How long does SPI registration take?

Typically 3-6 months, depending on the business model and ownership structure.

Is there a minimum capital requirement?

Minimum capital: 5,000 PLN (approximately 1,200 EUR).

Are open-banking services allowed for an SPI?

No, SPI cannot offer Payment Initiation Services (PIS) or Account Information Services (AIS); those are reserved for fully authorised institutions.

Does an SPI license allow international operations?

No, an SPI license is domestic only and does not allow passporting or provision of services outside Poland.

What happens if an SPI exceeds transaction limits?

If limits are breached and cannot be reduced, the SPI must either scale back its activity or transition to a fully authorized payment institution license.

Can an SPI maintain accounts at banks?

Yes, an SPI must open a payment account with a bank to hold funds and roll out payment services.

Is AML compliance required for an SPI?

Yes, SPIs must comply with AML, sanctions screening, and other regulatory reporting obligations applicable to all payment service providers.

SPI (MIP) License - Poland

Fast-track Polish payment institution regime for PSPs that need regulated status to launch payment flows (transfers, cards, acquiring, remittance) without going straight into full EMI

From scratch

From EUR 11,900

Timeline

From 3 months

Ready made

From EUR 48,000

On this page

Quick facts

Regulator / authority

Polish Financial Supervision Authority / Financial Supervision Commission (KNF)

Coverage

Accepting cash deposits and making cash withdrawals from the payment account, execution of a direct debit service, including one-off direct debits, payment by card, transfer order, payment credit, credit card payment, payment card issuance, acquiring, money transfer

Best for

Fintech launching regulated payment flows in Poland before scaling to EU API or EMI

Local presence

Required (Polish entity)

Substance level

Medium (the company should have a local address, the director can be a foreigner or local with the necessary qualifications, and a qualified compliance officer should be hired)

Banking friendliness

Medium

Who this is for

Best fit

Launching a payment or money transfer product in the EU
Testing a PSP model before full EMI licensing
Operating with limited transaction volumes within Poland
Building a fintech MVP with real users

Looking for regulated status without €350k+ capital
Ready to implement AML/KYC and reporting
Planning future upgrade to EMI

What you can do (scope)

Accepting cash deposits and making cash withdrawals from the payment account
Execution of a direct debit service, including one-off direct debits
Payment by card
Transfer order
Payment credit - credit card payment
Payment card issuance
Acquiring
Money transfer

Requirements overview

Company & presence

The legal entity should be registered in Poland with a local Polish address. Only a qualified Polish director allows opening bank accounts in high-street Polish banks.

Key persons / governance

At least 1 shareholder (2 recommended), a management board (can be 1 director), and an appointed compliance officer.

Capital / safeguarding / bonds

Minimum capital of 5,000 PLN (approx. 1,200 EUR).

AML/CTF baseline expectations

Requires a financial plan, business plan, incident procedure, AML Procedure, overall risk assessment sheet, and organizational solutions for calculating total monthly payment transactions.

Reporting / audits

Regular transaction reporting to KNF (quarterly and annually) on payment services value/volume. Annual updates on operational risk management and internal controls. Submission of financial information (including annual financial statements). AML/CTF reporting obligations. Information on payment accounts maintained at the National Bank of Poland. Reports on suprathreshold transactions to the GIIF.

Process (end-to-end steps)

Step 1: Eligibility & scope mapping

Confirm services fit SPI limits and business model.

Step 2: Entity setup / structuring (if needed)

Incorporation or adaptation of an existing Polish company.

Step 3: Documentation pack

Preparation of a financial plan, business plan, incident procedure, AML procedure, overall risk assessment sheet, organizational solutions to calculate the total monthly amount of payment transactions, etc.

Step 4: Submission to KNF

Formal filing and registration process with KNF.

Step 5: Follow-ups & clarifications

Iterations with KNF for clarification of business and compliance matters of the application.

Step 6: Go-live readiness (basic)

Obtaining an MIP license, onboarding with banks in Poland with a personal visit of the director to finalize the opening of a bank account.