Poland payment institution and e-money institution licence.

What you get

How the firm obtains the licence

1. Scoping and proposal. The route, a national payment institution, a national e-money institution or a small payment institution, the services the licence will state and the capital from disclosed, unborrowed sources are confirmed in writing before filing.
2. Application pack. The programme of operations and three-year financial plan, the own funds evidence, risk management and internal control, close links and the managers’ and major shareholders’ documents in searchable form for filing by e-Delivery.
3. Banking. The arrangements protecting user funds under article 78 and the operating and settlement accounts are arranged through the firm’s relationships before the decision, so the organisational arrangements are evidenced in the file.
4. Regulator engagement. Each KNF supplementation request is answered through one process with the evidence assembled, since every round extends the three-month period, until the decision; the licence fee follows within 14 days.

Key people, banking and technology

You will need directors with the education and experience to run a payment firm prudently, and clean criminal, regulatory and court records.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

Who needs the licence

A business providing payment services in Poland beyond the small regimes, or issuing e-money, needs a KNF licence. Poland is the largest payments market in central Europe and the KNF publishes its licence conditions, its process and its annual statistics in detail. A payment institution licence states the services covered, and adding a service requires a licence change. A business whose volumes stay below €1.5 million a month and which serves Poland only may register as a small payment institution instead.

Licence and registration types

At 31 December 2025 the KNF supervised 47 national payment institutions, 1 national e-money institution and 168 small payment institutions.

What the KNF requires

• Legal form and location. A Polish legal person with its seat in Poland; the managers must give a guarantee of prudent and stable management, evidenced by documents on education, experience and any criminal, administrative or civil proceedings; no close links with third parties, or with entities under non-EU laws, that would prevent effective supervision.
• Governance. A risk management and internal control system proportionate to the business, anti-money laundering compliance, compliance with the regulatory technical standards on strong customer authentication (Regulation (EU) 2018/389), and insurance or a guarantee for payment initiation and account information services.
• Capital. Initial capital from disclosed sources, not borrowed and not encumbered, converted at the National Bank of Poland rate on the licence date; own funds thereafter the higher of initial capital and the amount under the Minister of Finance regulation of 6 June 2018, maintained at all times.
• Safeguarding. Organisational arrangements to protect user funds under article 78 of the Act are a licence condition; a small payment institution describes its safeguarding under article 117o with the application and undertakes to notify the KNF of changes.
• Application pack. A written application signed under the company’s representation rules with documents in searchable electronic form, filed by e-Delivery, post or in person: programme of operations and three-year financial plan, evidence of own funds, description of risk management and internal control, close links, the identity of managers and major shareholders (10% or more), and the auditor. Formal gaps are cured within a period of not less than seven days or the application is left without consideration; the applicant updates the KNF on any change without being asked.

Capital

Figures in euro are converted to złoty at the National Bank of Poland rate on the licence date. The KIPE figures are the EU requirement under the Electronic Money Directive; the Polish statute applies them.

Timing

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

Small payment institution (MIP)

A natural or legal person whose monthly average of payment transactions over twelve months, including agents, stays below €1.5 million may register as a small payment institution. It provides every service except payment initiation and account information, in Poland only, including through branches and agents, with no passport. The KNF registers within three months of a complete application, the stamp duty is PLN 616, there is no initial capital stated and activity may start on the date of registration. The KNF refuses registration where the application stays incomplete after a cure request or the data is untrue, and must refuse where a court bars the applicant or it was struck off for a KNF prohibition within three years.

Passporting and scope

A national payment institution or e-money institution passports throughout the EU and EEA by branch, agent or cross-border services. The KNF forwards the notification to the host authority within one month and registers the activity after 30 days without objection; the registration fee is the equivalent of €400. A small payment institution serves Poland only. A limited network operator notifies the KNF above €1 million of transactions in twelve months.

Why applications are delayed

The KNF publishes its licence conditions and its statistics rather than a list of causes of delay. Its 2025 report shows 28 payment institution proceedings, 2 licences, 8 discontinued, 1 refused and 17 carried into 2026, and 3 e-money institution proceedings with none granted. The firm reads those figures as follows.

1. Supplementation rounds. The three-month period is extended by every request for supplementary documents, so a file that is complete on day one is the only way to hold the statutory timetable.
2. Any one condition unmet. The KNF refuses where any single licence condition is unmet: capital, own funds, governance, the management guarantee, the financial plan, close links, strong customer authentication or insurance for initiation and information services.
3. Discontinued proceedings. Eight of eleven proceedings closed in 2025 were discontinued rather than decided; the applicant’s own readiness, not the KNF, ends most applications.

A licence lapses if no payment service is started within twelve months or none is performed for six consecutive months.

Banking

A payment institution needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Poland and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

References

1. KNF: KIP licence conditions and conclusion of proceedings
2. KNF: KIP application review and the three-month period
3. KNF: KIP fees and costs
4. KNF: small payment institution registration
5. KNF activity report 2025, licensing statistics
6. Regulation of 23 April 2020 on e-money institution supervision contributions and fees

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.