Introducing the definition of 'sandbox' to the new act
We lobbied for the creation of a safe testing environment for startups. Our proposals were included in 94% of the final text of the minister's regulation.
The FinTech Polska Hub association faced a wall of unclear regulations that blocked the testing of new payment services. The lack of a legal 'regulatory sandbox' forced Polish companies to move their development departments to Estonia. We undertook to introduce a specific definition of a sandbox into the Polish legal system.
The challenge
In 2023, as many as 11 promising fintech startups resigned from operating in Poland due to the risk of penalties from the regulator. It was not clear what was allowed to be tested without a full banking license, which costs a fortune. The association's member companies lost an average of 430,000 PLN on audits that ultimately did not guarantee legal safety. The Ministry of Finance was working on a new act, but ignored key simplifications for the technology sector.
Our approach
We started with a comparative audit of regulations in 4 countries in the region to show officials how capital is escaping us. The Suprasorte Strategic Lobby team prepared 6 letters with specific amendments that struck at the heart of the problem. For 5 months, we took part in 14 parliamentary subcommittee meetings, patiently explaining the difference between a transactional system and a testing environment. We know the corridors of the Parliament and we knew who to reach with arguments about market stability.
The solution
We developed an original legal definition of 'technological sandbox', which allows for a 12-month trial period for new services. We proposed a system of conditional KNF permits, which shortens the formalities from 9 months to 41 days. Our solution also contained a ready-made error reporting scheme that does not result in immediate revocation of rights. Most of these provisions went directly into the final text of the regulation.
Results
Thanks to our actions, the fintech sector gained a clear legal framework for testing, which stopped the brain drain abroad. The first recruitment for the sandbox started in September 2024 and immediately attracted market leaders.
Timeline
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October 2023Analysis of 27 legal loopholes in the ministry's original draft.
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January 2024Submission of the report with recommendations for changes to the chairman of the committee.
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March 2024Participation in the work of the standing subcommittee on financial institutions.
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July 2024Final approval of the sandbox definition in the vote.
"I thought the legislative process was untouchable for small players. Suprasorte Strategic Lobby showed that facts matter, not promises. Our amendments passed almost unchanged."