Twino Review

Last Update: June 10th, 2025

Executive Summary

TWINO is essentially a single bet on Polish regulators not closing a payment‑institution credit carve‑out which serves as a replacement for payday loans. Investors carry a large majority of the business risk, while receiving an estimated 35% of the total upside.

Key Numbers:

• 95% revenue dependence on one Polish regulatory workaround (Fincard, KIP licence #62/2024)
• Single point of failure across country, regulation, and loan originator
• €5.3M+ in confirmed investor losses from previous market exits
• Strong short-term survival (€1.48M cash, profitable 2024) that masks structural problems
• Fincard Volume: €36.1M processed through TWINO
• Profit: €362k (platform), €7.27M (loan originator)
• Average investor advertised returns: 12%

Think of it like this: It's not a diversified restaurant portfolio, it's a single food truck that depends on the city not changing parking regulations - all paid for with your money. Borrowers pay ~42% on average to take out loans, which gets divided up as follows: 8% covers TWINO’s costs, 12% is for you and the remaining 22% is for TWINO’s owner.

But here's the fundamental problem: you're shouldering 100% of the regulatory risk while capturing only 35% of the total returns.

Let’s take a closer look at how it all works.

Fincard: The Engine 

Fincard (Fincard Sp. z o.o.) is 100 % owned by FINNO Europe SIA (Latvia), the holding company behind TWINO; ultimate UBO: Armands Broks. It was founded September 12, 2019 and is regulated as a “National Payment Institution” (KIP license #62/2024).

The Good News:

• 2023 Results: €32.5M revenue, €7.27M profit (22% margin)
• ≈115 000 credit cards issued as of  Aug 2024

The Terrifying News:

• TWINO gets 95% of its revenue from this single relationship
• It's all happening in one country (Poland)
• Under one regulatory classification (credit cards)
• With one business partner (who happens to be owned by the same guy)

You might be wondering: Why credit cards? That’s because Poland banned P2P loans. TWINO pivoted to issue credit cards (via Fincard), which then loans out money collected through a P2P platform in Latvia (TWINO).

Good On Paper, Tricky In Practice

At TWINO, all the surface-level indicators look absolutely fine:

✅ Clean BDO audit

✅ Strong Fincard performance

✅ Regulatory compliance

✅ Positive 2024 results

✅ €1.48M cash reserves

✅ 196% capital adequacy ratio

These indicators reflect current operational health. But that only counts as long as the regulatory framework doesn't change.

But MiFID II's €20,000 compensation only covers platform insolvency, not regulatory changes or market exits. It didn't prevent the €5.3M+ losses in Russia/Vietnam, and it won't prevent business model collapse from regulatory changes.

So what happens when Polish regulators decide credit card workarounds are also problematic? Based on the platform's track record (spoiler alert: it's not great), investors would likely absorb losses while management keeps previously collected fees.

The Polish Workaround

Poland's so-called Anti-Usury Act went live on 1 January 2024 and basically torched the entire P2P lending landscape in the country. The law itself sounds reasonable enough on paper: Bring non-bank lenders under proper supervision, bump up their capital requirements to PLN 1 million (a five-fold increase that already had smaller players sweating bullets).

But here's where it gets spicy: buried in Article 59d is what I'd call the nuclear option. 

The Legal Kill Shot

The law says consumer loan funds "may not come from collecting other people's funds, including bond issues or other debt instruments." Translation for those of us who don't speak legalese? If you're not a bank, you can only lend your own money. No more crowdfunding loans from regular investors.

That single sentence essentially killed the entire P2P model in Poland (which was probably the point). The classic peer-to-peer setup relies on pooling small investments from lots of people - exactly what this law now prohibits. Polish loan originators scrambled to wind down their retail investor programs by 31 December 2023, and most international platforms just said "nope" and delisted Polish loans entirely.

The messaging from most platforms was refreshingly blunt. Hive5 told their investors straight up: "From 2024, the new law will prohibit Polish lenders from borrowing funds from investors through online platforms." 

Warsaw's official line? Consumer protection: Stamp out dodgy payday lenders, cap excessive fees, get the financial regulator involved in anti-money laundering oversight. Poland never explicitly banned "P2P lending" in the statute. They just made the funding mechanism that makes P2P possible illegal.

Which brings us to how TWINO decided to get creative with this regulatory landscape...

Instead of accepting defeat, they reclassified their loans as "credit card products" through their sister company within the TWINO group, Fincard Sp. z.o.o. (which operates under the NetCredit and Halvo brands).

The Genius Part: This technically sidesteps the P2P ban because credit cards fall under payment institution licensing.

The Terrifying Part: This entire business model now depends on Polish regulators continuing to buy this classification. Forever.

Fincard lends off its own balance sheet, then sells receivables to investors via TWINO. That sidesteps Art. 59d because the public never ‘deposits’ money directly with the Polish lender; instead they buy its claims from abroad. If the KNF decides those assignments are functionally the same as ‘collecting other people’s funds’, the model breaks. 

The regulatory risk is even deeper than it appears. Under EU payment regulations (PSD2), payment institutions like Fincard can only offer credit if it's genuinely a part of a payment service - think actual credit card usage - and must be repaid within 12 months.

If Polish regulators decide that what Fincard is doing looks more like traditional payday lending than legitimate credit card services, the entire workaround collapses. The business model depends on regulators continuing to accept that these are "credit cards" rather than rebranded consumer loans funded through a Latvian investment platform.

The Track Record Problem (Or: Why Past “Disappointing” Performance May Actually Does Predict Future Results)

Unfortunately, this isn't just theoretical risk. TWINO's crisis management history shows exactly how this regulatory shutdown would play out - and it's about what you'd expect from a payday loan business.

Confirmed Investor Losses: €5.3M+

Russia (The Slow-Motion Train Wreck): €4M+ frozen since the 2022 war, with pessimistic recovery prospects limited to €100,000 monthly repayments. That's what, 40 months to recover IF everything goes perfectly?

Vietnam (The Late Exit Special): €1.3M confirmed write-offs after loan originator default in 2024. The kicker? Competitors like Robocash and Aventus exited Vietnam in Q2 2023. TWINO waited until April 2024: That’s nine months of collecting fees while risks escalated.

The Management Musical Chairs

Four CEOs in five years during the most critical periods:

• Russian invasion response (delayed exit, €4M+ frozen)
• Vietnam default management (late exit, €1.3M+ losses)
• Polish regulatory workaround implementation
• Current CEO: Nauris Bloks (since April 2025)

Running a P2P platform during geopolitical crises isn't exactly a walk in the park. But there's a pattern here of prioritizing fee collection over timely risk management, and that pattern could easily repeat with Polish regulatory risk.

The "Do a PeerBerry" Question (Spoiler: They Won't)

TWINO probably could absorb these investor losses if management chose to.

The Financial Capacity Exists

Available Resources:

• Fincard Profits: €7.27M (2023) + €1.5M (Q1 2024) = €8.77M+ recent profits
• TWINO Cash Position: €1.48M (tripled in 2024)
• Total Estimated Capacity: €10M+

Loss Coverage Analysis:

• Russia Losses: €4M+ → Coverable from Fincard profits alone
• Vietnam Losses: €1.3M → Easily coverable
• Total Confirmed Losses: €5.3M → Well within financial capacity

The PeerBerry Precedent

PeerBerry "repaid all war-affected loans on 16 December 2024 with no capital loss to investors" during the Ukraine conflict. So the capacity exists, the precedent exists, but TWINO opted not to do so..

Why They Won't (Despite Being Able To)

The Structural Excuse: PeerBerry operated integrated loan origination, while TWINO operates "separate" platform/originator entities (even though they're owned by the same person). The established pattern suggests they would choose not to absorb future regulatory-related losses, especially when they can point to "external regulatory changes" as justification.

More importantly, TWINO operates fundamentally as a payday lending business. As someone in that industry once told me, "the money is good, but you absolutely need a heart of stone." There's no room for mercy or courtesy in this sector, and investors should set their expectations accordingly. In practical terms, this means when a crisis hits, management will prioritize preserving their own fee income over protecting investor capital - exactly as we've seen with the Russia and Vietnam situations.

And let’s be honest: if you're investing in payday loan companies expecting returns, you're actively participating in this exploitative system. While such investments may be legal, they should be conscious choices made with full awareness of their human cost. As an investor, you can't reasonably expect the leniency and understanding that you deny to borrowers trapped in cycles of debt.

Market Conditions 

As with any lending business, TWINO is susceptible to changes in market conditions. Economic downturns can occur suddenly and render entire loan portfolios worthless. In such scenarios, investors bear the losses while the platform retains the fees it has already collected.

This may be the single most existential risk for TWINO. Yet, it's also the most straightforward one. You lend money at high rates, you risk non-repayment. The usual lending fundamentals apply. No need to elaborate further.

If you've invested long enough, you've seen all the opportunities that seemed like sure bets .. until a pandemic, a war, or a lunatic president happened. We may not know what will happen, but we can be pretty sure that things will happen that we never would have considered possible. The question is only whether they'll happen to us.

Polish Insolvency Laws

There's also the matter of Poland's evolving personal bankruptcy laws, which represents an additional systemic risk beyond the primary regulatory threat. Given the Polish government's increasingly consumer-friendly stance, there's a real possibility they could make debt relief even more accessible in the future. This would directly impact loan recovery rates for predatory lenders like TWINO, potentially reducing the very cash flows that investors depend on.

The Most Likely Scenario: Regulatory Shutdown (And Why It Won't Be Catastrophic, Just Expensive)

Phase 1: The Announcement (Day 0) Polish regulators announce that credit card lending through investment platforms will be reclassified or restricted, effective in 3-6 months (they'll probably give some transition time, unlike an invasion). TWINO immediately suspends new investments and issues a statement about "regulatory changes requiring operational adjustments."

Phase 2: The Scramble (Days 1-90) Management frantically searches for replacement loan originators in other countries while calculating how long their cash reserves will last without the €3M+ annual Polish revenue stream. They'll probably announce they're "exploring exciting new market opportunities" (translation: we're desperately trying not to go out of business).

Phase 3: The Wind-Down Announcement (Month 3-4) TWINO announces a "managed transition" of Polish operations. No new loans, existing loans will be repaid according to normal schedules. They'll spin this as "focusing on higher-growth markets" rather than admitting their business model just evaporated.

Phase 4: The Slow Repayment Period (Months 6-24) Fincard continues collecting on existing loans and passes repayments through to TWINO investors. This is boring, predictable, and mostly successful, just slow. Think mortgage payments, not dramatic asset seizures.

Phase 5: Here Things Can Go Different Ways:

1. The Successful Pivot: TWINO actually finds replacement loan originators and rebuilds their business. Investors get their money back and the platform survives with new focus markets.
2. The Managed Shutdown: TWINO can't replace the lost revenue stream. They announce platform closure once Polish loans are mostly repaid. Investors get 90-95% of principal back, platform shuts down "on a high note."
3. The Emergency Exit: Cash flow problems or regulatory requirements force TWINO to accelerate the wind-down by selling loan portfolios at discount. Investors get 80-90% of principal back, but faster than planned.

The Timeline Reality Check

Unlike Russia/Vietnam:

• No dramatic overnight freezing
• No "will I ever see my money again?" anxiety
• Just a slow, boring repayment process over 12-24 months

The Actual Investor Experience:

• Month 1-3: Uncertainty and platform communications
• Month 4-12: Regular monthly repayments, diminishing balances
• Month 12-24: Final repayments, platform probably announces closure
• Month 24+: You're out, with 85-95% of your money back

Why This Is Still Bad (Just Not Catastrophic)

The Real Losses:

• Opportunity cost: Money tied up for 12-24 months potentially earning nothing
• Platform fees: You paid fees during good times, get no compensation during wind-down
• Modest principal haircut: 5-15% loss from accelerated wind-down

Is It Worth It?

The moral dimension is a personal decision. If you're uncomfortable with payday lending, you already have your answer. But if you can accept that aspect, the question remains whether it's financially worthwhile.

Setting aside the moral dimension, let's examine pure financial mathematics. Looking at our live loan tracker, TWINO has consistently offered 12% returns with no variation. So the question becomes: is that rate attractive enough?

There are two ways to evaluate this. First, you can compare alternatives—examining what they pay and assessing their risk levels. The challenge here is that pinpointing exact risks is extremely difficult, particularly when comparing two different investment products.

The second approach is to analyze how risk and rewards are distributed within the specific venture where you're investing your money.

Here's what the 2024 audited statements reveal: TWINO covers its platform costs the moment it transfers funds to its Polish subsidiary, Fincard, collecting an average loan origination fee of 8.3%. 

Fincard performs quite well; its financial statements show that it covers that 8.3% fee, pays investors their 12% return, and still generates a 22% profit margin. Meanwhile, TWINO has been operating around break-even, so we can reasonably assume the 8.3% represents the actual platform operating costs.

This leaves Fincard's 22% profit versus investors' 12% return (before accounting for defaults). In other words, investors receive only one-third of the total returns while shouldering essentially all the risk. Oof.

The Promotional Pricing Exception

TWINO periodically offers bonus campaigns (such as the 2% cashback for 90 days promotion running through June 2025) that can push effective returns to 14-16% for new investors. At those enhanced rates, the risk-reward equation shifts meaningfully: You'd be capturing closer to 50% of total returns rather than the standard 35%.

This doesn't eliminate the structural risks, but it does make the compensation more proportional to what you're shouldering. For informed investors comfortable with the regulatory concentration risk, these promotional periods represent the only time TWINO's terms approach fair value.

The Final Word

Promotional pricing aside, the fundamental investment thesis remains problematic. TWINO is a legitimate, regulated platform with real operations that has genuine loan origination through Fincard with actual borrowers. The platform publishes clean audited financials and maintains regulatory compliance. They do pay out returns when things work normally and MiFID II regulation provides some investor protection.

However, despite these operational strengths, TWINO presents a classic risk-reward mismatch with 95% revenue concentration in a single regulatory workaround. The 12% advertised returns come with:

• Single-country, single-regulation, single-partner concentration risk
• €5.3M+ in demonstrated investor losses during past crises
• Risk-reward imbalance: You take 100% of regulatory risk but capture only 35% of total returns (12% vs Fincard's 22% profit margin)
• Management that consistently prioritizes fee collection over timely risk management

The numbers simply don't justify this risk structure. Management has €10M+ capacity to cover confirmed losses but chooses not to: That's your data point on how they'll handle the next failure.

The most likely outcome isn't catastrophic loss, but a slow 12-24 month wind-down if Polish regulators change their stance, with investors recovering 85-95% of principal. That's not terrible, but it's not the 12% return you signed up for either.

Current financials look solid because they measure operational health, not structural vulnerability. The platform runs fine until external dependencies change, which I can definitely see happening, given Poland's clear policy direction against predatory lending.

The question isn't whether TWINO is good or bad. It's whether you're comfortable with binary outcomes based on regulatory timing. If you need regulatory arbitrage exposure in Polish payday lending, TWINO executes competently. But if you want diversified P2P returns and fair compensation for the risk you’re taking, the current 12% offer (outside of promotional periods) doesn't support that thesis.

Sources and Further Reading

1. TWINO Group Audited Financial Statements 2024 - BDO Latvia
2. Fincard Sp. z o.o. Financial Reports 2023-2024 - Polish Company Registry
3. Polish Payment Institution License Database - KNF (Polish Financial Supervision Authority)
4. European P2P Platform Regulatory Changes - Various EU regulatory announcements
5. Historical Loss Data - Platform announcements and investor communications
6. MiFID II Compensation Scheme Details - EU regulatory framework documentation