Revolut to disclose customer data - what does it mean legally?

A landmark Irish court ruling - Revolut must disclose customer data

At the end of March 2025, the Irish High Court issued a ruling that may change how fintechs are perceived as "safe havens" for people seeking to avoid legal liability. The court ordered Revolut to disclose the personal and transaction data of 304 users and 10 resellers linked to the pirate streaming platform "IPTV is Easy".

The case concerned the illegal supply of paid TV channels at a fraction of the price of an official subscription. The copyright holders, including SKY, brought claims not only against the operators of the illegal service, but also against ordinary end users. This is the first such case in Ireland in which the subscribers of pirate services themselves have been held liable.

The ruling sends a clear signal that financial institutions operating under the fintech model are not above the law and can be required to cooperate with the justice system. For Revolut users worldwide, it means one thing - the era of apparent anonymity is coming to an end.

Does Revolut protect against bailiffs in Poland?

For years, Polish Revolut users have believed that funds held in an account with this fintech are practically out of reach of court bailiffs. This was because Revolut - as a foreign financial institution based in Lithuania and holding an Irish licence - is not connected to the Polish OGNIVO system. This system allows bailiffs to automatically search for debtors' bank accounts in domestic financial institutions.

The Ministry of Finance itself has confirmed that funds held in foreign accounts, including at Revolut, are not subject to the standard enforcement attachment mechanism. A bailiff has no technical means of automatically locating such an account. However, this does not mean that these funds are completely safe.

In practice, there are alternative legal routes that allow enforcement authorities to reach funds held in foreign fintechs. If a bailiff obtains an account number - for example from tax documentation, witness testimony or information provided by the debtor - they may attempt to attach the funds through international legal cooperation.

Mechanisms that allow a bailiff to reach funds in Revolut

• European Account Preservation Order (EAPO) - an EU legal instrument that enables funds in accounts in other Member States to be secured
• Brussels I bis Regulation - allows court judgments in civil and commercial matters to be recognised and enforced throughout the European Union
• Cooperation between tax authorities - under tax information exchange arrangements (including CRS - Common Reporting Standard), data on foreign accounts is passed to the Polish tax authorities
• Direct request to Revolut - on the basis of a final judgment of a Polish or European court, Revolut may be required to freeze or transfer funds
• Information from the debtor - a bailiff may require the debtor to submit an inventory of assets under threat of criminal liability for giving false statements

A precedent for Europe - consequences of the Irish ruling

The ruling of the Irish High Court has the potential to become a precedent for the whole of Europe. Similar legal action against users of pirate streaming services is already being taken in Italy and France. Platforms such as SKY openly announce further legal steps against recipients of illegal content.

From the perspective of Polish law, the ruling fits into a growing trend of cross-border cooperation in law enforcement. EU regulations, including the Directive on Copyright in the Digital Single Market (DSM), give copyright holders increasingly effective tools for pursuing claims. Fintechs, despite their innovative character, are subject to the same rules as traditional financial institutions.

For Polish Revolut users, the consequences may be multifaceted. First, people using illegal streaming services must reckon with the possibility of their personal data being disclosed under foreign court rulings. Second, the ruling confirms that Revolut - like any other regulated financial institution - is obliged to cooperate with the judicial authorities.

It is worth stressing that Revolut holds a banking licence issued by the European Central Bank through the Bank of Lithuania, which means it is fully subject to European regulations on anti-money laundering (AML) and reporting obligations to the relevant supervisory authorities.

What should Revolut users in Poland know?

The legal position of Revolut users in Poland requires a careful assessment. Contrary to popular belief, an account with a foreign fintech does not guarantee protection from financial or legal liability. Below we set out the key points that every user should be aware of.

First of all, Polish tax residents have an obligation to declare in their tax returns all income, regardless of the account on which it is held. Hiding funds in a Revolut account from the tax authorities may result in fiscal criminal liability. Under the automatic exchange of tax information (CRS), the Polish tax authorities receive data on the foreign accounts of Polish residents in any case.

Second, deliberately moving funds to a Revolut account in order to avoid enforcement by a bailiff may be classified as a fraudulent transaction within the meaning of the provisions on the Pauline action (Article 527 of the Civil Code). The creditor may then seek to have such a transfer declared ineffective as against them.

Third, in the context of the Irish court ruling, Revolut users should be aware that their transaction data may be disclosed under the rulings of the courts of any EU Member State. This applies not only to piracy-related cases, but potentially also to civil, criminal and tax matters.

Need legal help? Contact our law firm

The Irish court ruling clearly shows that the era of apparent anonymity in fintechs is coming to an end. If you are a Revolut user and are concerned about the legal consequences of your actions, do not wait for events to unfold. An appropriate legal strategy put in place in good time can protect you from serious financial consequences.

Our firm specialises in matters concerning bailiff enforcement, personal data protection and technology law. We help clients assess the legal risk of using foreign financial institutions and develop effective defence strategies.

Contact us today to arrange a consultation. We will analyse your legal situation and propose solutions tailored to your individual needs. Do not let a lack of legal knowledge expose you to unnecessary risk.