionnaire containing 37 questions
was sent to 233 rms, out of which 48 has responded. This study is a part of a bigger European
survey addressed to the FinTechs in the post-communist countries. However, the ndings presented
in this report, refer exclusively to Poland.
The report is divided into the following sections. In the rst one, we introduce the regulatory,
economic, social, and technological environment of the FinTech sector in Poland. Next, we present
detailed results of the survey carried out among the FinTech companies in Poland. We focus
on their business, key activities in daily operations, revenue model, nancing sources, challenges
and opportunities they were facing at the time of the survey, their interactions with banks and
governmental agencies. The survey was run just before the coronavirus outbreak, so it reects the
respondents’ opinions expressed in the pre-COVID19 world. Thus, in Conclusions, we express a
bird’s eye view on how the outbreak aected the overall conditions of the Polish FinTech.
The main ndings of the report are:
• although the FinTech sector is still considered young, 50% of the companies operating in
Poland exist on the market for longer than 5 years;
about 40% of the FinTech businesses are small companies (microenterprises) employing up
to 9 people, while only 6% hire more than 50 employees;
• Although Poland is not considered as a top-innovative country, the FinTech sector is de-
veloping dynamically: almost 40% of the respondents declared large or moderate growth of
employment between 2018 and 2019;
most of the companies do not consider competition as a pressing problem, but indicate nding
customers and regulation as the biggest growth barriers;
• the problems with legal system appear on various levels, starting from loopholes in some
areas, through diculties with compliance and ending up with the companies’ expectations
toward government agencies;
1
FinTechs dealing with payment, banking infrastructure and deposit & lending do not consider
themselves as competitors against banks, but rather as collaborators and supporters.
Acknowledgements
First and foremost we are grateful to companies who agreed to take part in the survey, i.e.:
PDU, AssetLife, BanqUP, Beesfund, Bee-Tech, BillTech, Blik, Braintri (Neontri), Brutto.pl,
BSS PolandSA, Centreo, Coderion, Comperia, Currency One, Digital Teammates, Empirica,
ePortfel24.pl, Faktorama, Find Funds, FinPack, Greencash, hiPRO, HOTPAY, Identt, Jak-
dojade, Let’s Pay (PerceptusSA), Monevia, NicePay (1PayPolandSp. zo.o.), NuDelta, Pay-
holding, PaymentTechnology, Scanye, SCFO, SportBonus, Squaber, Star Funds, Storyous,
Straal, Taxxo (Columb Technologies S.A.), Tpay (Ferbuy), Trex, Urban.one, Velochron,
VoiceLab, WWWASH, Ybanking, zbiletem.pl, zrzutka.pl.
We also would like to thank Quantify and QuantFin for running the survey in strict time
limits.
We are grateful to all of those, who have spare their time to read the preliminary ver-
sion of the Report and give us valuable comments, especially Maciej Janiszewski (CEO of
Payholding) and dr Grzegorz Wojtenko (CEO of Bee-Tech).
We also acknowledge the support of the Polish Ministry of Science and Higher Ed-
ucation through the project MINIATURA 2019/03/X/HS4/01025 5 as well as Regional
Initiative for Excellence programme of the Minister of Science and Higher Education of
Poland, years 2019-2022, grant no. 004/RID/2018/19, nancing 3,000,000 PLN.
Citation: Kliber, A., Będowska-Sójka, B., Rutkowska, A., Świerczyńska, K., Zdunkiewicz, W.
(2020) FinTechs in Poland: Insights, Trends and Perspectives, Technical Report.
DOI: 10.13140/RG.2.2.31841.53605
Polish FinTech Environment
This report captures the FinTech environment using a PEST analysis, which is commonly used for
assessing the external business environment. PEST is an acronym for political, economic, social
and technological factors. The underlying idea of the PEST analysis is that companies need to
react to changes in their external environment and are aected by those changes (see: Timaste et
al., 2019 after: Gupta, 2013).
Political and Legal Environment
The regulatory framework in Poland is strongly inuenced by the membership in the European
Union and a broader plan for the development of the Capital Markets Union (a single market for
innovative nancial services - the Digital Single Market). In the scope of this agenda, since March
2018, the European Commission has been realizing FinTech Action Plan, which aims to:
enable innovative business models to scale up at the EU level;
support the uptake of new technologies such as blockchain;
implement articial intelligence and cloud services in the nancial sector;
increase cybersecurity and the integrity of the nancial system (European Commission, 2018).
Coordination of regulatory actions is supposed to allow for the development of nancial inno-
vations with benet for clients, companies and banks oering innovative solutions in a harmonized
European ecosystem. Poland has already implemented some of the European FinTech regula-
tions including such directives as: Payment Services Directive (PSD2), Anti-Money Laundering
2
and Counter-Terrorist Financing (AML/CTF) and the Markets in Financial Instruments Directive
(MIFID-2). Despite that, complexity and uncertainty of regulatory requirements remain major
challenges for the sector development (KNF, 2018). To overcome these obstacles, Polish authorities
plan to i.a. deliver new legal solutions for FinTech sector, allow for a regulatory sandbox and
implement articial intelligence and distributed processing technologies (DPT) in supervision for
the nancial sector (KNFb, 2020)1.
Entities and regulation scope
There are three major tasks in terms of the FinTech regulation in Poland:
FinTech-oriented interpretation of existing rules,
issuing new rules,
deleting unnecessary rules from the system.
A crucial role in these matters is played by The Polish Financial Supervision Authority
(Urząd Komisji Nadzoru Finansowego, henceforth: the KNF). This institution does not only inter-
pret the rules as a nancial market supervisor but also actively supports legislative works. With
the support from external stakeholders, the KNF identies what (and how) should be changed
in the Polish regulatory environment. In particular, it launched the works within two important
initiatives: Special Task Force for Financial Innovation in Poland (identies obstacles in the insti-
tutional framework) and Innovation Hub (provides institutional support for business operators in
the FinTech sector).
KNF working group - Special Task Force for Financial Innovation
To eciently support the FinTech legal framework in Poland, the KNF has expanded its struc-
ture with the FinTech Department. This cell applies regulatory and supervisory measures and
tools for the development of FinTech in Poland (KNF, 2018). Since 2016, a Special Task Force
for Financial Innovation (public authorities, non-prot organizations, and business organiza-
tions representing market) has engaged to detect regulatory problems and identify key barriers
for technology development, under its auspices. This working group proposes solutions and rec-
ommendations for further regulatory activities and analyzes current developments in the system
2.
Problems identied by the KNF working group already in 2017 considered i.a. application of
Cloud Computing, replacing paper with digital documents, or decreasing restrictions for outsourc-
ing. Currently, the working group is divided into subsections that cover ve areas:
1. general system issues,
2. capital processing,
3. banking processing,
4. consumer and data processing,
5. identity and AML.
In 2020 24% of barriers in regulatory environment detected by the group have been identied
as falling into the scope of general issues (resolving them is important for all FinTech sub-sectors).
Apart from that, the group has dened problems, which are particularly important for data pro-
cessing (22%), payment services (20%), banking (15%), capital sector (10%), AML (6%), lending
1These actions are in the scope of a project carried out with the support of the European Bank for Reconstruction
and Development.
2The presence of Ministry of Finance and Oce of Competition and Consumer Protection within that body,
increases the expected impact of their works.
3
(3%), and insurances (1%) (KNF, 2020a). In practice, this translates into issues such as register
accessibility, the length of the procedures, written-form requirements, overregulation, or digital
identity (KNF, 2020b).
Innovation hub program
In 2018, the KNF launched the Innovation hub which aims to engage a dialogue with start-ups
and institutions under its supervision, such as banks. The idea of the hub is to provide all kinds of
support for companies from the FinTech sector, including the interpretation of regulations and the
licensing process. Among the topics raised by the group, the most common were: payment services
(including PSD2), ICO/virtual currencies, robo-advisors in the capital market, exchanges/cryp-
tocurrency exchanges, crowdfunding, banking/loans, stock exchanges and nancial markets (KNF,
2018). Companies seeking institutional support may qualify for the program.
FinTech activities regulation and enabling technology
The KNF working group identies the obstacles and denes its sources to adjust actions, re-
sponsibilities and facilitate the process of change. Several legislative acts need amendments in
order to enable innovations in nancial sector in Poland3. In this section we summarize some of
the required actions in reference to particular sectors and services.
Requirements for FinTechs in banking and nancial services
In the scope of the banking, digital banks, and new bank services there is still vast area of
required intervention, including supervision of compliance with the PSD2, RTS, and eIDAS4. In
principle, it is required to decrease formalities and clarify the rules of operation for new nancial
entities on the market. Among the fundamental issues, Supervisor’s opinion regarding maintaining
bank accounts for non-banking FinTech entities is required (for instance, there are situations in
which banks refuse opening bank accounts e.g. cryptocurrency trading platform organisers).
As noted by one of our respondents:
Maciej Janiszewski - the CEO of Payholding
After implementing the PSD2 regulations, Fintechs, instead of being treated on an equal
footing with banks, were even removed from the banking network under the pretext of not
meeting standards, etc.
Moreover, for those FinTechs that do not have a KNF license (e.g. MIP or KIP), agreements
are terminated by banks.
Lastly, the lack of licenses, insucient rules for monitoring transparency of transactions
(despite reporting transactions above EUR 15,000) and the lack of proper supervision over
the implementation of KYC and AML reduce trading certainty for the currency exchange
platforms.
So far, there are limited options for expanding Account Service Information Provider (further:
ASIP) services in Poland, both in terms of content (scope of data) and entity (extension of the
catalog of entities subject to the obligation to provide the data). Such input could foster ”open
banking” model to other nancial market segments. Technical facilitation of transactions in bank-
ing requires widening forms for declarations of consent to e.g. electronic stamps. Additionally,
European law introduces the concept of Third-Party Providers (TPP) — a new category of
3In particular the Act of 21 July 2006 on nancial market supervision and certain other acts in connection with the
development of nancial innovations, the Act of 29 July 2005 on public oering, conditions governing the introduction
of nancial instruments to organized trading and public companies, the Act of 19 August 2011 on payment services,
the Act of 11 September 2015 on the business of insurance and reinsurance, the Banking Law of 31 January 1989,
or the Act of 15 September 2000 Commercial Companies Code.
4eIDAS Regulation is Regulation (EU) 910/2014 on electronic identication and trust services for electronic
transactions in the internal market
4
entities that will be able to provide selected nancial services on behalf of the client, or to inform
them of the status of their account. For robo-advice, FinTech-specic regulations are not common,
yet a guidance on issues that are unique to robo-advice as compared with traditional nancial
advice are needed (see Table 1).
Table 1: Examples of required changes in legal environment of FinTech identied by the KNF
working group
Required action Expected outcome
Require regulation
new instruments for start-up funding
compulsory publication of rules interpretations for the KNF
creating a mechanism to review the KNF interpretation
legal and business advice for new transborder payment
services providers
Regulation change
national framework for crypto assets including taxation;
possibility to dematerialize shares in companies
clarication of rules for nancial instruments digitalization
possibility to tokenize documents such as cheques,
bills of exchange, waybills or bills of lading
allowing for digital document form to substitute written form
Interpretation / practice change
decreasing length of getting a license for payment services process;
excluding small payment institutions from obligation
of data processing in computing cloud
precise interpretation of the term “innovativeness” by the KNF
provide possibility for new securities creation
robo-advice – clarication whether there is a need for regulated
outsourcing requirements for the algorithm provider
Requirements for InsureTech
In the area of insurance, there are innovative solutions such as telematics, expert systems for
premium valuation, or insurance on request. Generally, existing regulations are considered as
sucient to embrace them. There are only some detailed issues which need to be addressed, such
as e.g. enabling nancial institutions to automatically obtain information from tax oces, or the
limitation of the liability of the service provider towards payment institution (for damages caused
to customers as a result of non-performance or improper performance of the contract).
Requirements for FinTechs dealing with crowdfunding
With a growing interest in crowdfunding for charity, the rules - in particular for telecommuni-
cation service providers - need to be claried. Polish authorities shall also prepare for the adoption
of an EU crowdfunding license. This idea involves a Community license to match investors and
companies in the EU, giving a chance to pitch business ideas to a wide base of founders (KNF,
2020a).
Requirements for FinTechs dealing with data analysis
In terms of data processing it is expected i.a. to allow business information oces (in Polish:
biura informacji gospodarczej) to outsource using modern technological solutions and to enable
creditors to send payment requests electronically in all cases (email, SMS, MMS). Other issues,
such as introduction of legal solutions for automated trading (including new identication methods
for legal persons using automatic trading tools), require further consideration. Moreover, there is
5
a need to create institutional framework to prevent identity theft, which hamper FinTech industry
development (KNF, 2020a).
Requirements for distributed ledger companies
Finally, crypto assets are subject to an array of regulatory and interpretation responses, yet
the area still requires major regulatory eort and clear position of Polish authorities. For now,
the rules are unclear and provide uncertain environment for any business model. There are no
new crypto-specic licenses or authorizations which could help to get the sector in order and allow
for its development. Some of the barriers for distributed ledger technologies can be found in the
eIDAS Regulation, which for that matter should be revised to explore the possibilities of reconciling
electronic identity framework with blockchain technology, e.g. self sovereign identity (SSI) (KNF,
2020a). It is noteworthy, that despite the public interest in cryptocurrencies in 2018-2019 necessary
changes in the legal system were not introduced. Currently, the interest has decreased, but the idea
to expand the application of distributed ledger technologies and digital assets remains an important
element of regulatory agenda.
Public policy
One of the crucial challenges for the better regulation policy in Poland is to eliminate gold
plating. The practice to implement solutions stricter than required by the European law, has been
common in Poland since the accession process. Instead of increasing compliance, these practices
usually hinder private sector development and create an illusion that Poland is not a part of the
European single market5. The KNF working group has made it one of its goals to identify such
rules for amendment.
Several restrictions in the Polish law (i.a. innovative outsourcing, insurer liability limitation)
were identied as barriers to be removed for the reason that no analogous regulations exist
elsewhere. Removal of such institutional constraints is not only market and innovation-friendly,
but also mandatory to cooperate with international supervision actors and other insti-
tutions. It is also good news, that Polish authorities open up to innovative policy approaches,
such as the ”regulatory sandbox”.
The regulatory sandbox is supposed to operate as a programme designated for innovative
startups to allow them to test their services or products under market conditions, without actually
meeting the regulatory requirements. This approach should help FinTechs to deliver secure products
to the market (KNF, 2018). Sandbox’s idea intends to reduce information asymmetries between
the market and the supervisor.
It is noteworthy that delays in the adjustments of regulatory environment may jeopardize the
security and the legal certainty for service providers in Poland. Contrariwise, in some cases, leaving
blank spots in the formal institutions’ framework can leave the space for invention of new products
or services. It also seems plausible, that the eorts of policymakers should be rst placed in the
regulatory eciency (e.g. the process interpretation of laws by the KNF) and next in the legislation.
Hopefully political tensions in Poland will not interfere with the process of FinTech regulation and
the establishment of sound policies for the FinTech industry.
Economic Environment
Big tech companies, e-commerce leaders, and social media platforms entering the market, as well
as FinTech startups, exert pressure on traditional nancial institutions to innovate by oering
completely new ways of making payments, granting loans, carrying out investment processes, pric-
ing insurance, and many more. Many technological solutions, including AI, machine learning,
5For example, a quota threshold for electronic money instruments that are exempt from the application of AML
provisions is 50 Euros in Poland, whereas in relation to the Community requirements it should be 150 Euros (Article
38 of the Act on counteracting money laundering and terrorist nancing).
6
blockchain/distributed ledger technology, biometrics, and cloud computing move from universi-
ties and R&D labs to business, thus nurturing a technological transformation of traditional
nancial services.
Open banking schemes, cyber security, data protection, digital identication, and the ability
of state ocials and supervisors to cooperate with FinTech companies in the Innovation Hub
give a solid public policy foundation for a nancial revolution. There are also several
changes within the regulation processes. Various EU directives inuencing the market are being
introduced, government initiatives, such as regulatory sandboxes or cross-disciplinary collaborations
of regulators are being launched, and the development of the RegTech is well underway.
The emergence of companies promoting nancial innovation, its inuence on traditional business
models, and the reaction of the authorities, are the elements that shape the nancial services market.
Disruptors often aim at leveraging their lower costs of operation, more innovative and up-to-date
infrastructure, or even large and loyal customer base. By trading on these advantages and oering
more secure, cheaper and faster services with more customised solutions, they are better capable
of capturing a signicant market share. The already-existing nancial institutions’ need for such a
solution seems to be extensive, when we realise that obstruction may come from many directions.
Those hindrances more frequently force traditional nancial services providers to reconsider their
value proposition and implement changes into their organisational culture, as well as into their
approach to R&D and innovation.
An important factor in a country’s attractiveness for innovative ventures is how favourable
its business environment is. There are various measures published by many authorities. One of
them is The Global Financial Centres Index (GFCI) - a ranking of the competitiveness of nancial
centres based on over 29,000 nancial centre assessments from an online questionnaire together
with over 100 indices from organisations such as the World Bank, the Organisation for Economic
Co-operation and Development (OECD), and the Economist Intelligence Unit. In March 2020,
Warsaw, the capital of Poland, has been 50th of the 108 cities covered (for comparison: Prague has
been 46th, while Vienna: 38th).
Another useful measure for comparison countries’ attractiveness for investors is the Global En-
terpreneurship one (furhter: GEDI). The authors of the index collect data on the entrepreneurial
attitudes, abilities and aspirations of the local population and then weight these against the prevail-
ing social and economic infrastructure (such aspects as broadband connectivity and the transport
links to external markets). This process creates 14 pillars which GEDI uses to measure the health
of the regional ecosystem.6In this methodology, Poland was ranked 30th, just after Lithuania
(29th), Slovenia (25th), but before Slovakia (36) and the Czech Republic (38).
Social Environment
What is certain about any disruption in the nancial sector, is that it is never one-o, and that
it usually drags on. The mechanism which is an integral part of the nancial services industry is
backed by new applications of the already-established technologies, as well as by newly-designed
solutions, but mostly by changing the expectations of customers. More and more customers demand
multi-channel access, a seamless service and integration, as well as value-added digital customer
experience.
On the other hand, companies have organised programs fostering the growth of selected startups
by mentoring the company by professionals, organising workshops, giving access to experts of
marketing, accounting, and other related elds, providing the company with oces, facilitating the
process of Venture Capital nancing or granting non-refundable nancial aid, as well as enabling
access to business clients.
Taking into account the evolution of the way in which the basic nancial activities are performed,
startup acceleration programs and the favorable economic environment, we can suppose that the
impact of FinTech on the traditional nancial market will be more and more visible.
6See: https://thegedi.org/global-entrepreneurship- and-development-index/ for details
7
In international comparisons of social environment among countries, three factors are taken into
account: availability of talent and skills, the customer base, and associations for those in the sector
(see e.g. : Timaste et al., 2019). The performance of countries with regard to the availability of
talent and skills is assessed in the IMD World Talent Ranking using three factors. The Investment
and Development factor measures the resources engaged in increasing the home-grown workforce,
Appeal measures the attractiveness to local and foreign talent, and Readiness measures the quality
and skills of human resources. In the IMD World Talent Ranking 2019 of 63 countries, Poland came
37th: 27th in Investment and Development, 46th in Appeal, and 45th in Readiness. The overall
score was better than the analogous one for the Czech Republic (39), Hungary (45) and Slovakia
(57), but weaker than the one for Latvia (34), Lithuania (28) and Estonia (27). 7
Technological Environment
The API economy boosted by open banking scheme
The shortcut API stands for application programming interface, i.e. a computing interface which
denes interactions between multiple systems. These enable entrepreneurs to create platforms,
marketplaces and envision new business models. API’s eliminate barriers to growing revenues by
integrating platforms and apps so that organizations can quickly launch new business models and
then scale fast.
One of the most valuable initiatives for the development of the Polish FinTech sector was the
PolishApi initiative. The project participants include the Polish Bank Association together with
commercial and cooperative banks, cooperative savings and credit unions (SKOK), the Polish Or-
ganisation of Non-banking Payment Institutions (PONIP) together with its associated members,
the Polish Chamber of Information Technology and Telecommunications (PIIT), the Polish In-
surance Association (PIU), Krajowa Izba Rozliczeniowa, Biuro Informacji Kredytowej, and Polski
Standard Płatności. 8
The PolishAPI standard is the essential part of the Open Banking on the Polish nancial
market. It denes the interface that permits third parties to access payment accounts, and as such,
it enables the cooperation of FinTech companies with banks. The objective of the initiative is also
to reduce the costs of implementation of the PSD2 Directive (and other accompanying legal acts)
for the payment institutions and third parties (see: https://polishapi.org/en/). The creators
of the standard assume its permanent improvement in response to administrative, technological
and business changes in the Polish and European markets.
Data universe, AI and cloud
The exponential growth of the datasphere oers countless opportunities to provide brand new AI-
driven solutions. The Big Data revolution can break out due to increasing cloud computing power
at reduced costs. These costs decrease on average by 50% in 3 years.
Internet and mobile access
According to the World Bank data, in 2018 77.5% of population in Poland had access to Internet,
while mobile cellular subscriptions per 100 people amounted to 134.7. Thus, the percentage of
population with Internet access in Poland was higher than in Hungary (76.1%), but lower than
in Lithuania (79.9%), the Czech Republic (80.7%), Slovak Republic (80.7%), Latvia (83.6%), and
Estonia (89.4%). However, when it comes to mobile cellular subscriptions per 100 people, Poland
exceeded Hungary (103.4), Latvia (107.3), the Czech Republic (119.1) and Slovakia (132.8), but
was overtaken by Estonia (145.4) and Lithuania (163.9).
7See: IMDB World Talend Ranking (2019) for details.
8See: https://polishapi.org/en/ for details.
8
FinTech companies in Poland
In the Doing Business report from 2017, Poland scored the high 24th place (see: Widawski and
Brakoniecki, 2016), while in 2019 - the 25th within the OECD group and 40th overall. In this
index, economies are ranked on their ease of doing business. A high score in the ranking means
that the regulatory environment is more favorable to the opening and running of a local rm.
Such a result has a strong implication for the FinTech sector, where the companies on early-stage
development dominate. On the other hand, as Widawski and Brakoniecki noted, in the Global
Innovation Index (GII) Poland took only 39th place. The GII has become one of the leading
references for measuring an economy’s innovation performance. This means that Poland provides
relatively good opportunities for starting a new business and there are a lot of niches to ll with
respect to innovation. The Report of FinTech Hub Polska published in 2017 stressed that the role
of FinTech has been already noticed by the government and that FinTechs were pointed to be one
of the key sectors to become a driver of the Polish economy.
Overview of the FinTech companies in Poland
To identify the eld of activity of Polish FinTechs we used the following classication presented in
Table 29.
FinTech sector in Poland - overview
Our FinTech database constructed at the turn of 2019-2020 consisted of 233 companies of
which the majority dealt with Payments (28.3%). The second largest group were companies
from Deposit and lending sector (22.7%). Further, 17.6% of the identied enterprises
were those who provided Banking infrastructure, 9.9% have been classied as from an
Investment management sector, while 9.4% accounted to Analytics. The Distributed
Ledger Technologies subsector was relatively small as we identied 5.2% of rms belonging
to that one. Eventually, the smal lest number of companies were classied as InsureTech
and Accountech (each group accounted for 3.4% only).
We need to stress also that a number of companies operates in more than one sector. The
classication is mostly based on the rms’ descriptions found on the Internet or in other FinTech
reports. In the survey, some companies classied themselves to dierent areas than it would stem
from their description on the website, while some others did not indicate any of the pre-dened
class.
Results of the Survey
The survey was run in January 2020 by Quantify and QuantFin Foundation. We obtained responses
from 48 companies. The questions considered the following aspects:
Field of activity, key activities and revenue model;
Maturity and size;
Sources of capital;
Challenges and opportunities (sentiment questions on 10 points Likert scale)
Communication with state organizations and possible support expected from them;
The relations of FinTechs with banks.
9This classication is similar to that used in IFZ FinTech Study 2018 (Ankenbrand et al. 2018) with the exception
of insurance, which was excluded from that work. Our classication is also compatible with the one used by our
partners in their FinTech Report Estonia (Timaste et al., 2019).
9
Table 2: Polish FinTechs: eld of activity
Payment Mobile payments
Online payments
Mobile transfers
Other form of payments
Analytics Big data
Data (business) analytics
Big data analysis
Machine learning
Articial intelligence used for automated advice
Chatbots
Banking infrastructure User interface
Processing enhancement
Infrastructure technology
Software companies in the nancial sector
Distributed ledger technology Cryptocurrency
Blockchain
Deposit and lending Crowdinvesting
Crowdlending
Invoice trading
Investment management Robo advisor
Social trading
Hybrid models
Advice-supported Digital Investing
InsureTech Software technology in insurence
Accountech Software technology in accounting
Field of activity, key activities and revenue models
Similarly to the distribution in the whole population (i.e. 233 companies mentioned in the
previous paragraph), in our sample, three main groups encompass companies dealing with pay-
ment (33.3%), deposit and lending (20.8%) and banking infrastructure (18.8%). The fourth-largest
group is analytics (10.4% - comparing to 9.4% in the whole population). In our sample, the share
of investment management companies and the Accountechs is equal and represents 6.3% of the
investigated group. This is not fully compatible with the whole population, where the share of in-
vestment management companies was larger (9.9%), while the share of Accountech smaller (3.4%).
The smallest fraction of our sample belongs to the companies from the insurance and distributed
ledger sector (2.1% each - meaning that we had only one respondent from each of the groups). The
distribution of the sample by the activity type is presented in Figure 2.10
We also asked the companies about their key activities - i.e. the activities a company performs to
run its business. These include programming and engineering, marketing, and managing day-to-day
operations. The results are presented in Figure 3. More than 60% of the respondents mentioned
programming and engineering as their main activities. Remaining 40% indicated marketing or
running daily businesses as the core ones.
It appears that depending on the sector of operation, key activities of companies are dierent
10It was possible to choose more than one option as an area of activity or dene its own.
10
Figure 1: Field of activity of companies
(Figure 4). The analytic companies rarely engage in marketing and nding clients (we obtain
no such answer from our respondents), while they spend most of their time on programming and
engineering. Respondents from banking infrastructure also indicated programming and engineering
as their key activities (53% of the cases). Companies from payment, investment management and
deposit and lending spend roughly the same amount of time on the three identied activities, while
the Accountech - slightly more on marketing and nding clients, than on any other activity.
Eventually, we asked the companies about their revenue model. Most of the respondents named
commission income (from service or products they deliver) as the main revenue source. The second
most frequently given answer was a license fee from a product or software. Centralized hosting
of business applications and trading income (from active trading in the nancial markets) were
marked twice rarer (respectively: by 19% and 17% of the respondents). 13% of the respondents
chose data (gathering and selling) as their revenue source, while 10% - advertising income. Only
4% pointed out the interest income as a revenue source. The full picture is presented in Figure 5.
Maturity and size
Around 85% of our respondents represented companies already running, while 15% - those under
development (in a testing phase). In Table 3, we present the percentage of companies from dierent
activity elds in each maturity group. In the sample of the already running companies, the largest
share belongs to the payment (34%), banking infrastructure (21.95%) and deposit and lending ones
(19.51%). Again, among the companies under construction, the share of the deposit and lending,
investment management, as well as payment rms is equal (each: 28.57%).
In the FinTech study from 2018 (Mapa polskiego Fintechu 2018), the authors document that
60% of Polish FinTechs were created in 2013 or later, while only 3% operated longer than 20 years.
Our sample data roughly reects this distribution. 35% of our respondents operated on the market
for a period of 1 to 5 years, while the majority (44% - from 5 to 10 years). The lowest share (6%)
declared to fall in the interval from 10 to 15 years (see Figure 6, left panel).
When we compare it with the data from the 2016 report (Widawski i Brakoniecki, 2016),
we notice that the share of very young companies (1 to 5 years) shrank from 62%, which can
suggest that the companies still exist in the market, but moved to the second group (5-10 years of
maturity), which in 2016 constituted only 18% of the group. Such a shift might be treated as a
sign of development in the sector.
In 2016, small rms dominated in the FinTech sector in Poland. The situation did not change
11
Figure 2: Field of activity of companies which completed the survey
Figure 3: Daily key activities of respondents
much in 2019, when the companies of 1 to 9 employees constituted almost 40% of the sample (see
Figure 6 right panel and Table 4). The second two largest groups were FinTech employing from 10
to 25 people (27.1% of the sample) and employing from 26 to 50 people (25% of the sample).
In Table 4, we present the distribution of the size of the companies versus their eld of activity.
We can see that in the sectors of payment, deposit lending, as well as insurance and investment
management, the small companies were the most frequent ones (1 to 9 employees). Among the
rms from the banking infrastructure eld, the most frequent size was from 10 to 25 employees. In
analytics, the dominating enterprises were those that employed from 26 to 50 people. The largest
companies, employing 51-100 people, were present only in the sector of banking infrastructure and
payment, while those that hired over 100 people - in banking infrastructure only.
From the companies that participated in the questionnaire, the majority of the sample (87.5%)
were those whose employees were working in Poland. Only 4 admitted that not all of their employees
worked in the home country (the answers provided were: 98%, 90%,10% and 2% of employees from
Poland).11
11When we compare it with the country of registration: 46 companies were registered in Poland, one in the Czech
Republic and one in Belgium. Moreover, 77% of the respondents stated that they focused their business on the
Polish market, while 33% served international clients.
12
Figure 4: Daily key activities by sector
Figure 5: Revenue model
In Figure 7, we present the change of employees of the surveyed companies between 2018 and
2019. It appears, that in the prevailing case, the number of employees did not change. However,
from those companies that admitted a change in the workforce, only 6.3% reported a moderate
decline, while the rest - moderate (22.9%) or large (16.7%) growth.
To summarize, the FinTech sector in Poland is dominated by micro and small enterprises, hiring
most often from 1 to 50 people, operating on the market not longer than 5 (35%) or 10 years (44%).
This means that the start-ups represent a large sector of the Polish FinTechs. The substantial share
of the companies who documented the growth of their employment, also conrms that this branch
of the market is still growing.
Sources of capital
In its report from 2018, Cashless notes that nearly half of the FinTechs use equity capital to
nance their business (Cashless, 2018). This means that the founders of these companies need to
have such a high level of accessible funds to be able to build technical infrastructure and recruit
skilled employees.
In the case of the companies investigated in our survey, again one source of capital dominates -
equity capital. Only seven companies did not indicate it (three respondents refused to answer this
question). Out of these seven, three received capital from a business angel or an individual investor,
two - from venture capital funds, one - from the accelerator, and one - from a bank or other nancial
institution. Moreover, two respondents indicated current sales income as an additional source of
13
Table 3: Share of companies of dierent activity in already running and under development groups
Already running Under construction
Accountech 7.32% 0.00%
Analytics 12.20% 0.00%
Banking infrastructure 21.95% 0.00%
Deposit and lending 19.51% 28.57%
Distributed ledger 2.44% 0.00%
Insurance 0.00% 14.29%
Investment Management 2.44% 28.57%
Payment 34.15% 28.57%
TOTAL 100.00% 100.00%
Figure 6: Maturity and size of FinTech companies
capital.
As one can see in Figure 8, equity capital is supported mainly by business angels, individual
investors and venture capital funds. This also corroborates the results presented by Cashless in
2018, where business angels and venture capitals appeared to be two-second popular sources of
capital.
None of the companies have mentioned capital sources such as IPO or Initial Coin Oering.
The ICO is a kind of nancing that uses distributed ledger technology (DLT), i.e. Blockchain.
Recently, it is one of the most popular methods of obtaining nancing by entities with potentially
high innovativeness of services rendered but associated with considerable investment risk. However,
the KNF refers to it with caution (see the report of Cashless from 2018).
When it comes to other possible sources of capital, dr Grzegorz Wojtenko, the CEO of Bee-Tech,
notes that The National Centre for Research and Environment (further: NCBiR) should be one of
the key ones.
dr Grzegorz Wojtenko - the CEO of Bee-Tech
Cooperation between industry and universities denitely needs improvement. There is no
mature concept here. Most of the intellectual potential associated with universities is, of
course, used by companies, but rather through establishing direct cooperation with individual
scientists, instead of the institutional cooperation. Scientists are involved in the work on
the NCBiR application, but not as formal representatives of the university, only private
individuals. This is due to the pragmatic approach of the university and the lack of a
good mechanism for university-industry cooperation. Unlike heavy industry (very capital-
intensive), the area of new technologies (including FinTech) is still an opportunity for Poland
to be among the leaders in an international race.
14
Table 4: Number of employees versus the eld of activity
Field of activity Number of employees
1 – 9 10-25 26-50 51-100 101-250 no answer
Accountech 2.1% 4.2% - - - -
Analytics 2.1% 2.1% 6.3% - - -
Banking Infrastructure 4.2% 6.3% 4.2% 2.1% 2.1% -
Deposit and lending 8.3% 6.3% 4.2% - - 2.1%
Distributed ledger - - 2.1% - - -
Insurance 2.1% - - - - -
Investment Management 4.2% - 2.1% - - -
Payment 16.7% 8.3% 6.3% 2.1% - -
TOTAL 39.6% 27.1% 25.0%% 4.2% 2.1% 2.1%
Figure 7: Change in number of employees between 2018 and 2019
Challenges and opportunities
The outbreak of the COVID-19 pandemic in March 2020 undoubtedly provided many opportu-
nities for the development of the FinTech sector. For instance, as noted by dr Grzegorz Wojtenko
(Bee-Tech CEO):
dr Grzegorz Wojtenko - the CEO of Bee-Tech
It took only two weeks to increase the amount of contact-less payments without a PIN from
50 to 100 PLN - after the two-years discussion.
Our survey was run just before the pandemic, but some of such opportunities have been already
identied. In Figure 9, we present the answers given by our respondents to the question about
the main triggers for the development of the sector. The most frequently chosen answers were
digitalization of nancial services,expansion of FinTech beyond traditional nancial services and
rising number of payment options at retailers. Thus, the main reasons given by the respondents in
January 2020 are also the ones that should remain valid in the post-COVID world and provide the
main opportunity for the development of the sector in the future.
15
Figure 8: Sources of capital
For this reason, it is necessary to analyse also the obstacles that prevent the development of the
companies. According to the report of Widawski and Brakoniecki (2016) the three main catalysts
for the development of nancial technology are: clearly set strategic directions for the digitization of
the state, a vibrant innovation ecosystem and a system of incentives for start-ups and corporations.
The identication of technological, cultural and educational barriers, and above all legal ones, is
fundamental to achieving these goals.
FinTechs in Poland - especially start-ups - face many challenges. Staszewska (2018) enumerates
the following: complying with regulations, resistance among companies to adopt new technolo-
gies, changing consumer behavior and widening access to funding. The report of Widawski and
Brakoniecki identied three main barriers to its growth:
lack of new knowledge on emerging nancial technologies;
ambiguous regulations and lack of binding interpretations made by the supervisory authority,
meaning higher business risk;
lack of incentives for both banks and start-ups.
The results of our survey show that when it comes to the specic problems which the FinTechs
companies face, among the most pressing issues are (see Figure 10):
• regulations;
the availability to nd skilled sta/experienced managers;
nding customers.
The mean value of the responses for these questions amounted to 8 on 1 - 10 scale. Furthermore:
the cost of production,
the expansion to international markets
were both second-ranked. The least pressing (with mean value of response equal to 6) appeared
to be the access to nance and a threatening competition.
Among ”other problems”, the companies enumerated:
16
Figure 9: Triggers behind FinTech development
data cost (ranked 8),
openness of large organizations (ranked 10),
and lack of clear regulations (ranked 9 - although the regulations as such were also mentioned
as one of the answers to be chosen).
In Table 5 we present the distribution of the responses by the six most common FinTech groups
in our sample. It seems that not each group valued the problems equally. For instance, the
problem of nding customers was most pressing for Accountech, deposit and lending, as well as
for companies from the payment sector. Regulations seem to be the least important problem for
the companies representing the accounting eld. Eventually, nding competent sta seem to be
roughly equally important for all the sectors. The competition was the least pressing for investment
and management, as well as Accountech enterprises.
Table 5: Specic problems and their pressure - by FinTech type
Accountech Analytics Banking infr. Dep. and lend. Inv. manag. Payment
Competition 4.67 5.00 6.00 7.10 4.67 5.81
Finding customers 9.67 8.60 7.44 9.00 7.00 8.56
Access to nance 6.00 5.40 6.11 7.50 7.33 5.13
Cost of production/labour 6.67 6.40 7.11 6.30 4.67 6.88
Availability of sta 7.00 8.60 7.89 7.60 7.00 7.38
Regulation 4.67 8.00 8.11 8.30 8.33 7.25
Expansion to international markets 7.67 7.20 7.56 7.00 6.33 6.38
Although most of the companies named regulations as one of the most pressing problems, only
37.5% of the respondents of our survey claimed that the existing nancial regulations restrict their
activities, The rest (67.5%) do not consider the regulation as an obstacle.
Those, who answered yes to the question, most often complained about ambiguity and impre-
cision of the regulations, adding that those that were precise, required lots of bureaucracy. The
respondents claimed also that the regulations are backward, not taking into account the rapidly
changing reality. This was especially visible in the case of companies dealing with leasing, where
regulations expected by the industry - i.e. the possibility of signing leasing contracts online - have
not yet been implemented. The respondents wished that institutions would consult market leaders
to implement modications that make sense and reect current changes as well as changes antic-
ipated in the near and distant future. Some respondents noted also that the legislators favoured
17
Figure 10: Specic problems and their pressure (means)
banks and that the regulations did not take into account the existence of FinTechs. As most Fin-
Techs in Poland deal with payments, the comment of one of the respondents that acquiring the
status of a payment institution is tedious, lengthy and expensive, is of special importance.
Eventually, we asked the FinTechs to evaluate their company against competitors on a 7-point
Likert scale, when it comes to such aspects as:
prot margin (1 - very low to 7 - very high);
asset light, i.e. xed costs related to assets (1- low xed costs to 7 - high xed costs);
ability to scale (1-very scalable to 7 - not scalable);
innovativeness (1- very innovative to 7 - not innovative);
ease of compliance (1 - not subject to high compliance regimes to 7 - subject to very high
compliance regimes).
The results are presented in Figure 11, for each sector separately, as mean values of responses. It
comes out that companies belonging to the sector of analytics, banking infrastructure, deposit and
lending, as well as payment pointed out the ease of compliance as the highest problem. Analytic
rms, as well as investment management ones felt innovative as compared to the competitors. The
prot margin was the highest problem for the Accountech and investment management businesses.
FinTechs versus state organizations
In their report from 2018, Flanders indicated that the KNF is the most important organization
that supports FinTechs in Poland (see also: Political and Legal Environment section of this
18
Figure 11: Company against competitors (means)
report). Indeed, when it comes to the state organizations with whom the FinTech sector commu-
nicates regularly, 35.4% of the respondents mentioned the KNF. The second most commonly given
answer was: ”none”. 12.5% of the companies communicated with tax oces. The remaining answers
listed banks, the Warsaw Stock Exchange, the Polish Agency for Enterprise Development (PARP),
the General Inspector of Financial Information (GIFF), the Polish Development Fund (PFR) and
various ministerial agencies (e.g. Ministry of Finance, Ministry of Economic Development, etc.) -
see Figure 12 for details.
Figure 12: State organizations with which FinTech sector communicate on regular basis
When we asked our respondents about the incentives that they would like to get from the state
organizations, the majority would expect special regulations from the Polish government (65%).
56% named sandboxes as potential incentives for sector development. Eventually, 46% of the
respondents would like to obtain tax relief (see Figure 13).
19
Figure 13: Incentives from state organizations
In Figure 14 we present the distribution of the answers by the analysed sectors (we omit In-
sureTech and distributed ledger, to assure the anonymity of the responses). Tax reliefs were the
least common answer among analytic companies. The highest need for special regulations was noted
in the banking infrastructure, deposit and lending and Accountech, while in the case of payment -
regulatory sandboxes were as frequently chosen answer as the special regulations.
Figure 14: Expectations of incentives by eld
We stress the fact that these answers corroborate the KNF recommendation mentioned in the
section Political and Legal Environment of this report, as well as the answers given by the
respondents to the question about the specic problems (see Table 5). Regulations were chosen as
one of the most pressing problems by analytics, deposit and lending, banking infrastructure, and
investment management companies (in all cases the mean value was equal at least 8.00). In the
case of the payment sector, the mean value of the Regulation pressure amounted to 7.25, and only
among the Accountech companies, it was relatively low (4.67). When we look at Figure 11, the
answer Ease of compliance was also ranked very high by analytic, banking infrastructure, deposit
and lending and payment sectors. All the results suggest that the need for clear regulations is a
pressing problem, and solving it is crucial for the development of FinTech companies.
20
FinTechs versus banks
The authors of Flanders Investment and Trade Market Survey (2018) note that in recent years,
Poland has become a regional leader in technologically advanced, pioneering solutions in the banking
sector. Mobile is emerging as an essential channel for Polish customers.
In her paper from 2018, Staszewska notes that Polish banks indeed are willing to co-operate with
FinTechs (and vice-versa) and that the most innovative of them consider themselves as a part of
the FinTech sector. When we look back at Figure 2, we can notice that most of the Polish FinTechs
deal with payment, banking infrastructure, deposit & lending, as well as investment management.
This means that they can indeed support or even replace banks with customer relationships,
oering better or more personalized products.
Staszewska (2018) noted that FinTech start-ups cannot compete with banks when it comes to
the convenience and security of having a current account at a bank. This was also noticed by one
of our responders, who said: Banks are strong economic organisms and in the event of a threat they
will be able to buy competition or make a change in their business. The role of the FinTechs is the
role of ”disruptor” but without changing the market relationship.
Moreover, Staszewska (2018) named three fundamental advantages FinTech start-ups have over
traditional banks:
the ability to cut costs and improve the quality of nancial services (FinTechs do not face as
much regulation as traditional banks, they do not have to upgrade legacy IT systems that are
no longer relevant. They neither have to maintain branch networks, nor to protect existing
businesses);
the way of risk assessment (traditional banks use credit scores and meetings with clients to
assess the risk of a loan, while FinTechs can make data-driven assessments of customers before
lending them funds, based on Internet data);
the opportunity to create more diverse and stable credit landscape that is less concentrated
geographically (traditional banks take short-term liabilities and use them to create long-term
assets like mortgages, while crowdfunding platforms connect lenders and borrowers directly
in peer to peer lending, with individual lenders bearing the risk of default on the loan, not
the intermediary).
Based on the results of its international survey on mobile banking from 2015, ING said that
60% of smartphone users in Poland had already used mobile banking or expected to use it (ING,
2015). This was the third best score in Europe - compared to Netherlands (67%) and the UK (63%).
Thus, the potential of growth of mobile banking services in the coming years is still enormous. Yet,
according to Flanders Investment, 38% of established retail banks in Poland did not oer their
services through the mobile channel, neither via a dedicated app nor a website based on “lite” /
RWD (responsive web design) architecture. Those things changed rapidly during the pandemic -
we comment on it at the end of the survey.
In our survey, we asked the FinTech sector about their opinion on the following question:
How do you see that FinTechs change traditional banks? It appears that the FinTechs do not
see themselves as competitors, but rather as collaborators with the traditional banks (see Figure
15). 73% of the respondents claim that traditional banks will inevitably adopt new technologies,
modernize, and ultimately digitalize. 60% support also the idea of the emergence of new business
providing specialized services, but not attempting to be universal banks. 44% suspect that the
role of traditional banks will change to commoditized service providers, while direct customer
relationships will be handled by FinTechs. The smallest group expects either that traditional banks
would become irrelevant (17%) or disappear and be replaced by new technology-driven banks (19%).
When it comes to the problem of legal regulations, the impact of FinTechs was noticed also
by our respondents (one of them said that they will contribute to the ongoing dialogue on the
introduction of legal regulations).
21
Figure 15: FinTechs versus banks
In the survey, we also asked FinTechs to explain, how they cooperate with traditional banks.
Only 17% stated that they do not interact at all. From those who do cooperate, the majority sell or
aggregate bank products and create appropriate IT solutions (analytical tools, mobile applications,
or programs responding to the challenges of banks related to large amounts of work in the back-
oce areas). Other FinTechs use bank products - mostly traditional accounts. Some companies
declared to interact with banks indirectly (e.g. through leasing companies, brokerage houses, etc.).
To summarize - most FinTechs in Poland directly or indirectly cooperate with banks, either as
supporters or as customers. Most of them do not aim at competing with banks nor see themselves
as a threat to them. Instead, banks and FinTechs are mutually linked through cooperation.
Conclusions
The survey was run in January 2020, just before the outbreak of the coronavirus pandemic. There
is no consensus on the prognosis, how the current situation can aect the FinTech sector. On the
one hand, lots of the companies are startups, and they need funding from investors, who may not be
willing to support them. On the other hand, the outbreak of the pandemic increased the demand
for cashless payments. The online work created opportunities for some FinTechs - namely those
from the banking infrastructure and payment sectors. The new reality that the world has to face
is a home-oce work, increased demand for cashless payments and digital solutions. When most
of the small enterprises encountered many tremendous diculties to survive, the FinTech branch
seems to be in a better position.
As the interview provided by Comparic (2020) shows, there are some ambiguities about the
FinTech future. From one side, the current situation is an opportunity for the FinTech start-ups,
who are better in facing high-risk situation than the traditional banks. On the other hand, there
are lots of FinTechs that provide dierent products and solutions for the tourism industry and those
would face the same challenges as the whole sector. It seems that the FinTech industry responds
to the new economic situation dependently on the sector in which they operate.
There is no doubt, however, that those who operate in payment or banking infrastructure sector,
22
will be the ones, who will suer the least. As the cashless payments have become compulsory in
the everyday shopping, the market for apps and all solutions aimed to ease the market exchange
has ourished.
From the beginning of the outbreak, the FinTech sector has had a signicant competitive advan-
tage over other sectors as the one which is based on software and technology. Moreover, what has
come out in favor of FinTechs, is that they have no physical footprints and thus, are operationally
eective during the lockdown. There is no need to reduce employment in rms which have no phys-
ical branches. Moreover, Fintechs are digital natives with strong emphasis on user-experience and
hence, are much more exible than the traditional rms. Although FinTechs, as almost debt-free,
could have been considered to be more resistant to the unfavorable market conditions, in fact their
dependence on the continuity of equity investment is remarkable. And this type of nancing might
be very capricious in tough times.
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