EMI licence in PolandOverview
Poland implements EMD2 and PSD2 through the Act of 19 August 2011 on Payment Services, which covers payment institutions, small payment institutions, payment service offices and national electronic money institutions (krajowa instytucja pieniądza elektronicznego, or KIPE). A KIPE is authorised and supervised by the Polish Financial Supervision Authority (KNF) and may issue e-money and provide payment services, both domestically and across the EEA through passporting.
The capital and prudential framework follows the EU standard. Initial capital must be at least the Polish zloty equivalent of EUR 350,000, and the institution must maintain own funds calculated in line with the e-money rules, with additional methods applied to payment services. Client funds must be safeguarded in accordance with the Act, and the institution must have sound governance, internal control, risk management and ICT arrangements, now subject to DORA.
Authorisation proceedings before the KNF are administrative proceedings conducted in Polish, so the application, policies and supporting documents must be prepared in Polish or accompanied by sworn translations. The KNF assesses the business plan, the suitability of management board and supervisory board members, the reputation and financial standing of shareholders, and the AML/CFT framework under the Act of 1 March 2018, with the General Inspector of Financial Information (GIIF) acting as the financial intelligence unit. Applicants should expect a careful, document-driven review in which consistency between the business plan, policies and people is tested closely.
Poland also offers lighter domestic statuses for firms that do not need to issue e-money, notably the small payment institution and the payment services office, which are worth considering where the model allows. For e-money issuers, PSD3 will repeal the e-money directive and bring KIPEs within the payment institution regime, with re-authorisation of existing institutions during the transition period set by the final EU texts.
Key benefits
- Access to a large, digitally active consumer and business market
- EEA-wide passporting from a single KNF authorisation
- Competitive operating and staffing costs with strong engineering and compliance talent
- Respected supervisor, supporting relationships with banks and card schemes
- Lighter alternative statuses available for models that do not need e-money
- Strategic base for expansion into Central and Eastern Europe
Requirements
- Polish legal entity with registered office and head office in Poland
- Initial capital of at least the PLN equivalent of EUR 350,000, from documented lawful sources
- Ongoing own funds meeting the requirements of the Payment Services Act
- Management board and supervisory board members with appropriate knowledge, experience and good repute
- Shareholders with qualifying holdings who ensure sound and prudent management
- AML/CFT procedures under the Act of 1 March 2018, including risk assessment, CDD and reporting to GIIF
- Safeguarding of funds received from e-money holders
- Internal control, risk management, compliance and ICT security arrangements aligned with DORA
- Business plan with financial forecasts for at least the first three years
- Application and supporting documents in Polish or with sworn translations
Licence options & capital
National electronic money institution (KIPE)
PLN equivalent of EUR 350,000
Full e-money issuance and payment services, passportable across the EEA, authorised and supervised by the KNF.
Small payment institution or payment services office
Domestic statuses with lighter requirements for firms that execute payments without issuing e-money. Thresholds and permitted services are limited.
Passporting into Poland
EMIs licensed in another EEA state may serve Polish customers through cross-border services, agents or a branch following home-state notification.
Step-by-step process
- 1
Model review
We confirm whether a KIPE licence is required or whether a lighter status or passport fits the business.
- 2
Company and capital
The Polish company is incorporated, capital is paid in and evidenced, and board members are identified.
- 3
Polish-language file
The application, business plan, policies and personal documents are prepared in Polish, with sworn translations where needed.
- 4
KNF assessment
The KNF reviews the file, requests additional information and may meet the applicant; requests pause the statutory clock.
- 5
Decision
The KNF issues an administrative decision granting or refusing authorisation, after which the KIPE is entered in the register.
- 6
Launch and passporting
Safeguarding, reporting to the KNF and any EEA passport notifications are put in place before operations start.
Typical documents
- Application for authorisation and articles of association
- Business plan with programme of operations and financial forecasts
- Evidence of initial capital and its source
- Description of shareholders and group structure to beneficial owners
- CVs, criminal record certificates and suitability declarations for board members
- Safeguarding procedures and flow of funds description
- AML/CFT procedures and business-wide risk assessment
- Governance, internal control and risk management documentation
- ICT security, incident management and business continuity policies
- Outsourcing arrangements and agent or distributor information, where relevant
How Legal Wealth helps
Legal Wealth helps international groups approach the KNF with a file that is complete, consistent and properly localised. We advise on whether a KIPE licence or a lighter status suits the model, coordinate incorporation, capital and board appointments, prepare policies and the business plan, and manage translations and correspondence with discretion. We also support ongoing compliance and planning for PSD3. Contact info@legalwealthglobal.com to arrange a confidential discussion.
Enquire with Legal WealthFrequently asked questions
What is a KIPE?
A krajowa instytucja pieniądza elektronicznego is a Polish national electronic money institution, authorised by the KNF under the Payment Services Act to issue e-money and provide payment services.
How much capital does a KIPE need?
At least the Polish zloty equivalent of EUR 350,000 in initial capital, plus ongoing own funds calculated under the Act.
Can the application be filed in English?
KNF proceedings are conducted in Polish. Applicants should expect to file in Polish and provide sworn translations of foreign documents.
How long does authorisation take?
EU rules set a three-month period from a complete application, but information requests pause the clock, and KNF reviews of e-money applications typically take substantially longer in practice.
Is there a lighter alternative?
If the business does not need to issue e-money, a small payment institution or payment services office may be possible, though these are domestic statuses with volume and service limits.
What happens under PSD3?
KIPEs will become payment institutions authorised to issue e-money once PSD3 is transposed, and will need re-authorisation within the transition period.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
