DecentrAtty
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
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.
What's included in our support
Core package
- Full-scope advising on registration of company and MIP application
- Set of corporate documents (articles of association, certificate of incorporation, share certificate, etc.)
- 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.
- KNF submission support
- Regulatory Q&A handling
- Polish virtual legal address for 1 year
Optional add-ons
- AML officer outsourcing
- MLRO outsourcing
- Banking EMI onboarding
- Ongoing compliance support
- Upgrade path to API or EMI
- Accounting services
Ready made
SPI (MIP) - Poland · From EUR 48,000
FAQ
What is an SPI (MIP) in Poland?+
A Small Payment Institution is a regulated entity that can provide most payment services in Poland under a lighter regulatory regime compared to a fully authorized payment institution.
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.
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