Electronic Money Institution (EMI) license in Poland

Poland is an attractive gateway for fintech companies seeking an EMI license and access to the EU market. The KNF provides clear procedures, strong customer protection, and predictable supervision. We support your project at every stage: from incorporation and documentation to safeguarding setup and regulator communications. Our goal is to accelerate authorisation and launch operations safely in Poland and across the EU.

• Poland grants access to the European payments market.
• Two regimes are available: EMI and Small Payment Institution.
• We conduct assessment, prepare documents, and file the application.
• The cost of licensing depends on capital and chosen services.
• KNF supervision enhances trust from clients and partners.

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Regulations for EMI license in Poland

Electronic Money Institutions in Poland are regulated under the Polish Payment Services Act (Ustawa o usługach płatniczych) and supervised by the Polish Financial Supervision Authority (KNF). The regulator oversees the entire process, from license application to ongoing supervision of authorised firms. Key requirements include minimum initial capital, own funds obligations, safeguarding of client money, and strict AML/CTF compliance.

• EMI activities are regulated by the Polish Payment Services Act.
• The minimum capital for a full EMI license is €350,000.
• Own funds must be maintained in proportion to transaction volume.
• KNF provides ongoing supervision and compliance monitoring.
• AML/CTF procedures and safeguarding of client funds are mandatory.

Types of EMI licenses in Poland

In Poland, the KNF distinguishes between two levels of licensing, allowing companies to choose the model best suited to their business scale. The full EMI license is designed for established players with EU-wide ambitions, while the Small Payment Institution (MIP) regime is tailored to startups and firms with limited operations. This structure makes the Polish market accessible for businesses of different sizes.

Full EMI license

The full EMI license authorises unlimited issuance of electronic money and access to a broad range of payment services. It grants the right to operate across the European Union under the passporting regime. The KNF enforces strict requirements on capital, governance, and safeguarding, ensuring high credibility of licensed entities.

• Minimum initial capital requirement is €350,000.
• The license allows unlimited issuance of e-money.
• Payment services may be offered throughout the EU.
• Strict compliance with AML/CTF and safeguarding is mandatory.
• Firms must maintain a sound business model and internal controls.

Small Payment Institution (MIP)

The MIP license is intended for companies starting operations with limited transaction volumes. It provides a faster and more cost-efficient entry into the market but imposes limits on monthly transactions and does not grant passporting rights. This makes it a suitable option for startups testing their products or models locally before scaling up.

• No minimum share capital is required for MIP.
• The license is valid only within Poland.
• Monthly transaction volume is subject to regulatory limits.
• Exceeding thresholds requires upgrading to a full EMI license.
• AML/CTF compliance and internal control measures remain mandatory.

Services you can provide with an EMI license

An EMI license in Poland enables companies to provide a broad range of financial services related to electronic money and payment operations. This status strengthens trust from clients and banking partners and grants access to the EU market.

• The company may issue electronic money and manage e-wallets.
• It is authorised to carry out domestic and international transfers.
• The firm may issue and service payment cards.
• The company may provide payment services for online shops and digital platforms.
• Client funds must be safeguarded in compliance with regulations.
• The company may offer additional payment instruments, including direct debits and credit transfers.

Requirements to obtain an EMI license in Poland

To obtain an EMI license in Poland, a company must comply with a set of requirements established by the KNF (Polish Financial Supervision Authority). These include capital thresholds, safeguarding obligations, governance standards, and maintaining a local presence.

Capital and own funds

The minimum initial capital requirement for a full EMI license is €350,000. In addition, the firm must maintain sufficient own funds to cover outstanding e-money liabilities and related risks. The capital level depends on the business model and scale of operations.

Safeguarding of client funds

All customer funds must be safeguarded in segregated bank accounts or protected by insurance or a bank guarantee. KNF requires regular reporting and transparent procedures to ensure that safeguarding arrangements are functioning properly. This guarantees that client funds remain protected in case of financial difficulties.

Governance and management

Directors and key personnel must meet the «fit and proper» criteria. This includes a clean regulatory and criminal record, proven expertise in the financial sector, and the ability to effectively manage the institution. KNF reviews professional backgrounds and checks for prior misconduct.

Business plan and internal procedures

The application must include a detailed three-year business plan with strategy, financial forecasts, and operational model. Internal policies must also cover AML/CTF compliance, risk management, IT infrastructure, and business continuity planning. Well-prepared documentation speeds up the authorisation process.

Legal form and local presence

The company must be incorporated in Poland as a legal entity and maintain a registered office in the country. This ensures effective regulatory supervision by KNF and compliance with local presence requirements. Corporate documents must align with Polish law, and shareholder structures must be transparent.

Roadmap to obtain a payment license in Poland

The process of obtaining an EMI license in Poland consists of several sequential steps. It usually takes between 6 and 12 months, depending on the completeness of the documentation, responsiveness to KNF queries, and the complexity of the business model. A structured roadmap helps reduce delays and improves the chances of successful licensing.

Step 1. Incorporation and initial setup

The first step is incorporating a legal entity in Poland and setting up the corporate structure. Shareholders must be identified, directors appointed, and a registered office established. At this stage, it is also advisable to start discussions with a bank for opening a safeguarding account.

• Incorporation of a company in Poland (commonly sp. z o.o.).
• Appointment of shareholders and directors.
• Establishment of a registered office in Poland.
• Preliminary talks with a bank regarding safeguarding.

Step 2. Preparation of documentation

The next step involves preparing a business plan, programme of operations, and internal procedures. The package must also include AML/CTF policies, risk management framework, safeguarding arrangements, and IT systems description. The completer and more well-structured the submission, the faster KNF can issue a decision.

• Drafting a three-year business plan.
• Preparing the programme of operations and internal procedures.
• Developing AML/CTF policy and risk management systems.
• Providing documentation on safeguarding and IT infrastructure.

Step 3. Submission to KNF and review

Once documentation is ready, the application is filed with KNF for review. The regulator examines the business model, checks management qualifications, and analyses the ownership structure. KNF often issues requests for clarification, and timely, accurate responses are crucial.

• Filing the application with KNF.
• Review of documentation and corporate structure.
• Fit & Proper checks for directors and shareholders.
• Responding to KNF’s requests within deadlines.

Step 4. Decision and post-authorisation setup

The final stage is KNF’s decision and post-authorisation compliance setup. The firm must open its safeguarding account, implement compliance and reporting systems, and prepare for ongoing supervision. From this point, the business may officially provide EMI services.

• Receiving KNF’s decision to grant the license.
• Opening a safeguarding account with a bank.
• Setting up compliance and reporting procedures.
• Preparing for regular inspections and supervision.

Advantages of EMI license in Poland

Obtaining an EMI license in Poland gives companies access to the growing EU fintech market and provides a strong competitive edge. The jurisdiction combines strict KNF supervision with transparent procedures and support for innovative projects.

• The license grants access to the European Union market.
• KNF supervision builds trust with clients and banks.
• Poland offers a stable and predictable jurisdiction.
• The licensing process remains structured and transparent.
• The license enables international scaling opportunities.
• Safeguarding ensures the protection of client funds.

Ready to move forward? Ask a question to a compliance expert

Don’t delay your fintech launch – start your EMI licensing process in Poland today. Our expert team will guide you through every step: from company incorporation and documentation to KNF authorisation and compliance setup.