⚠ Best Execution Is a Standard Somebody Else SetsModerate threat

XTB (XTB) — threat to the moat

When the venue is your own book, best execution is a comparison against reference prices you selected yourself.

A firm that quotes the only available price to a retail client is required, under European conduct rules, to take all sufficient steps to obtain the best possible result for that client, and to be able to demonstrate it. When the venue is the firm's own book, the demonstration is necessarily a comparison against reference prices the firm itself selects.

Four things the same firm decidesThe price the client seesQuoted by XTB, no order bookWhether to hedge it8 pc of notional, June 2026The reference used for best executionSelected by XTBThe spread advertisedAmong the lowest, XTB saysWhat it actually earned84 to 238 USD per millionWhat the client is shownAggregate, quarterly, in a PDFEvery one of these is legal, disclosed and managed - and all four sit on one side
Which is why the supervisor keeps returning to this question.

This is the enduring supervisory question in market making, and it has produced concrete outcomes elsewhere in retail finance: rules on the display of costs and charges, requirements to publish execution quality, restrictions on internalisation, and in the specific case of order-flow payments, an outright European ban taking effect on 30 June 2026.1 The direction is consistently toward making the intermediary's economics visible to the client.

The commercial exposure is not a fine. It is that a client who can see, on the statement, how much of the price movement went to the house is a client who compares brokers on something other than the advertised spread. XTB's advertised terms are genuinely competitive; the realised take per unit of activity varies by a factor of three and is disclosed only in aggregate, once a quarter, in a management report most clients never open.

There is also a conflict that no disclosure removes. The firm sets the price, holds the other side, decides how much to hedge, and profits when the client is wrong. Every one of those is legal and managed. Together they are the reason the regulator keeps returning.

Watch for any European requirement to disclose execution quality or firm revenue at the level of the individual client trade.

References
  1. ReportedThis is the enduring supervisory question in market making, and it has produced concrete outcomes elsewhere in retail finance: rules on the display of costs and charges, requirements to publish execution quality, restrictions on internalisation, and in the specific case of order-flow payments, an outright European ban taking effect on 30 June 2026.
    XTB Group Management Board report on activities in 2025, business model and competitive landscape - the model "combines the features of an agency model with a market maker model, in which the Company is a party to transactions concluded and initiated by clients"; "XTB operates as a market-maker, meaning it is the counterparty to a client's transaction"; "XTB executes all transactions in shares, ETFs, and CFDs based on these assets directly on regulated markets or alternative trading systems. XTB is not a market maker for this class of instruments"; the competitive environment divided into trading platform providers (eToro, Trading 212, Robinhood), fintech companies (Trade Republic, Scalable Capital, Revolut) and CFD-only brokers (Plus500, IG Group, CMC Markets, Saxo Bank), with Polish bank-affiliated brokerages named as mBank Biuro Maklerskie, Santander Biuro Maklerskie, Dom Maklerski Banku Ochrony Srodowiska (BOSSA), PKO BP Biuro Maklerskie, ING Securities and Bank Pekao S.A. Biuro Maklerskie, and XTB described as a market leader in Poland; the planned European ban on the payment-for-order-flow model from 2026; key competitive advantages listed as a wide product range including stocks, ETFs, Investment Plans and CFDs plus interest on free funds, an eWallet with a multi-currency card and long-term savings accounts IKE (Poland), ISA (United Kingdom) and PEA (France); the proprietary xStation platform and XTB mobile app; no commissions up to EUR 100 000 turnover on stocks and ETFs and no withdrawal fees; operations in over 15 countries; regulation by nine financial authorities including the FCA and KNF; client fund segregation; 24/5 support; and the XTB Academy. Brand ambassadors Mads Mikkelsen (2016-2018), Conor McGregor and Iker Casillas (2022-2024) and Zlatan Ibrahimovic (2024-2026); nearly PLN 585 million allocated to marketing in 2025, up 69,6%, including the largest campaign in the group's history launched in September 2025 across 13 markets including Poland, France, Germany, the United Kingdom, Chile, the Middle East and Indonesia, and sponsorship at Roland Garros and Wimbledon; the XTB brand dating from 2009 and the word "trading" replaced by "investing" in 2023 — FY2025 · publ. March 2026 · source ↗
Sources
Generated September 24, 2026