⚠ A Business Model That Has to Be DisclosedHigh threat

XTB (XTB) — threat to the moat

A mandatory warning is evidence, and it accumulates in front of the people who write the next rule.

Mandatory loss disclosure is a milder intervention than a ban, and regulators generally try the milder one first. That is the uncomfortable position of a product whose marketing must carry the proportion of customers it harms: the warning is evidence, and it accumulates.

Replacing customers rather than retaining them361,6kNew clientsH1 25703,3kNew clientsH1 26853,9kActive H1 251 489,9kActive H1 261,4k złRev peractive H1 251,4k złRev peractive H1 26703 333 clients acquired in a half-year; the active base rose by 636 000
Acquisition running at ninety-five per cent growth, revenue per client flat.

The 2018 leverage cap was the first European answer to that evidence.1 Since then several national supervisors have gone further within their own markets, restricting or prohibiting the advertising of leveraged products, tightening the appropriateness testing that determines who may open an account, and limiting the circumstances in which a retail client may opt up to professional status and thereby recover higher leverage. None of that is speculation about the future; it is the record of the past eight years.

The client-side consequence is arithmetic. If three quarters of accounts lose money, the pool of people who have tried the product and would try it again shrinks with every cohort, and the acquisition machine has to run faster simply to stand still.2 XTB acquired 864 286 new clients in 2025 and 703 333 in the first half of 2026 while average operating revenue per active client fell to 1 800 złoty and then, in the second quarter of 2026, to 700 for the quarter.3 That is what replacing customers rather than retaining them looks like in a management report.

The falsifying evidence would be retention data, which XTB does not publish. In its absence, watch new clients against active clients: 703 333 acquired in a half-year against an active base that rose by 300 000.4

References
  1. ReportedThe 2018 leverage cap was the first European answer to that evidence.
    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 ↗
  2. ReportedIf three quarters of accounts lose money, the pool of people who have tried the product and would try it again shrinks with every cohort, and the acquisition machine has to run faster simply to stand still.
    XTB mandatory risk disclosure on xtb.com - "74% of retail investor accounts lose money when trading CFDs with this provider." and "CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage." — September 2026 · publ. 2026 · source ↗
  3. Moat Explorer calcXTB acquired 864 286 new clients in 2025 and 703 333 in the first half of 2026 while average operating revenue per active client fell to 1 800 złoty and then, in the second quarter of 2026, to 700 for the quarter.
    Moat Explorer calculations from XTB's published figures. Correlations across the eight quarters from Q3 2024 to Q2 2026 between operating income (470 234, 465 416, 580 294, 580 597, 375 821, 609 344, 1 094 018 and 992 558 thousand złoty) and, first, CFD turnover in lots (1 627 978, 1 657 390, 1 907 974, 2 321 584, 2 094 296, 2 542 526, 2 323 204 and 1 831 627) giving 0,25, second, CFD notional in dollars (695 315, 727 854, 937 867, 1 144 554, 1 118 278, 1 605 005, 1 333 410 and 1 029 179 million) giving 0,37, and third, profitability per lot (272, 253, 277, 229, 152, 208, 439 and 484 złoty) giving 0,92; the ranges over those quarters are 1,56 times for lots, 2,31 times for notional, 3,18 times for profitability per lot and 2,91 times for operating income. Annually from 2019 to 2025 the correlation between CFD turnover in lots and operating income is 0,96. Market capitalisation of 16 970 million złoty is 144,34 złoty multiplied by 117 569 251 shares, which against trailing twelve-month revenue of 3 071,5 million złoty (2 146,056 less 1 160,891 plus 2 086,324) gives 5,53 times sales, and against trailing net profit of 1 261,4 million (644,199 less 410,052 plus 1 027,240) gives 13,45 times earnings and earnings per share of 10,73. Historic price-earnings ratios are year-end share price multiplied by 117,569 million shares divided by net profit: 8,15, 5,23, 8,31, 4,76, 5,62, 9,66 and 13,10 for 2019 to 2025, with price-to-sales of 1,97, 2,64, 3,16, 2,51, 2,75, 4,42 and 3,93. XTB's 2025 operating income of 2 146,056 million złoty converts to 570,9 million dollars at the National Bank of Poland's 2025 average rate of 3,7588, giving 480 dollars per active client across 1 189 397 active clients against Plus500's 3 268 dollars across 242 440, a ratio of 6,8 times, while Plus500's revenue of 792,4 million dollars is 39 per cent more than XTB's. Client instruments of 43 363 639 thousand złoty across 2 825 700 clients is 15 346 złoty each, against 12 603 at 31 December 2025 and 10 048 at 31 December 2024; 43 363 639 thousand złoty converts to 8,6 billion pounds at 5,03 złoty to the pound, or 3 051 pounds a client, against Trading 212's 25 billion pounds across 4,5 million funded accounts, or 5 556 each. Gross gain on stocks and ETPs as a share of gross gain on CFDs is 0,7 per cent for 2023 (11 050 over 1 622 633), 1,7 per cent for 2024 (30 654 over 1 837 173) and 3,8 per cent for 2025 (78 310 over 2 035 006); as a share of client instruments held, 78 310 over 27 283 557 is 29 basis points. Marketing divided by salaries is 0,44 in 2019 (37 716 over 86 024), 1,42 in 2025 (584 898 over 413 019) and 1,76 in the first half of 2026 (435 510 over 246 964). Revenue per employee is 1,54 million złoty for 2023 (1 618 385 over 1 054), 1,51 million for 2024 (1 873 436 over 1 245), 1,42 million for 2025 (2 146 056 over 1 516) and 2,70 million annualised for the first half of 2026 (4 172 648 over 1 548). Poland's share of operating income is 46,7 per cent in 2023, 52,7 in 2024, 54,4 in 2025 and 57,4 per cent in the first half of 2026 (1 197 033 over 2 086 324). Net interest income is 3,1 per cent of 2024 revenue and 3,6 per cent of 2025 revenue; the share of interest kept is 78 per cent of 140,1 million less 62,1 million, or 56 per cent. Institutional revenue is 2,0 per cent of 2025 operating income (42 524 over 2 146 056) and was 8,7 per cent in 2019 (20 847 over 239 304). Second-quarter 2026 net profit of 1 027 240 less 535 042 is 492 198 against 216 129 a year earlier, a rise of 127,7 per cent, while the sequential fall from 535 042 is 8,0 per cent. The 2018 to 2019 declines are 17,0 per cent in operating income and 43,1 per cent in net profit — FY2019-H1 2026 · publ. September 2026 · source ↗
  4. ReportedIn its absence, watch new clients against active clients: 703 333 acquired in a half-year against an active base that rose by 300 000.
    XTB results presentation for the first half of 2026, client key performance indicators - new clients 333 292 and 370 041 in the two quarters of 2026, 703 333 for the half against 361 643, up 94,5%; active clients 1 489 872 against 853 938, up 74,5%; clients in total 2 825 700 against 1 697 894, up 66,4%; net deposits 11 768 823 against 7 240 875, up 62,5%; average operating revenue per active client 1,4 in both halves and 0,7 in the second quarter against 0,9 in the first; average client acquisition cost 0,6 against 0,7; turnover of CFD instruments in lots 4 154 831 against 4 229 558, down 1,8% — H1 2026 · publ. 28 August 2026 · source ↗
Sources
Generated September 24, 2026