Changes in KNF Proceedings: Upfront Fees, New Cost Allocation and Faster Procedures

On May 19, 2026, the Polish Council of Ministers adopted a draft amendment to the rules governing fees payable to the Polish Financial Supervision Authority (KNF). The proposal, submitted by the Minister of Finance and Economy, forms part of a broader deregulation agenda aimed at simplifying administrative procedures and improving efficiency in regulatory proceedings.

Key changes to KNF proceedings

• a more equitable allocation of supervisory costs,
• the introduction of upfront fees for permits, approvals, and register entries.

A fairer allocation of supervisory costs

Currently, the costs of certain proceedings—such as notifications of the intention to acquire shares in an investment firm or a management company (TFI), or assigning additional duties to a TFI management board member—are borne by all financial market participants.

The draft proposal seeks to change this approach. Under the new rules, only entities that initiate proceedings will be required to cover the related costs. As a result:

• other market participants should benefit from lower supervisory charges,
• cost allocation will become more transparent and proportionate,
• the system will be perceived as fairer across the market.

Upfront fees for applications

Another key change concerns the timing of fee payments. Until now, fees for permits, approvals, or registrations were collected only after the conclusion of proceedings. The new framework introduces an upfront payment requirement, meaning fees must be paid at the time of filing an application with the KNF.

This change is designed to:

• improve the quality of submitted applications,
• reduce the number of incomplete filings,
• limit the need for formal requests to supplement documentation,
• streamline administrative processes.

Impact on the duration of proceedings

In practice, many applications submitted to the KNF currently contain formal deficiencies or incomplete documentation. In such cases, the authority requests additional information, and the statutory deadline for issuing a decision only starts once the application is complete.

This often leads to prolonged proceedings—sometimes lasting several months or even over a year. The upfront fee requirement is expected to encourage applicants to prepare complete documentation from the outset, which should:

• accelerate the start of statutory deadlines,
• shorten overall processing times,
• increase administrative efficiency.

Eliminating operational inefficiencies

The proposed changes also address practical issues such as:

• delays in fee payments after proceedings conclude,
• the need for enforcement and debt collection measures by the KNF,
• “test” or non-serious applications submitted only to assess licensing procedures or regulatory readiness.

What do these changes mean for businesses?

For companies operating in or entering the financial market, the proposed changes will require a more structured and disciplined approach to regulatory processes.

In particular, businesses should:

• ensure full completeness of documentation before submission,
• budget for administrative fees at an early stage,
• take a more strategic approach to initiating regulatory proceedings.

Entry into force

The new regulations are expected to come into force 6 months after their publication in the Journal of Laws.

Summary

The proposed reform of KNF proceedings aims to simplify procedures, improve efficiency, and increase accountability among applicants. The introduction of upfront fees and a fairer cost allocation model should contribute to faster proceedings and a more efficient financial regulatory framework.