Tech, gaming and IT: Trends in Poland M&A

Notable inbound transactions included OpenAI’s acquisition of Neptune Labs (Neptune.ai), TSS Europe’s investment in Asseco Poland (over PLN 1 billion), and CGI’s purchase of Comarch’s public administration software business in Poland.

The data suggests that the deal flow in 2025 was driven mainly by strategic capability expansion rather than opportunistic consolidation. This suggests that, despite slightly lower number of transactions as compared to 2024, Poland remains well positioned for sustained investment in 2026.

Higher complexity in TMT

While TMT transactions become more compliance-driven, with regulatory risk moving into early structuring and directly affecting valuation, the focus of these deals is also shifting.

1. AI, cyber and data governance

Frameworks such as the European Union (EU) Artificial Intelligence Act (the AI Act), the NIS2 Directive (EU 2022/2555), and Poland’s amended National Cybersecurity System Act are raising due diligence standards across the board, affecting not only large transactions but increasingly also small and mid-market deals. Buyers systematically assess not only intellectual property (IP) transfer, but also data governance, model transparency, incident response maturity, and dependency risk.

These factors in turn increasingly influence valuation adjustments, indemnity structures, and earn-out mechanics, rather than being treated as purely technical issues, potentially decreasing the value and number of future deals.

2. Rising employment exposure 

Recent changes in Polish labour law, combined with intensified scrutiny of contractor models typical for IT and gaming companies, are also increasing transaction risk in classification of business-to-business (B2B) arrangements, making employment diligence central in high-growth targets.

3. Expanded FDI scrutiny

The upcoming EU foreign direct investments (FDI) screening reform is expected to significantly broaden scrutiny of AI, software-as-a-service (SaaS), cloud, and data-driven businesses, as well as of intra-EU investments where the investor is owned or controlled by a third-country entity.

As a result, stricter FDI screening in Poland should be anticipated, alongside enhanced merger control enforcement by the Polish competition authority. This increases the importance of regulatory sequencing and pre-notification strategy, with deal certainty increasingly dependent on approval timelines.

Outlook

Current data shows that Poland continues to act as a structural hub for TMT M&A, supported by strong innovation pipelines and sustained international investor interest. However, with the evolving legal environment and new risks, dealmaking is shifting toward fewer but more complex, regulated transactions focused on scalable digital assets.

[1] M&A Index Poland Fuzje i przejęcia w 2025 roku, Navigator Capital & FORDATA, 2026 (accessed: 04.05.2026).

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Justyna Jóźwiak is a talented lawyer who is lauded for her hard work, and exceptional professionalism. Specialising in corporate law, no detail is too small for her and no project too big.