Posted by Since May 2025, Fincard, by far the largest lender on TWINO, has been under investigation by Poland’s consumer protection authority UOKiK.
The allegation: circumvention of the statutory interest rate cap. The possible consequences: a fine of up to €5.3 million, plus refunds to customers that cannot yet be quantified, and proceedings that could drag on for years.
As someone who personally has more than €15,000 invested in Fincard receivables via TWINO, I have taken a closer look at the matter over the past few weeks and, in parallel, sent the Latvian P2P platform a list of questions.
This article covers what exactly the dispute between the consumer protection authority and the TWINO lender is about, what consequences are at stake, and what the proceedings mean for investors on the Latvian P2P platform.
What Happened?
On 15 June 2026, UOKiK announced that it is conducting proceedings against two credit card providers: the Bulgarian company Easy Payment and Fincard, which offers credit cards in Poland under the Net Credit and Halvo brands.
According to the company, the proceedings against Fincard were initiated as early as May 2025. Important: these are still ongoing proceedings. So far, there has been neither a decision nor a fine.
What are the Proceedings About?
Poland caps the cost of consumer credit on two levels.
- On one hand, there is an interest rate cap (2024: 18.5% per year),
- on the other hand, there are separate caps on fees and commissions.
From May to December 2024, Fincard charged, in addition to interest, a commission for the use of the credit limit. This was charged regularly and depended on the amount used. Together with the interest, the cost of credit added up to around 39% per year, according to Fincard.
UOKiK argues: a fee that is charged on an ongoing basis and grows with the amount borrowed is economically interest, whatever it is called. In effect, the interest rate cap was circumvented.
Fincard claims: the law allows interest and fees side by side. Both have their own caps, and both were complied with. The model is also widely used on the Polish market.
At its core, this is a dispute over interpretation: where does a fee end and interest begin?
Interestingly, Fincard has been using a different model since January 2025: interest on the credit actually used, plus a separate commission for making the approved limit available. This commission is 1.64% of the approved limit per billing period, regardless of how much of it is used.
Fincard cites not the proceedings but that default rates were too high under the old model as the reason for the change. Whether the new model is unproblematic from UOKiK’s point of view remains open. So far, however, it is not part of the proceedings.
Where does Fincard stand?
Fincard has told the news agency PAP that it has acted in compliance with the law and will appeal against any negative decision. In response to my questions, the company does not rule out a settlement with UOKiK either. Since the press release, however, there has reportedly been no further contact with the authority.
Fincard has support from Polish lawyer Tomasz Czech, who considers the allegations unfounded in a LinkedIn post and expects the case to fail in court. The discussion beneath his post, however, also shows that legal opinion is divided on this question.
Investors should also bear two things in mind.
First: Fincard has not disclosed its legal arguments, which is understandable in regards to the ongoing proceedings. The “strong legal arguments” that TWINO referred to in its Telegram group therefore cannot be verified from the outside.
Second: TWINO had pointed out that the financial supervisory authority KNF had never raised objections to the pricing model. When asked, Fincard explained that the KNF is informed about product changes but does not approve them individually. “No objections” therefore does not mean “reviewed and approved”.
Consequences and Worst-Case Scenario
What consequences could Fincard face in the worst case?
Fine. UOKiK can impose a fine of up to 10% of the annual turnover. With revenue of €53 million (Fincard annual report 2025), that would be a maximum of €5.3 million. The TWINO CEO had told the community that UOKiK fines in practice tend to be around 2 to 3% of the revenue. However, there is no evidence to support this.
Refunds to customers. If UOKiK classifies the practice as unlawful, customers could demand fees back. Fincard says it cannot quantify this risk. The company also does not say how many customers were affected.
No provision. Fincard has not yet made a provision for the proceedings. The risk is therefore not reflected in the financial statements.
Long duration. In the community, there was talk of one to three years. In the questionnaire, Fincard writes that some cases in the industry have been open for more than seven years. The proceedings are therefore likely to accompany Fincard for years.
On top of this comes a state of regulatory limbo: responsibility for the Polish implementation of the EU Consumer Credit Directive CCD II was taken away from UOKiK in May 2026, and the law is being rewritten by the Ministry of Justice. Poland will therefore miss the EU deadline set for November 2026. A law is not expected before 2027.
Until then, it remains unclear which fee models will be permitted in future.
Ramifications for TWINO Investors
What consequences do the proceedings have for investors on TWINO?
TWINO is effectively Fincard. As of 1 October 2026, around 96% of the outstanding portfolio belonged to Fincard: €37.6 million (91.6%) to Netcredit and €1.8 million (4.5%) to Netcredit FLEXI. The only other lender, Vamo from Vietnam (defaulted), accounts for €1.6 million (3.9%). Anyone investing on TWINO is therefore investing in Fincard. There is no diversification within the platform.
No buyback guarantee. Unlike on many other platforms, there is no buyback guarantee on TWINO. What matters, therefore, is solely whether Fincard can bear a fine and possible refunds on its own.
The capacity is there. Fincard has more than €18 million in retained earnings and is profitable. A fine at the upper end would eat up a noticeable part of that, but would not threaten Fincard’s existence. The refund risk, on the other hand, cannot be assessed, because neither Fincard nor UOKiK has quantified it. And as long as there is no provision, none of these risks show up in the figures investors see.
Conclusion and Assessment
The UOKiK proceedings are not a case of fraud and not an acute crisis. They are a legal dispute over a pricing model that Fincard has not used since the beginning of 2025.
For the risk assessment, this means the following:
- The outcome of the proceedings is open and may take years.
- Fincard’s legal position cannot be verified from the outside.
- With a 96% Fincard share and no buyback guarantee, every Fincard risk is a TWINO risk.
From a purely financial perspective, Fincard has very solid key figures. The uncertainty in this case lies above all in the fact that, depending on the outcome of the proceedings, possible refunds to customers cannot be quantified. This uncertainty needs to be priced in, and the weighting of the TWINO position assessed on that basis.
Personally, I have decided for the time being neither to expand my investment on TWINO nor to sell my loans, but to wait and see how the proceedings develop.
My cautious optimism is based on the fact that I do not expect an absolute worst-case scenario. TWINO has been present in Poland for more than 15 years and has lived through, and adapted to, several waves of regulation during that time. Even if the pricing model should turn out not to have been compliant, the financial consequences for a company with more than €18 million in retained earnings seem bearable to me.
On top of that, TWINO answered my questionnaire in great detail and also admitted uncomfortable things in the process. That is more transparency than you usually get in the P2P market on critical topics. Personally, I take that as a good sign to continue backing the positive development of the P2P platform under its new CEO Nauris Bloks.
A detailed assessment of the platform can be found in my TWINO Review.
I’m Denny Neidhardt, the founder of re:think P2P. On this blog, I help retail investors make smarter, well-informed investment decisions in the world of P2P lending. Since 2019, I’ve been publishing in-depth analyses, platform reviews, and risk assessments to bring more transparency to this investment space. My goal is to challenge marketing claims, question developments, and empower investors with honest, independent insights.