Publication date: January 19, 2026
A regulated market is a system for trading in financial instruments admitted to trading. It operates according to the rules established by the entity operating the market and is supervised by the Polish Financial Supervision Authority. It is the most formal and strictly regulated type of market. It must be based on transparency, equal access, and disclosure requirements. Shares, bonds, and other securities are permitted on the market. The goal of this market is to ensure safe and fair trading in financial instruments. Market participants include banks, companies, investment firms, and investors.
An auction platform is a specialized type of organized market. It is used for the sale of specific instruments – most commonly CO2 emission allowances—through auctions. The Act of 29 July 2005 on Trading in Financial Instruments is one of the most important legal acts of the Polish capital market. It regulates the operation of the securities and other financial instruments trading market, as well as the activities of investment firms, stock exchanges, trading platforms, and financial supervision. Pursuant to the Act on Trading in Financial Instruments, the Regulation of the Minister of Finance was issued on July 23, 2025, amending the Regulation of April 12, 2019, on detailed conditions that must be met by the regulated market and the auction platform.
The following changes are introduced to the Regulation of the Minister of Finance of April 12, 2019, on detailed conditions that must be met by the regulated market and the auction platform (Journal of Laws, item 726):
• Introduction to the calculation in §4. A company that operates a regulated market and manages the operational risk to which the regulated market it operates is exposed – including risks related to the use of information and communication technology – ITC, in accordance with the requirements specified in Chapter II of Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on the digital operational resilience of the financial sector and amending the regulations.
• The proposed amendment serves to implement Dora Regulation. In §4 paragraph 2, point 1 has been repealed, providing that the company operating a regulated market is responsible for developing rules for identifying and estimating the level of risk. The repeal of this section is related to the introduction of its expanded version.
• §4a has been introduced, under which a regulation has been introduced, pursuant to which a company operating a regulated market has technical and organizational solutions ensuring: operational resilience in accordance with the requirements specified in Chapter II of Regulation 2022/2554, including:
• Another change is the addition of §5a to Article 5. This Article applies to companies operating a regulated market submitting data to the consolidated tape data center. Article 2(1)(35) of Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012 establishes mechanisms to ensure compliance with data quality standards, in accordance with Article 22b of that Regulation.
Pursuant to the aforementioned Regulation 600/2014, a consolidated tape provider or CTP is a person authorized to provide services that involve collecting data from trading venues and approved entities that publish and consolidate such data into a continuous and electronic stream of current data that provides essential regulatory and market data. Article 22b establishes data quality standards, specifying regulatory technical standards.
The amendment also applies to §8, section 2, item 4, which adds the term “state-owned bank conducting brokerage activities.” Therefore, in the new regulation, a company operating a regulated market establishes transparent and objective rules for obtaining member status on a given regulated market. These rules take into account the obligations associated with holding regulated market member status resulting from additional requirements to which members other than investment firms, state-owned banks conducting brokerage activities, foreign investment firms, or credit institutions are subject. After section 2, section 2a has been added, stipulating that companies operating a regulated market must ensure that no fewer than three members who demonstrate a significant degree of activity hold regulated market member status, each of whom may interact with other members in relation to price formation on the regulated market.
An additional change is the introduction of a provision in §8, section 3, point 1a, which allows a company operating a regulated market to grant regulated market member status to a state-owned bank conducting brokerage activities. In Article §10, section 2, the words “investment firms” and “foreign investment firms” have been replaced with “investment firms” and “state-owned banks conducting brokerage activities,” as well as “foreign investment firms”. Additionally, an amendment has been introduced to §10, section 4. The provision requires the entity operating a regulated market to implement solutions that distinguish orders and transactions submitted using direct electronic access from those executed directly by an investment firm, bank, or foreign investment firm. This entity must also have the ability to suspend the execution of orders and transactions executed through such access, regardless of the actions of the entities that provided such access. The purpose of the provision is to ensure the security of trading, oversight of electronic trading, and the ability to quickly respond to potential threats to the market.
Another change is in §10, introducing references to “state-owned banks conducting brokerage activities” right after investment firms. The largest change concerns the introduction of §10a. This provision applies to a company operating a regulated market that allows the submission of orders using algorithmic trading. It imposes the obligation to have appropriate solutions and procedures in place, consistent with Commission Delegated Regulation (EU) 2017/584, aimed at preventing disruptions in trading in financial instruments and effectively managing such disruptions if they occur. These solutions include, among other things, the obligation for market members to test algorithms, the introduction of mechanisms to limit the number of unexecuted orders relative to the number of transactions, and the ability to slow down the transmission of orders in situations where there is a risk of system overload. The reference to Chapters II and IV of Regulation 2022/2554 indicates that the purpose of the provision is to implement EU requirements on ICT risk management and digital resilience testing, thus aligning national regulations with EU regulations on the stability and security of electronic trading.
The Regulation of the Minister of Finance fully transposes numerous directives stemming from EU regulations into Polish law, ultimately contributing to more effective risk management related to information and communication technologies and strengthening operational digital resilience. The changes are also dictated by the modification of the legal nature of state-owned banks, which is reflected in the proposed amendments.