XTB Weighs Internalising Stock Orders — What the Systematic Internaliser Shift Means for EU Traders

Filip Kaczmarzyk, XTB's board member for trading, said in an interview published on Friday that the broker is looking closely at systematic-internaliser-type solutions for executing stock and ETF orders. XTB currently sends cash-equity and ETF orders to regulated markets; Kaczmarzyk described an alternative in which a broker keeps an inventory of liquid securities and sells from that stock when clients place orders, reducing exchange, commission and other execution costs. He did not say whether XTB would register as an SI itself, connect to an external provider, or adopt a different structure, and gave no implementation timetable.

The economic logic is straightforward. XTB charges no commission on real stocks and ETFsup to EUR 100,000 (about $117,000) of monthly turnover, with a 0.2% commission and a EUR 10 minimum applying above that threshold and a 0.5% margin on relevant currency conversions. Kaczmarzyk said XTB has no plans to restore standard commissions. If you commit to giving trading away for free, you have to make it cheap to deliver — and internalising execution is one lever for doing that. The review sits inside a broader strategy: CEO Omar Arnaout said in February that roughly 95% of XTB's revenue still came from CFDs, and set a target of cutting that to around 70% within two to three years by growing equities and other products.

Under MiFID II, a systematic internaliser is an investment firm that deals on its own account on an organised, frequent, systematic and substantial basis when it executes client orders outside a regulated market, a multilateral trading facility or an organised trading facility. Crucially, the regime is not a licence to set any price. MiFIR requires SIs in shares and ETFs to publish firm quotes during normal trading hours, to apply transparent and non-discriminatory execution rules, and to comply with best-execution obligations. Internalisation is a regulated way of being the counterparty to your trade, not a loophole around the rules that protect you.

This is also not the same thing as payment for order flow, even though the two get conflated. PFOF pays a broker for routing your order to a third party that executes it; the EU has banned it, and the transitional exemption that let some jurisdictions keep using it has now expired. An SI, by contrast, executes qualifying orders against its own book under a distinct transparency and conduct framework. The distinction matters because the end of PFOF is precisely what forces low-cost brokers to find another way to fund cheap trading — and internalisation is one of the routes left open. We unpacked the ban itself in our note on the EU's payment-for-order-flow ban.

XTB would not be entering an empty field. Trade Republic changed its execution model in July 2026, shortly after Germany's exemption from the EU's PFOF ban expired: it now aggregates prices from around 30 exchanges before executing orders against its own account, while letting clients pick a specific venue — Xetra, Euronext, NYSE or Nasdaq — for a EUR 2 fee. Scalable Capital has instead used a subscription tier to fund low-cost trading. These are different answers to the same question, and they show that the plumbing behind “commission-free” is being rebuilt across the European neobroker sector, not just at one firm.

The reason to pay attention is conflict of interest. When a broker is the counterparty to your trade rather than a neutral router, price quality and the controls around it become central. That backdrop is sharper for XTB because of a separate matter: in March 2026 the Polish regulator, the KNF, fined the broker PLN 20 million (about $5.5 million) over client onboarding, target-market controls, risk information and conflicts tied to a promoted-instrument list between 2022 and 2023. The sanction had nothing to do with internalisation or the cash-equity model now under study, and XTB has requested reconsideration, calling the amount disproportionate. But it makes the governance around any move toward own-account execution — how the broker documents price quality and manages potential conflicts — the thing worth watching.

First, do not read “internalisation” as a red flag on its own. It is a long-standing, quote-bound feature of European market structure, used by banks and brokers to fill orders efficiently. For a retail investor buying a liquid European blue-chip or a mainstream ETF, an internalised fill can be perfectly competitive — sometimes better than a small exchange order once you account for fees.

Second, ask how best execution is evidenced, not just promised. The right questions for any internalising broker are: how does it show that the price you received matched or beat the prevailing market, and can you choose to route to a named venue if you prefer? Trade Republic's EUR 2 venue-selection option is a useful benchmark for what “you can still opt out” looks like in practice. A broker that publishes clear execution-quality data and gives you a routing choice is treating the conflict seriously.

Third, separate the execution question from the cost question. Commission-free is only free if the spread, the FX-conversion margin and any above-threshold fees are reasonable. XTB's 0.5% currency-conversion margin and its 0.2% commission above EUR 100,000 of monthly turnover are the numbers that actually hit a heavier trader, regardless of how orders are executed underneath.

Among the EU-authorised brokers we cover, the two below illustrate different ends of the spectrum — a proprietary-platform, commission-free equities specialist and a long-established multi-asset house — both under top-tier EU oversight.