Ostateczna decyzja ws. „Konsorcjum Idea Broker” sp. z o.o.

The Polish Financial Supervision Authority (KNF) has issued a final decision in the case of Konsorcjum Idea Broker sp. z o.o., overturning its earlier 2024 decision and imposing a new sanction. The regulator found that the firm allowed brokerage activities to be carried out by an individual who was not entered in the Register of Insurance Intermediaries, contrary to Article 29(1) of Poland’s Insurance Distribution Act. For compliance teams, this underscores the non-negotiable requirement to verify the registration status of every person or entity performing insurance distribution activities before delegating or outsourcing those tasks.

Firms operating in Poland—or distributing insurance cross-border into Poland—should audit their intermediary networks, agent and sub-agent arrangements, and outsourcing agreements. Practical steps include: (1) confirming each intermediary’s current entry in the KNF register; (2) updating onboarding and periodic due diligence procedures; (3) embedding registration checks into contract approvals and renewals; (4) training staff on Article 29(1) obligations; and (5) documenting oversight of delegated activities. The decision also signals that KNF will revisit and replace earlier enforcement outcomes when legal or factual assessments change, so firms should maintain robust records and be prepared to respond to supervisory reviews.

While the immediate action targets one broker, the compliance principle applies across insurance distribution. Non-compliance can lead to financial penalties, licence restrictions, and reputational damage. Conversely, firms with strong intermediary verification frameworks can differentiate themselves as reliable partners.

RegCanary will continue to monitor KNF enforcement trends and their implications for insurance distribution governance.