The Licence, and the Nine Regulators Behind ItNarrow moat

XTB (XTB) — moat facet

A permit from 2005 that keeps competitors out, held by the party that halved the business overnight in 2018.

XTB has held a brokerage permit from the Polish Financial Supervision Authority since 8 November 2005.1 Everything the company does rests on it, and nothing about the company is harder to copy.

Group total capital ratioWACC ~100%165,8%2019200,1%2020200,1%2021218,1%2022188,7%2023192,3%2024186,0%2025A ratio of 100 per cent would already be compliant
Seven years in which money was never the constraint on this company.

A retail brokerage licence in the European Union is not a form. It requires capital held permanently against the business, a compliance function with real authority, segregated client money, audited controls over an in-house trading book, and a supervisor willing to say yes. XTB is regulated by nine authorities across Europe, the Middle East and Latin America, and it clears its own Polish capital requirement by a margin most banks would find embarrassing: a total capital ratio of 186 per cent at the end of 2025, against a ratio of 100 per cent that would already be compliant.2

What the licence buys is a market with very few new entrants. The rivals XTB names in its own filings are the same rivals it named five years ago.3 The field consolidates rather than expands, because the cost of entering it is a supervisory relationship that takes years to build and can be withdrawn in a single decision.

Which is exactly the qualification. This barrier belongs to somebody else. It keeps competitors out, and it also allows the party holding it to change the terms of the business without notice, which the European Securities and Markets Authority did in August 2018 and could do again.4

At 186 per cent, the capital ratio says the licence is not currently constraining anything XTB wants to do.5 It is the supervisor's appetite, not the balance sheet, that binds here.

Moat trajectory: Holding steady

The permit dates from 2005, the branch network from the years after it, and nothing about the regulatory position has changed materially since 2018. The capital ratio has sat between 165 and 218 per cent for seven years. This facet neither improves nor decays; it simply is.

The number that tests this moat
Reported
Group total capital ratio
186,0% at the end of 2025, never below 165% since 2019

The Polish brokerage permit dates from 8 November 2005 and XTB is regulated by nine authorities. Its group capital ratio has been 165,8, 200,1, 200,1, 218,1, 188,7, 192,3 and 186,0 per cent across 2019 to 2025. The licence keeps competitors out and has never constrained anything XTB wanted to do; it belongs to somebody else, which is the entire qualification. Watch for any conduct proceeding in a market carrying real revenue.

Source: XTB Group consolidated annual report for 2025 ↗
Aspects of the moat
DIG DEEPER 01
One Permit, Fifteen Countries
One Polish authorisation serves fourteen other countries, which is why 703 333 clients in six months is physically possible for 1 516 people.
DIG DEEPER 02
The Capital Nobody Requires It to Hold
A 186 per cent capital ratio on a balance sheet that is mostly other people's money - because the product being sold is the ability to pay.
DIG DEEPER 03
The Entities Outside Europe
Belize, the Emirates, Chile and Indonesia are where the 30:1 leverage cap does not reach.
DIG DEEPER 04
Control Without a Majority
One holder with 35,78 per cent controls a regulated brokerage, and the supervisor is part of why that cannot simply be sold.
⚠ Threats to the moat
⚠ THREAT 01
The Regulator Sets the Leverage
The most important input into this revenue line is not a market variable - it is a number set by a committee, and the committee has moved it before.
⚠ THREAT 02
A Licence Is Permission, Not Property
Nine regulators is nine relationships that can each go wrong on their own, and one of them has already fined this company more than a quarter's…
References
  1. ReportedXTB has held a brokerage permit from the Polish Financial Supervision Authority since 8 November 2005.
    XTB Group consolidated financial statements for 2025, balance sheet, off-balance-sheet items, employment, capital and shareholders - nominal value of derivative financial instruments at 31 December 2025 and 31 December 2024: Index CFDs 3 933 252 and 3 766 277; Commodity CFDs 6 216 958 and 3 705 548; Currency CFDs 3 284 496 and 2 952 168; Stock and ETF CFDs 1 615 397 and 1 169 077; Bond CFDs 1 553 and 11 126; total 15 051 656 and 11 604 196, of which transactions with brokers represent 16% at 31 December 2025 and 14% at 31 December 2024; clients' financial instruments held in brokerage accounts: listed stocks and rights to stocks 15 138 542 and 7 907 437; ETFs 12 144 808 and 5 773 953; other securities 207 and 207; total 27 283 557 and 13 681 597; contributions made to the compensation scheme with an opening balance of 17 923 and a closing balance of 23 981; total employment in the Group at 31 December 2025 of 1 516 people against 1 245 at 31 December 2024, including persons under employment contract and other forms of civil law contract including B2B; the Parent Company supervised by the Polish Financial Supervision Authority under a permit dated 8 November 2005, No. DDM-M-4021-57-1/2005, registered in the National Court Register under KRS 0000217580 with its seat at ul. Prosta 67, 00-838 Warszawa; foreign branches in the Czech Republic, Spain, Slovakia, Romania, Germany, France and Portugal; subsidiaries including XTB International Ltd (Belize), XTB MENA Limited and XTB Financial Services L.L.C (United Arab Emirates), PT XTB Indonesia Berjangka (90%), XTB Agente de Valores SpA (Chile), XTB Services Limited (Cyprus), X Open Hub Sp. z o.o. (Poland), XTB S.C. Limited (Seychelles), XTB Africa (PTY) Ltd (South Africa) and a Turkish entity in liquidation, with XTB Digital Ltd of Cyprus liquidated in September 2025; share capital of 117 383 635 series A shares and 185 616 series B shares of nominal value PLN 0,05, each carrying one vote with no preference; XXZW Investment Group S.A. of Luxembourg, controlled by Jakub Zablocki, holding 51 472 869 shares or 43,78% at 1 January 2025 and 42 067 329 shares or 35,78% at 31 December 2025, which gives the company control even though it holds less than 50%; dividends of 640 753 thousand złoty paid during 2025 — FY2025 · publ. March 2026 · source ↗
  2. ReportedXTB is regulated by nine authorities across Europe, the Middle East and Latin America, and it clears its own Polish capital requirement by a margin most banks would find embarrassing: a total capital ratio of 186 per cent at the end of 2025, against a ratio of 100 per cent that would already be compliant.
    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 ↗
  3. ReportedThe rivals XTB names in its own filings are the same rivals it named five years ago.
    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 ↗
  4. ReportedIt keeps competitors out, and it also allows the party holding it to change the terms of the business without notice, which the European Securities and Markets Authority did in August 2018 and could do again.
    XTB third-quarter 2018 results as reported by Finance Magnates - total operating income was PLN 47,6 million, a 35 per cent fall from PLN 73,1 million in the same period of 2017; profit fell by 80 per cent year on year from PLN 31,3 million in 2017 to PLN 6,2 million; total revenues from CFDs were PLN 47,3 million excluding a fine, against PLN 72,5 million a year earlier; currency CFD revenue of PLN 10,4 million was PLN 18,9 million or 64 per cent lower and commodity CFD revenue of PLN 27,9 million was PLN 22,3 million or 80 per cent higher; the broker received an administrative fine from the Polish Financial Supervision Authority of PLN 9,9 million, taking the quarter to a consolidated net loss of PLN 2,9 million; the European Securities and Markets Authority's rules effective from 1 August 2018 reduced leverage for retail customers to 30:1 or lower depending on the underlying asset — Q3 2018 · publ. 2018 · source ↗
  5. ReportedAt 186 per cent, the capital ratio says the licence is not currently constraining anything XTB wants to do.
    XTB Group Management Board report on activities in 2025, synthetic summary of data for 2019-2025 (values for 2025, 2024, 2023, 2022, 2021, 2020 and 2019 in that order): market value of the Company's shares at period end 71,8, 70,4, 37,8, 31,0, 16,8, 17,9 and 4,0 złoty; earnings per share 5,5, 7,3, 6,7, 6,5, 2,0, 3,4 and 0,5; equity 2 000,5, 2 003,6, 1 734,7, 1 506,1, 915,6, 888,3 and 490,7 million złoty; group total capital ratio 186,0, 192,3, 188,7, 218,1, 200,1, 200,1 and 165,8 per cent; EBITDA 857,8, 1 006,6, 941,4, 897,7, 285,7, 523,5 and 72,2 million złoty; EBITDA margin 40,0, 53,7, 58,2, 62,2, 45,7, 65,6 and 30,2 per cent; net profit margin 30,0, 45,7, 48,9, 53,0, 38,0, 50,4 and 24,1 per cent; return on equity 32,2, 45,8, 48,8, 63,3, 26,4, 58,3 and 12,2 per cent; return on assets 8,2, 15,1, 18,0, 21,1, 8,8, 23,5 and 5,5 per cent; new clients 864,3, 498,4, 312,0, 196,9, 189,2, 112,0 and 36,6 thousand; total clients 2 164,9, 1 361,6, 897,6, 614,9, 429,2, 255,8 and 149,3 thousand; active clients 1 189,4, 701,1, 418,4, 270,6, 193,2, 108,3 and 49,6 thousand; net deposits 14 672,3, 8 607,3, 3 793,7, 3 423,2, 2 933,4, 1 961,2 and 409,4 million złoty; average operating revenue per active client 1,8, 2,7, 3,9, 5,4, 3,2, 7,4 and 5,1 thousand złoty; average client acquisition cost 0,7, 0,7, 0,8, 1,1, 0,6, 0,8 and 1,0 thousand złoty; turnover in CFD derivative instruments 8 866,4, 6 274,2, 6 779,8, 6 592,9, 4 045,9, 3 113,4 and 1 638,6 thousand lots; profitability per lot 215, 275, 227, 212, 144, 249 and 140 złoty; stock and ETF volume in nominal value 21 812,5, 9 574,1, 4 512,7, 3 336,3, 4 437,3, 1 643,3 and 178,8 million dollars; turnover in CFD derivatives in notional value 4 805,7, 2 626,6, 2 285,9, 2 259,6, 1 737,4, 1 021,8 and 541,5 million dollars; standalone operating income 1 908,4 and net profit 638,9 million złoty; balance sheet total 9 086,7 million złoty — FY2019-FY2025 · publ. March 2026 · source ↗
Sources
Generated September 24, 2026