According to the Polish Financial Supervision Authority (KNF), the number of STOR notifications fell by 17% last year compared with 2024. Over the past five years, just over 500 such reports were recorded in total. Experts say this is relatively few for the Polish capital market.
The data also show that most notifications concern market manipulation. Experts add that Poland’s market is relatively well protected, although the figures may not fully reflect reality. Even so, they argue that the number of STOR reports is relatively low, both in absolute terms and in relation to the size of the market and comparisons with other EU countries. Poland performs quite well in this type of ranking. It does not even appear in the top ten, and its contribution is rather symbolic.
Data from the Polish Financial Supervision Authority show that in 2025 the number of STOR notifications — suspicious transaction and order reports — amounted to 78. This was 17% fewer than in 2024, when there were 94. Looking at the years 2021–2025, a total of 539 such cases were recorded: 136 in 2021, 120 in 2022 and 111 in 2023. The trend is therefore clearly downward.
As Krzysztof Michrowski, a stockbroker, court expert and specialist in capital market law, explains, notifications are submitted by the Warsaw Stock Exchange, brokerage houses or investment fund companies. In his view, the decline in the number of reports is the result of the effective elimination from the market of entities involved in manipulation. Market manipulation and insider dealing are punishable by a fine of up to PLN 5 million and imprisonment of up to five years.
“The statistics and their comparison over the years confirm the effort made by the KNF to neutralise both individual market manipulators and organised groups. Today, we rarely see new, complex and large-scale manipulation cases. When we do identify them, we react immediately and inform the market as part of the KNF Office’s transparency policy. The measures taken, the tools used and the experience of supervisory staff have helped effectively reduce the scale of manipulation on the stock market,” says Daria Ringwelska, Director of the Market Infrastructure and Trading Department at the KNF Office.
According to Dr Rafał Parvi from WSB Merito University, the number of STOR notifications is low, both in absolute terms and relative to the size of the Polish market and EU comparisons. In 2024, 5,981 STOR notifications were submitted across the EU and EEA, down 8% year on year. Germany accounted for 30% of them, France for around 16%, while Sweden and Italy each accounted for around 8%. Poland does not even appear in the top ten, and its contribution is rather symbolic, at around 1–2%.
Each year, millions of transactions are concluded on the Warsaw Stock Exchange and NewConnect. In Dr Parvi’s opinion, the 2025 data rather confirm that the Polish capital market is relatively well protected and does not suffer from a structural problem with abuse. If the number of STOR reports were rising sharply, as happened in some large countries in the past, that would be a red flag. In Poland’s case, the opposite is largely true.
“Insider trading is a separate issue, as it is one of the most difficult stock market offences to prove before the courts. Criminals are also aware of this. As the KNF Office, however, we are taking steps to discourage such illegal conduct and to make everyone aware of how damaging the disclosure and use of inside information is to market integrity,” adds Daria Ringwelska.
More detailed KNF data from the analysed period show that most notifications concern manipulation. Last year, there were 51 such reports. In addition, 23 concerned the use of inside information and four fell into other categories. A year earlier, the figures were 64, 24 and six respectively, while in 2023 they were 55, 45 and 11. Four years ago, the breakdown was 75, 26 and 19, while in 2021 it was 106, 20 and 10.
“Manipulation of a financial instrument involves using various unfair methods to broadly influence the price or volume of that instrument, usually in order to obtain certain benefits, including avoiding losses. Key factors that facilitate manipulation include limited liquidity resulting from a shallow order book. In such cases, even a small transaction can significantly affect the price of an instrument. Manipulators generally target companies with small market capitalisation or those listed on alternative markets, such as NewConnect,” says Krzysztof Michrowski.
Dr Rafał Parvi notes that manipulation dominates the reports, but its scale is decreasing. In his view, this is a typical and rather positive picture of supervision. According to the WSB Merito University expert, the most common schemes in recent years have included pump and dump, which involves inflating the price and then selling off holdings, as well as wash trades, or artificial trading.
Other practices include layering and spoofing, which involve placing a large number of buy or sell orders without intending to execute them; momentum ignition, which means initiating an artificial upward or downward trend; and concealing ownership, or hiding actual ownership through collusion.
“A particularly dangerous phenomenon is insider trading. This refers to the use of confidential information that has not yet been made public to carry out stock exchange transactions. It may involve, among other things, financial results that significantly differ from expectations, planned mergers and acquisitions, major contracts or decisions to announce a tender offer for shares. Using such data before it is officially disclosed creates information asymmetry and violates the fundamental principle of equal opportunities for investors,” adds Krzysztof Michrowski.
According to KNF data, in 2025, eight notifications were submitted concerning violations of Article 183 of the Act on Trading in Financial Instruments, which relates to manipulation, and five notifications concerned violations of Articles 180 and 181 of the same act, relating to the disclosure and use of inside information. In 2024, the figures were also eight and five respectively. A year earlier, they were eight and three, in 2022 five and five, and in 2021 one and four.
According to Krzysztof Michrowski, despite the visible decline in the number of STOR reports, more than 10% of them still result in the KNF Office filing a notification with the prosecutor’s office on suspicion of a crime. In his opinion, taking into account the harm caused to unaware market participants by manipulators or those using inside information, this is still a relatively high number.
“Official STOR data do not fully reflect reality. The scale of market abuse is most likely much larger, while detection remains limited. This is typical of white-collar crime and financial abuse. In addition, the reporting obligation rests primarily on investment firms, platform operators and persons professionally arranging transactions. Many of these entities have insufficient monitoring systems or fear reputational costs,” Dr Parvi points out.
Krzysztof Michrowski, however, believes that in the broad context of the phenomenon under discussion, official data do reflect reality. Many STOR reports are false alarms. Investment firms prefer to err on the side of caution and submit a report concerning a transaction they consider suspicious, rather than expose themselves to possible administrative sanctions for failing to report it.
“Regulators openly point to the problem of under-reporting. Even the KNF’s advanced tools, including automation, machine learning and anomaly analysis, do not detect everything, especially subtle manipulation, insider trading without clear traces, OTC transactions, cross-border activity or smaller instruments. Many abuses are structured in such a way that they appear to be normal market activity,” Dr Parvi argues.
The WSB Merito market expert also notes that in Poland both experts and the KNF emphasise that the problem is underestimated, and that the low number of STOR reports may result more from gaps in the reporting and supervision system than from a clean market. In its priorities for 2026, the KNF Office continues to strongly emphasise the fight against insider trading and manipulation.
Research into court rulings shows that proceedings last very long — even eight times longer than average — while conviction effectiveness is moderate. At the same time, the expert clearly stresses that the overall trend is downward.
“The KNF does not refer hundreds of cases to the prosecutor’s office, but only those that have a real chance of leading to an indictment. If the KNF were filing, for example, 30–40 notifications a year, we could talk about a growing problem. Here we have a stable, low level in the years 2022–2025. This is a signal that prevention works, and that supervision is effective and rational. The number of notifications in 2025 does not reflect the real impact on the market. One well-documented notification concerning a large group and high amounts is more important than a dozen minor cases,” concludes Dr Rafał Parvi.
Source: CEO.com.pl
