Friday, 31 July 2026
The Polish Financial Supervision Authority (Polish FSA) has adopted a comprehensive new set of recommendations governing insurance distribution, marking the most significant overhaul of the country’s regulatory framework in more than a decade.
Published on 29 June 2026, the new guidance replaces the regulator’s 2014 distribution guidelines and expands the framework from 12 recommendations to 29. The measures will take effect from 1 July 2027, while specific provisions relating to the savings component of life insurance products will be introduced a year later, on 1 July 2028.
Broader Impact Across the Insurance Market
Although the recommendations are formally directed at insurance companies, their practical impact extends well beyond insurers. The new rules will also affect insurance intermediaries operating in Poland, including agents and brokers based in other European Union member states that provide services in the Polish market either through local branches or under the EU’s freedom to provide services regime.
Recommendations covering intermediary oversight, remuneration, support and compliance obligations are expected to reshape relationships between insurers and their distribution networks, making Poland’s approach one of the more far-reaching within the European insurance sector.
Stronger Focus on Customer Value
A central element of the new framework is the requirement that insurance products deliver demonstrable value to customers.
The Polish FSA expects insurers to ensure that the expected value of claims and benefits remains proportionate to premiums paid. In general, products should generate expected claims and benefits worth at least 30% of anticipated gross premiums, while lower-cost insurance products are subject to a minimum threshold of 20%.
This value-based assessment, previously associated primarily with certain credit protection insurance products, will now apply across a much broader range of insurance products and distribution channels. Several specialist products, including large-risk insurance, annuities, insurance guarantees and selected pension products, remain outside the scope of these requirements.
For life insurance products that include an investment or savings element, regulators have also introduced a maximum annual cost impact threshold of 2.65%.
New Rules for Remuneration
The recommendations introduce enhanced governance over remuneration structures for employees, agents and distributors.
Insurance companies are expected to establish remuneration policies that promote customer interests rather than purely sales-driven objectives. Variable compensation and incentive schemes should increasingly incorporate qualitative performance indicators alongside commercial targets.
Suggested assessment criteria include customer complaints, satisfaction surveys, mystery shopping results, policy cancellations, reasons for rejected claims and outcomes of legal disputes, reflecting a stronger emphasis on service quality and customer outcomes.
Greater Oversight of Insurance Agents
The updated framework strengthens insurers’ responsibilities for supervising their distribution partners.
Beyond monitoring legal compliance and registration requirements, insurers are expected to provide agents with ongoing guidance, training and operational support. The recommendations also encourage corrective actions before disciplinary measures are imposed, creating a more structured framework for cooperation between insurers and intermediaries.
The regulator has also clarified that agents should have a clear basis for requesting assistance from insurers where necessary.
More Flexible Customer Needs Assessment
The Polish FSA has adopted a more practical approach to assessing customers’ insurance needs than originally proposed during consultations.
If customers decline to provide information needed for a needs assessment, insurers must explain the consequences of withholding that information rather than automatically preventing the sale. Companies are also required to maintain appropriate documentation demonstrating that recommended policies match customer requirements, while retaining flexibility over how those records are created across different distribution channels.
For policy renewals, insurers may continue using previously collected customer information provided customers are informed and given the opportunity to update their details.
In cases involving third-party or group insurance contracts, insurers must obtain sufficient information from the policyholder to assess the needs of the insured individuals or groups.
Renewals Face Additional Scrutiny
Before renewing policies or offering cover for a new policy period, insurers will be expected to review whether any product changes could affect the suitability of coverage for customers based on their previously assessed needs.
Industry Preparation Begins
The recommendations will operate under a “comply or explain” approach. Insurers choosing not to implement specific recommendations must notify the Polish FSA by 15 July 2027 and explain how they intend to meet the regulator’s supervisory objectives through alternative measures.
With implementation less than a year away, insurers are expected to begin reviewing product governance, distribution practices, remuneration structures and internal compliance frameworks to ensure readiness before the new regime comes into force.
While formally aimed at insurance companies, the breadth of the recommendations means that intermediaries, including cross-border operators active in Poland, are also expected to experience significant operational and compliance changes under the new framework.
