KNF Regulatory Sandbox


As part of the KNF Board’s task to undertake activities aimed at supporting innovation in the financial market, the KNF Authority (PL. Urząd Komisji Nadzoru Finansowego—UKNF) is launching a development programme for the financial market called ‘The KNF Regulatory Sandbox’.

The Sandbox will be running in a decentralised model, under which IT test environments are made available by start-up accelerators, financial institutions, foundations and/or other qualified entities (called Sandbox Operators).

The Sandbox is open to the entities which are planning to start operating in the financial market (start-ups) and have an untested innovative financial product and/or service based on innovative information technologies, and to the entities which already provide certain solutions on the financial market (supervised entities—financial institutions) and wish to conduct further tests in order to develop new services and/or business models.

The Operators’ test environments may be both virtual, in the form of a computer system simulating market behaviours, and completely real, involving interaction with real clients (however without the option for using clients’ funds). Both the test environments and the entities which are to test their solutions will be monitored and technically assisted by the UKNF.

In order to be eligible for the KNF Regulatory Sandbox, an innovator must have a registered office in the territory of the Republic of Poland.

The applications for the Sandbox will be reviewed according to specific criteria for participation in the Programme, such as:
(1) Range of the solution
The Sandbox is open to the entities which offer financial products and/or services with the required features of a KNF-supervised activity, and/or solutions designed for direct support and/or development of activities of supervised entities.
(2) Innovative nature of the solution
The new solution should be innovative or, at least, different from the existing solutions available on the market. In addition, the product or service should support the development of the Polish financial innovation sector.
(3) Real need to participate in the Sandbox
The entity’s need to use the Sandbox should be justified, i.e. the entity must meet the condition that placing a product or service on the market involves significant costs and that there is no guarantee for the return of funds invested in obtaining the required authorisations. In addition, the innovator must meet the condition according to which the solution clearly does not fit in the existing legal framework, which prevents it from being placed on the market.
(4) Readiness to test the solution
An important issue which should be noted by applicants is the readiness to conduct the tests and the consent to the testing performed by a third party or by the UKNF.