How to Launch an MVNO in Poland: Navigating mObywatel & PESEL Laws

Poland is increasingly attracting interest as a potential market for MVNO development, largely due to its structured regulatory framework and growing digital infrastructure. At the same time, Poland has been systematically developing its national digital identity ecosystem, including PESEL-based identification mechanisms and government-backed digital services. As a result, telecom operations are becoming more closely connected with public identity systems and national registries.

For founders and companies planning to enter the Polish telecom market, this creates a specific operational context. Infrastructure access and wholesale network cooperation are only part of the equation. Equally important is understanding how telecom services interact with public identity frameworks, regulatory reporting systems, and legally defined verification processes. Successful market entry therefore depends not only on commercial strategy, but also on the ability to design operations that align with Poland’s regulatory and digital governance environment.

What Is an MVNO?

An MVNO (Mobile Virtual Network Operator) is a mobile service provider that offers telecommunications services without owning or operating its own radio access network infrastructure. Instead of building physical networks, an MVNO delivers services using capacity leased from an existing mobile network operator or through a wholesale intermediary.

In practical terms, this means that the MVNO focuses on service design, customer experience, pricing models, distribution channels, and digital infrastructure, while the underlying connectivity is provided by an established network operator. This model allows companies to enter the telecom market without the capital-intensive requirements associated with building and maintaining physical network infrastructure.

From a regulatory perspective, MVNOs are typically classified as telecommunications service providers rather than infrastructure operators. As a result, their obligations are focused on service provision, consumer protection, data processing, identity verification, and regulatory compliance, rather than spectrum management or network deployment.

Understanding the MVNO Model in the Polish Context

As of the end of 2023, the Polish MVNO landscape comprised 139 virtual operators. Among them, 37 recorded the transfer of more than 100 numbers from other networks during 2023, while 17 surpassed the threshold of 1,000 transferred numbers.

Although the number of MVNOs has clearly grown compared to the end of the previous decade, the sector’s overall market share in Poland remains relatively limited. In contrast to several other European and global markets where MVNOs have achieved stronger commercial penetration, the Polish MVNO segment continues to represent a comparatively small portion of the telecommunications ecosystem.

In the Polish context, the MVNO model operates within the same general regulatory framework as other telecom service providers, meaning that virtual operators are subject to the same legal standards in areas such as subscriber identification, consumer rights, and data protection, even though they do not own network infrastructure.

Legal Framework: Market Entry Without a Telecom License

Poland does not require a telecom license to operate as an MVNO. Instead, telecom service providers must be registered in the Register of Telecommunications Entrepreneurs (Rejestr Przedsiębiorców Telekomunikacyjnych, RPT), which is maintained by the Office of Electronic Communications (Urząd Komunikacji Elektronicznej, UKE).

This registry-based system means that entering the telecom market is administratively simple. However, it also means that responsibility shifts from licensing to operational compliance. Once registered, an MVNO becomes fully responsible for consumer protection obligations, data processing, identity verification, SIM registration, and regulatory reporting.

In practice, Poland replaces licensing complexity with compliance complexity.

PESEL as the Foundation of Identity in Telecom

PESEL is not just an identification number, but it’s becoming the backbone of legal identity in Poland. It connects citizens and residents to public services, financial systems, healthcare, digital government platforms, and telecom services.

For MVNOs, PESEL becomes a core operational dependency. Subscriber onboarding, SIM registration, eSIM activation, and digital identity verification processes all rely on PESEL-based identification. This makes identity verification a legally regulated process rather than a business decision.

That being said, telecom onboarding in Poland is not just simply about collecting data, but also about connecting to a national identity infrastructure.

mObywatel and Digital Identity Integration

mObywatel represents Poland’s shift toward fully digital public identity. It is not merely a mobile application but a state-backed digital identity platform that integrates official documents, authentication mechanisms, and access to public services.

For MVNOs, this matters because telecom services are increasingly becoming part of the digital identity ecosystem. Identity verification is no longer limited to document scanning or manual KYC checks – it operates within a legally defined digital framework that includes mObywatel, Trusted Profile (Profil Zaufany), and national registries.

In practical terms, access to such digital identity mechanisms does not have to be built directly by the operator from scratch. Integration with state-backed identity systems can be implemented through specialized technology providers that offer compliant identity and onboarding infrastructure, such as IDENTT. This allows MVNOs to incorporate mObywatel-based verification into their onboarding flows using certified, production-ready identity solutions rather than developing custom integrations independently.

In practical terms, a SIM or eSIM registration process using mObywatel could follow a model such as:

A customer initiates SIM registration digitally through the MVNO’s onboarding interface. Instead of uploading document photos or completing manual identity forms, the user selects digital identity verification as the preferred method. The system redirects the user to a secure authentication environment linked to the state digital identity infrastructure, where identity confirmation is performed using mObywatel.

The user confirms their identity through the application using government-approved authentication mechanisms. Once verified, the system receives structured identity confirmation data, including legally required identifiers such as PESEL, without manual document processing. This data is then used to complete the SIM registration process in compliance with national telecom and identity regulations.

From the user’s perspective, the process feels similar to logging into a trusted government service. From the operator’s perspective, it functions as a legally valid identity verification mechanism embedded directly into the onboarding flow.

PESEL Reservation Law and SIM Registration

Recent legal changes introduced the possibility for citizens to reserve (block) the use of their PESEL number to prevent fraud and identity abuse. This has direct consequences for telecom operations.

SIM and eSIM activation can no longer be treated as purely commercial processes. Operators must now verify PESEL status, respect reservations, and ensure that identity verification complies with national protection mechanisms.

This creates a new operational reality: onboarding flows must be legally aware, not just conversion-optimized.

Practical MVNO Launch Architecture

Launching an MVNO in Poland typically follows a clear structural path. First comes corporate formation and legal setup, followed by registration in the telecom registry. However, digital administration increasingly relies on PESEL-based identity systems, meaning that founders and board members, especially foreign nationals, must integrate into the Polish digital identity infrastructure to operate efficiently.

Without this integration, access to reporting systems, public registries, and digital administrative tools becomes significantly more complex.

Then wholesale network access is secured through agreements with MNOs or MVNEs. At the same time, identity systems must be designed: PESEL verification logic, onboarding flows, SIM/eSIM registration, and digital compliance processes. Only after these foundations are built does commercial scaling become viable.

Existing operators demonstrate how compliance-driven onboarding has become a standard part of telecom operations in Poland. Identity verification, SIM registration, and digital onboarding are embedded into the customer experience as default processes, not exceptional cases.

Conclusion

Telecom regulation is not what makes launching an MVNO in Poland difficult. The real challenge lies in digital identity integration. The country offers one of the easiest market entry paths in Europe from a licensing perspective, but one of the most structured identity and compliance environments from a regulatory perspective.

This creates a clear strategic requirement: MVNOs must be designed not only as telecom services, but as digitally regulated identity platforms. Operators that understand this build scalable, compliant, and trusted brands. Those that underestimate it struggle with onboarding, regulatory friction, and legal risk.

In Poland, the real barrier to entry is regulatory architecture and not infrastructure nor spectrum. For modern MVNOs, that architecture starts with PESEL, mObywatel, and identity compliance, not with physical antennas and base stations.