Poland remains a key and consistently growing insurance market in Europe. The sector continues to evolve, with market development shaped by regulatory expectations, operational standards and changing risk dynamics. These factors frame current developments in distribution, the digital framework and customer interaction.
Insurance distribution
One of the most significant forward-looking developments is the Polish Financial Supervision Authority’s (KNF) work on comprehensive Recommendations on Insurance Distribution. Although constituting soft law, these Recommendations set out supervisory expectations across the entire distribution lifecycle, including governance, remuneration, assessment of customer needs and product value. Their stated objective is to eliminate unsuitable products from the market and to standardise practices across insurers and intermediaries. Once finalised, they are expected to serve as an important benchmark in supervisory reviews.
Digital resilience and technology risk
From an operational perspective, the implementation of the EU Digital Operational Resilience Act (DORA) represents a structural change for Polish insurers. National guidance on cloud computing has been withdrawn in favour of the EU framework, and national legislation will grant the KNF broad supervisory and sanctioning powers. Insurance companies should therefore expect increased focus on ICT risk management and outsourcing arrangements. In parallel, Poland is preparing its national framework for the application of the EU Artificial Intelligence Act. While sector-specific guidance is still evolving, insurers using AI processes should anticipate heightened governance and compliance expectations.
Digital customer interaction
Digitalisation continues incrementally. Introduced amendments will allow complaints and correspondence to be conducted electronically. Government-backed digital tools, including the mStłuczka motor claim reporting function within the mObywatel application (a mobile app launched by the Polish government), reflect a broader policy direction towards automated claims’ initiation and data-driven processes. Furthermore, the mObywatel app is set to become a cross-border accepted identity wallet (including introduction of qualified signatures within the app). Financial institutions such as banks and insurance companies are expected to offer entirely new services based on the data in the identity wallet, which could be used, for example, in credit processes and in calculating insurance premiums.
Outlook for 2026
Looking ahead to 2026, insurers in Poland should expect intensified supervisory focus on distribution practices, property insurance exposure, catastrophe risk and operational resilience, alongside preparation for revised Solvency II requirements and future insurance recovery and resolution frameworks. These developments will require not only regulatory compliance, but also strategic, operational and transactional readiness. In this evolving environment, our team supports clients across regulatory and transactional matters, including M&A, portfolio transfers and strategic projects, combining deep local expertise with a clear understanding of the evolving risk landscape.
