TWINO Review 2026: A Real Licence, One Borrower

What is TWINO?

TWINO is an investment platform based in Riga and operating since 2015. Investors contract with AS TWINO Investments, a Latvian investment firm. The lending group behind TWINO started in 2009 and has originated over €1.2 billion of loans since, per TWINO’s statistics page. At the end of 2025 TWINO held €34.4 million of securities for its investors and counted 21,037 registered users.

Loans in Russia, Vietnam and the Philippines were once part of TWINO’s offer, and all three books are closed. What remains in 2026 is one market and one borrower, and in my assessment that concentration is the most important fact about the platform.

How does TWINO work?

TWINO sells asset-backed securities, which it calls Loan Securities, issued by SIA TWINO Investments Poland. The issuer is a Latvian company of the TWINO group set up with €2,800 of equity. The issuer uses your money to buy claims on a business loan that a second group company, SIA TWINO Finance, made to Fincard Sp. z o.o., the Polish company behind the NetCredit credit cards, per the base prospectus. You don’t own consumer loans. You own a security whose payments come from a loan to one company, which Fincard repays on its own schedule whatever its card customers do.

Fincard’s repayments go to the issuer, which transfers them to TWINO to credit your account. The issuer pays you only once Fincard’s money has arrived.

No buyback obligation or guarantee stands behind the securities, so your money rests on Fincard paying.

The platform earns almost all of its income as a fixed monthly fee from Fincard, not from fees you pay.

What you can invest in

TWINO offers three kinds of investment in October 2026, with minimums of €1 for Loan Securities and €10 for FLEXI.

All three are issued by companies in TWINO’s owner’s group, and TWINO, not a custodian, keeps the record of who holds them. The real-estate shares are held in TWINO’s own name for you. FLEXI isn’t a savings account. Its securities depend on Fincard like the Loan Securities do, and getting your money out of FLEXI relies on another investor or TWINO buying them.

What return can you expect on TWINO?

TWINO’s homepage advertises a fixed return of 6% to 12% a year, and the median TWINO investor on P2P Dash has earned 11.6% a year including cashback, across 180 portfolios, as of November 2026. The 6% is FLEXI’s rate and the 12% the top rate on Loan Securities. TWINO’s rates hold: its investors’ median sits within half a point of the 12% on Loan Securities.

TWINO publishes no average return of its own, and 12% was the rate on almost all the new Loan Securities at my check in August 2026. Two things come off that rate:

• the tax Latvia withholds from every interest payment, which takes a 12% rate to about 9% at the 25.5% TWINO’s prospectus applies until a tax residence certificate is on file, and to about 11% at a treaty rate of 5% or 10%.
• cash waiting for new securities, which earns nothing. At my check the primary market held four series with €377,349 left to buy, three at 12% and one at 10%, so a larger deposit can wait uninvested, and six months without a purchase starts the inactivity fee.

TWINO has the sixth-highest Returns score of the 21 platforms I’ve reviewed, 4.3 out of 5. The score rests on what investors kept last year and this year, not on advertised rates and not on the risk of losing money, which Is TWINO safe? covers.

Is TWINO safe?

TWINO protects your money against its own failure but not against Fincard’s, and every security TWINO issues today is repaid from Fincard’s loan. No buyback obligation or guarantee stands behind the securities. As a licensed investment firm supervised by Latvijas Banka, TWINO keeps your securities and cash apart from its own assets, with up to €20,000 from the investor compensation scheme. TWINO publishes no default rate or loss figure for the securities it issues today, as of October 2026. The risk in the assets you hold remains fully yours.

TWINO is tied for the 10th-highest Safety score of the 21 platforms I’ve reviewed, 2.4 out of 5. The score rests mostly on how TWINO is built, with a licence, segregated client money, approved prospectuses and audited accounts for TWINO and Fincard, held down by one borrower behind every security, which Poland’s consumer authority has charged and which lends more than a quarter of its loan assets to its own group. It rests partly on a record in which TWINO’s frozen Russian book and its Philippine book were repaid and its Vietnamese securities lost money.

Is TWINO regulated?

Yes, TWINO is regulated as an investment firm in Latvia. AS TWINO Investments has held a Latvian investment brokerage licence since August 2021, granted by the Financial and Capital Market Commission, and Latvijas Banka has supervised it since 2023, when the central bank took over the commission. Latvijas Banka approved both current base prospectuses for TWINO’s securities, the Loan Securities one on 29 May 2026. The central bank inspected TWINO’s IT and security in the first half of 2025, per TWINO’s annual report. EU rules require TWINO’s auditor to report each year to Latvijas Banka on how TWINO safeguards your securities and cash, and TWINO doesn’t publish that report. Latvijas Banka also authorised TWINO as a crypto-asset service provider in June 2026, though TWINO’s public site offered no crypto product on 30 October 2026. TWINO is one of 5 of the 21 platforms I’ve reviewed licensed under MiFID II, the EU’s rules for investment firms, as of September 2026.

TWINO isn’t a bank, so money on TWINO has no deposit insurance, FLEXI included. The client agreement says the cash in your account “is not a deposit” and is protected under investor-protection law instead.

What happens if TWINO fails?

Your securities and uninvested cash on TWINO stay yours if TWINO itself fails, because TWINO keeps them apart from its own assets, and the national investor compensation scheme pays up to €20,000 of what TWINO can’t return. The scheme doesn’t cover a loss on the securities themselves. Under its client agreement, an insolvent TWINO would stop trading, pay out your cash balance as the law requires and email you about your securities. The only register of who holds each security is kept by TWINO, which also passes on every payment from the issuer, and none of the prospectuses names anyone to take over either role. A TWINO failure would leave your claim intact and your payments waiting for whoever takes over that register.

What you own on TWINO is a security from SIA TWINO Investments Poland, not the loan behind it. The issuer pays you only what it receives from Fincard, any shortfall beyond that is “extinguished”, the issuer doesn’t have to pursue Fincard unless securityholders first cover the costs, and no Latvian securitisation law stands behind the arrangement, per the base prospectus.

The base prospectus says two things about where your claim ranks. Its risk factors say the agreement behind the securities makes all claims arising from them “subordinated to other claims of the Issuer”, and its terms say they rank “pari passu” with the issuer’s unsubordinated obligations.

Your uninvested cash sits in client accounts at Citadele and BluOr, two Latvian banks, and earns no interest. Under the client agreement, TWINO’s liability to you is capped at your cash balance at the moment of any damage.

In 2025 TWINO made a profit of €92,309 on revenue of €2.56 million, down 14% from 2024, and its capital stood at 206% of the regulatory requirement at the end of the year, per its annual report.

Loan originators

TWINO lists one current loan originator, Fincard Sp. z o.o., the company behind the NetCredit credit cards in Poland, on its loan originators page in November 2026. Fincard funds at least 5% of its card book with its own money, because the loan from TWINO’s group may never exceed 95% of it, per the prospectus.

The prospectus says Fincard pledges its card loans to SIA TWINO Finance, the group company that lent to it, and that no pledge or guarantee is available to you, while the final terms of a series issued in August 2026 state “Collateral: No”.

FLEXI’s own page says its securities are “backed by a diversified portfolio of consumer loans originated by Netcredit in Poland”, while the FLEXI prospectus says a securityholder must “rely solely and exclusively upon the covenant to pay under the Assignment Agreement and the credit and financial standing of the Loan Originator”.

Fincard is profitable. Its audited 2025 accounts show PLN 228.3 million of revenue, PLN 43.7 million of net profit and PLN 115.6 million of equity, and its card book has more than tripled since the end of 2022. Its cards cost borrowers about 40% a year, and Fincard sells debts that reach 45 days late instead of collecting them in court. Its accounts book PLN 74.8 million of losses on selling loans in 2025, about a third of its revenue, and its pricing still left it a profit.

In June 2026 Poland’s consumer authority UOKiK charged Fincard with getting round the legal cap on consumer-credit interest, alleging that commissions calculated on the used credit limit worked as interest. A fine can reach 10% of turnover. Fincard disputes the charges, and its auditor qualified the 2025 accounts because Fincard booked no provision for the case. UOKiK’s announcements showed no decision by 30 October 2026, and the prospectus TWINO published in May 2026, almost a year after UOKiK opened the case, doesn’t name it.

Fincard has held a national payment institution licence from Poland’s financial supervisor, KNF, since November 2024. Poland has yet to pass the law implementing the EU’s new consumer-credit rules, with no bill in parliament on 30 October 2026, and the prospectus rates those rules a high risk to Fincard because they can cap the price of credit.

Fincard had lent PLN 68.1 million, more than a quarter of its loan assets, to three related companies at the end of 2025, PLN 47.6 million of it to its own parent, SIA FINNO Holding, per the same accounts. Investor money enters the group as a loan to Fincard, and Fincard lends to its own parent from the same balance sheet. FINNO Holding, which like TWINO answers to TWINO’s founder, has filed group accounts for 2022–2025 in the Latvian business register, while TWINO’s financials page shows group accounts only up to 2021.

Defaults and recovery

TWINO publishes no default, recovery or loss figure for the securities it issues today, as of October 2026. Its in-app statistics chart sorted the money outstanding into “Current” and “Pending_payment” only, with no category for default, when I looked at it on 27 August 2026.

When sanctions and Russia’s capital controls held up TWINO’s Russian book in 2022, TWINO kept passing on what Russia’s monthly transfer limit allowed, added buyback offers in the recovery’s last year, and recovered the last of it by 5 August 2026, four and a half years on. The Philippine book was repaid in full with all interest in January 2026.

TWINO’s Vietnamese book ended in a loss. In March 2026 TWINO told an investor that the most recent distribution was “the final payment that could reasonably be expected” and that “no further distributions are currently anticipated”. On 27 August 2026 TWINO’s secondary market still warned that investing there in Vamo.vn, the Vietnamese loan brand, “carries a significant risk of loss”, because its lending companies “have suspended their lending operations”.

Conflicts of interest

TWINO has five conflicts of interest with its investors, set out in its client agreement, its cost disclosure, its prospectuses and its ownership.

• TWINO can change its terms by publishing them. Changes take effect once published, after notice TWINO promises 10 days ahead, and continued use counts as acceptance. You can leave only by closing your account, which requires you to hold no securities. The terms in force since 9 July 2026 narrowed the inactivity fee’s exemption, so the fee now pauses only while your account is suspended for something you failed to provide, or once it’s closed.
• TWINO is paid by Fincard, the company your money is lent to. Fincard pays TWINO €15,000 to sign and a fixed €210,000 a month “regardless of the volume of the financed credit portfolio”, and 98.9% of TWINO’s 2025 commission income came from companies under common control with it, per its annual report. The platform’s income depends on keeping Fincard as its client, not on what you earn.
• TWINO’s costs are paid before you if your securities have to be enforced. The prospectus lets TWINO refuse to act against Fincard unless securityholders cover its costs first, and puts its costs and expenses ahead of your claims.
• TWINO’s consent is all the issuer needs to change the agreement behind your securities. The issuer can amend or waive the assignment agreement with TWINO’s consent, without asking securityholders, and that agreement isn’t published.
• One person owns TWINO, the companies that issue your securities and Fincard. Armands Broks owns TWINO outright and is the ultimate owner of the issuer, SIA TWINO Finance and Fincard, and the prospectus says conflicts between TWINO’s roles “cannot be excluded”.

How do you use TWINO?

You use TWINO in six steps, from signing up to choosing how your money is invested.

1. Sign up with your email address and a password, and confirm your email address.
2. Fill in TWINO’s KYC form with your personal and financial details.
3. Verify your identity with Onfido, from photos of your passport or ID card and a selfie.
4. Take the Suitability and Appropriateness assessment, which you must complete before you can use Auto-Invest or FLEXI.
5. Add money in euros by bank transfer or Pay by Bank from an EU or EEA account in your own name.
6. Choose how your money is invested, by hand on the primary or secondary market, with an Auto-Invest portfolio or in FLEXI.

TWINO is tied for the second-lowest Usability score of the 21 platforms I’ve reviewed, 3.0 out of 5. The score rests on TWINO’s Auto-Invest portfolios and FLEXI, which invest your money automatically, and on its apps for iOS and Android. Two things count against it: Auto-Invest has no setting to keep any one series small, and TWINO admitted, replying to an investor in 2025, that a period without its app also hurt how it communicated with investors.

Opening an account

I opened my TWINO account on 27 August 2026, starting at 20:28 and finishing TWINO’s questionnaire at 20:45, about 17 minutes in all and most of it spent on questions, and the account was approved almost immediately after.

The Suitability and Appropriateness assessment decides how much you can invest in each way TWINO offers. My answers left buying by hand without a limit but capped Auto-Invest, which TWINO runs as a portfolio management service, at €42,000. The assessment can be retaken after 14 days.

The sign-up consent linked an order-execution policy from 2024, replaced on TWINO’s legal page in April 2026, and my profile’s register of agreements listed earlier versions “published 11.11.1911”, with empty files behind them. Neither affects your money, but both are errors in the documents TWINO asks you to accept.

Deposits

Depositing on TWINO is free. Only euros are accepted, from an account in your own name at a bank in the EU or EEA. A manual transfer goes to AS TWINO Investments’ account at Citadele in Latvia with your investor number as reference, and TWINO says it’s credited within 2 business days on average. Pay by Bank sends you to your own online bank to approve the payment, and on 20 October 2026 TWINO’s deposit page named Ecommpay, a payment provider, as the company handling it.

Auto-invest

TWINO has two kinds of auto-invest, Auto-Invest portfolios and FLEXI.

I looked through the Auto-Invest form on 27 August and 20 October 2026, without funding a portfolio. It sets an interest-rate range from 1% to 16%, a term of 1 to 12 months and a country, with Poland the only country on the list, plus switches to keep investing your available cash and your repayments. FLEXI sits in a separate wallet, which I left locked behind TWINO’s “Unlock FLEXI” step. With Fincard the only loan originator on offer, no setting on TWINO spreads your money beyond one company.

Support

TWINO offers support by email at info@twino.eu, which no support contact of mine has tested. Its support team works Monday to Friday, 08:00–17:00 CET, per its contact page, which states no response time.

How fast can you get your money out of TWINO?

You can withdraw cash from TWINO for free within 2 business days, to a bank account in the EU or EEA. Invested money comes out as each Loan Security matures, 3 to 12 months after issue, or earlier when another investor buys it on the free secondary market. Fincard can extend each loan by up to nine months without asking you, and your securities’ maturity moves with it. FLEXI money comes out within 5 business days, through another investor or TWINO’s repurchase, as long as sell requests stay below 10% of the loan behind FLEXI.

TWINO is tied for the fourth-highest Liquidity score of the 21 platforms I’ve reviewed, 3.0 out of 5. The score rests on TWINO’s published terms, since my account has held no money, with free withdrawals, short terms, a free secondary market and FLEXI’s repurchase weighed against a market in which every series depends on the same company, a 29.9% floor on discounts and Fincard’s right to extend its loans.

Withdrawals

TWINO withdrawals are free to EU and EEA accounts and take up to 2 business days, per TWINO’s published terms, since my account has held no money. A withdrawal to an account outside the EU and EEA, the UK and Switzerland included, costs €35. You can have two withdrawal requests running at once, and the smallest withdrawal is a minimum TWINO shows only inside your account.

Secondary market

The TWINO secondary market is where you sell your Loan Securities to other TWINO investors before they mature, with no fee for the buyer or the seller. You set the price as a discount of up to 29.9% or a premium of up to 4.9% on face value, and a sale goes through only if another investor buys. Under its client agreement, TWINO can restrict your right to resell when it judges that TWINO or you “may suffer material losses”.

On 27 August 2026 the market held about 1,900 listings over 97 pages, and every ask on the first page was at a premium, many at the 4.9% cap.

The 29.9% floor means that in a rush for the exit a sale waits for a buyer instead of finding a lower price, and because every series depends on Fincard, a Fincard problem would bring sellers and keep buyers away at the same time.

Withdrawing from FLEXI

FLEXI lets you ask for your money back at any time. Under the FLEXI prospectus, TWINO undertakes to buy your FLEXI securities within 5 business days as long as all sell requests together stay below 10% of the loan behind them. Above that, your request is marked pending and filled “at the earliest possible moment”. Fincard backs TWINO’s undertaking with collateral of at least 10% of the loan, which Fincard must restore within 14 days of the issuer’s notice. The issuer itself owes you no early repayment. A request is usually filled by another investor first, then by TWINO with Fincard’s collateral, then by early repayment of the loan.

Above the 10% line, requests wait on other investors or on Fincard repaying its loan early, so in a rush the exit depends on the same company your FLEXI money is lent to.

Closing your account

You can close your TWINO account with 10 days’ written notice, once you hold no securities and owe TWINO nothing. You’re then told how the cash left in your account will be paid out, and TWINO may first deduct any charges you owe. The platform can itself close a profile that hasn’t bought anything for 12 months, and it needs 60 days’ notice to end the agreement without cause.

What fees does TWINO charge?

TWINO charges no fee to deposit, invest, sell on its secondary market or withdraw to an EU or EEA account. Withdrawing to an account outside the EU and EEA is the one charge you can choose, and the inactivity fee is the only TWINO fee charged for doing nothing. TWINO is one of 6 of the 21 platforms I’ve reviewed that charge an inactivity fee, as of September 2026.

If your securities ever have to be enforced against Fincard, TWINO’s costs are paid before your claims.

The inactivity fee starts in the seventh month without a purchase, at €10 a month. With no securities in your account, it runs until your cash reaches €0. With securities, it runs as long as your cash exceeds €50 or 15% of your securities’ value, whichever is greater, so an investor who holds to maturity and leaves the interest uninvested pays it too. One purchase every six months keeps the fee from starting.

Pros and cons

Who should use TWINO?

TWINO suits investors who want short-term fixed-rate securities from a licensed firm and size them as one company’s credit risk.

TWINO suits:

• Investors who want a licensed firm that keeps their securities and cash apart from its own assets
• Investors who keep it to a small position they can afford to lose, sized as a loan to one company
• Investors who want short terms and a fee-free secondary market to sell on before maturity
• Investors who read audited accounts and want to follow the one company behind their securities

Avoid TWINO if you are:

• Looking for protection against the borrower failing, because no buyback obligation or guarantee stands behind TWINO’s securities
• Expecting your money spread across many borrowers, because every security TWINO issues today is repaid from one company’s loan
• Treating FLEXI as a savings account, because its 5-day repurchase holds only while sell requests stay under 10% of the loan behind it
• Uneasy lending to a company under regulator charges, because Poland’s consumer regulator has charged Fincard over its card commissions
• Wanting the money you lend to stay with the company you lend it to, because Fincard lends more than a quarter of its loan assets to its own group