Payment Institution Licence in Poland (KIP)

Most "which payment licence do I need" questions resolve to one of four rungs. Picking the wrong one is the most expensive mistake in the process – too light and you hit a wall on volume or scope; too heavy and you carry capital and compliance you don’t yet need.

This hub is about the KIP – the full payment-institution authorisation. If you are Poland-only and below EUR 1.5m in average monthly turnover, the lighter MIP route is usually the right start; it has its own guide – the MIP guide >. An even lighter niche rung exists for money remittance only (biuro usług płatniczych), registration-based and capped. The EMI sits alongside the KIP for anyone whose product is issuing e-money rather than moving it – a regime we also handle, and one PSD3 is set to fold into the payment-institution framework (§12).

A KIP is a legal person seated in Poland that has obtained KNF authorisation to provide payment services (art. 60 of the Payment Services Act). The authorisation names the specific services it covers (art. 63 of the Payment Services Act), drawn from the statutory catalogue in art. 3(1):

• > maintaining payment accounts and cash deposits/withdrawals (pkt 1–2);
• > executing payment transactions – credit transfers, direct debits, card transactions (pkt 3);
• > executing transactions funded by payment credit (pkt 4);
• > issuing payment instruments and acquiring (pkt 5);
• > money remittance (pkt 6);
• > payment initiation – PIS (pkt 7);
• > account information – AIS (pkt 8).

Unlike a small payment institution, a KIP has no turnover cap, is not confined to Poland, and can provide PIS and AIS. It can also run ancillary business as a hybrid payment institution. What it takes on in return – capital, safeguarding, own funds, and full supervision – is the subject of the sections below. If you are still deciding whether you need this much, the MIP guide > covers the lighter alternative.

Any business providing payment services in Poland on a professional basis needs either a KIP authorisation or one of the lighter statuses on the ladder. The full KIP is the right rung when at least one of these is true: turnover will exceed the MIP ceiling of EUR 1.5m average monthly; the business needs to operate in other EEA states (which a MIP cannot); or the service set includes payment initiation or account information, which a MIP is barred from (art. 2(17b) of the Payment Services Act).

Conversely, if you are testing a product on the Polish market, below the cap, and Poland-only, the MIP is faster and cheaper – start there and step up when a limit binds. That decision, and the 30-day clock that forces the step-up on a MIP that breaches its cap, is covered in the MIP guide >.

A KIP applicant must be a legal person seated in Poland (art. 60 of the Payment Services Act), governed by people who satisfy the fit-and-proper standard (§06), with a business and financial plan, safeguarding arrangements, and initial capital scaled to the services sought.

Initial capital

Art. 64(1) of the Payment Services Act; PSD2 art. 7. The threshold depends on the service set:

Capital is measured in PLN at the NBP average rate on the day the authorisation is issued, and may not come from a loan or credit or otherwise be encumbered. On top of initial capital, a KIP must maintain ongoing own funds – covered in §10.

Safeguarding is the sharpest line between a KIP and a small payment institution, and the provision regulators scrutinise hardest. Where a KIP receives client funds to execute payment transactions, art. 78 of the Payment Services Act (PSD2 art. 10) gives it two routes, and it must use one of them:

• > Segregation – keep client funds separate from own funds and, by the end of the next business day, place them on a segregated account with a bank or credit institution, or invest them in secure, liquid, low-risk assets held on a segregated account; or
• > Guarantee or insurance – a bank guarantee, insurance guarantee, or insurance policy for an equivalent amount, taken out with a bank or insurer outside the institution’s own group, which KNF can call on.

The point of safeguarding is that client money survives the institution’s insolvency. A product design that quietly relies on using client funds – common in yield or float-based models – fails this test and has to be restructured before filing, not after.

Fit-and-proper (rękojmia)

KNF must be satisfied that the applicant and the people managing it give a guarantee of prudent and stable management – the rękojmia ostrożnego i stabilnego zarządzania standard, assessed from the application (art. 61(1)(8)–(9) of the Payment Services Act) and imposed as a licence condition (art. 64(1)(4)). Qualifying shareholders – holding 10% or more of capital or votes (art. 2(37)) – are assessed too, and any later acquisition of a qualifying holding is subject to notification and possible KNF objection (art. 72a–72d).

AML

A KIP is an obliged institution under the AML Act and must run a full AML/CFT framework, including a designated AML officer (AMLRO) under art. 8 of the AML Act, KYC and ongoing monitoring, and suspicious-transaction reporting to the Financial Intelligence Unit (GIIF). Governance, risk management, and internal control must be sized to the scale and complexity of the services.

Authorisation is a full substantive review, not a registration. The application content is set out in art. 61(1)(1)–(11) of the Payment Services Act: a programme of operations and business plan, the governance and internal-control description, the AML framework, safeguarding arrangements, the ownership structure and fit-and-proper documentation, the financial plan, and the ICT/operational-resilience documentation. KNF issues the authorisation specifying the services covered (art. 63), or refuses it where a condition of art. 64 is not met (art. 65).

Timeline

The statutory decision period is three months from a complete application or its formal supplement (art. 62 of the Payment Services Act). That is the decision clock, not the elapsed time: in practice, the iterative back-and-forth on documentation and the completeness bar mean the real timeline runs materially longer – plan in quarters, not weeks. KNF conducts the process in Polish and leans toward written, paper-based interaction rather than pre-application dialogue, which lengthens the exchange for applicants used to a more conversational regulator.

This is where direct counsel earns its keep. Across 10+ payment-institution proceedings before KNF – small and national payment institutions – the pattern is consistent: files stall on completeness and on documentation that reads as a template rather than a description of how this business actually runs. You deal with one named attorney who runs the file end to end, not an account manager or a queue.

The state fees are modest; the real cost is capital and compliance.

• > Authorisation issuance fee: the PLN equivalent of EUR 1,250 (at the NBP average rate on the day the authorisation is issued). Changing the authorisation later costs EUR 400; entry in the KIP register after authorisation carries no additional fee.
• > Initial capital: EUR 20,000–125,000 by service set (§04) – not a fee, but capital you must hold and not encumber.
• > Ongoing own funds: maintained continuously and adjustable by KNF (§10).
• > Safeguarding: the operational cost of segregated accounts or a guarantee/insurance policy (§05).
• > Ongoing supervision: KIPs bear KNF’s supervisory costs under the financial-market supervision framework.

As with a MIP, the budget that matters is the documentation package and the ongoing compliance operation – not the EUR 1,250 at the door. The difference at the KIP level is that capital and safeguarding are real, standing commitments, not a one-off.

Passporting is the KIP’s decisive advantage over a MIP. Once authorised, a KIP may provide its services throughout the EEA – through a branch, through agents, or on a cross-border services basis (art. 91(1) of the Payment Services Act; PSD2 arts. 11–17). The mechanism is a notification: the KIP notifies KNF, which forwards it to the host-state authority, after which the KIP may begin on the notified date. No host-state authorisation is required.

The traffic runs both ways. An EU payment institution or account-information provider authorised elsewhere can passport into Poland (art. 96–98b of the Payment Services Act; art. 97 gives KNF one month to send its assessment and any AML/fraud reservations to the home supervisor). For a business whose ambitions cross borders, this is the whole case for a KIP over a MIP: one authorisation, EEA-wide reach.

Authorisation is the entry point, not the endpoint. A licensed KIP carries continuous obligations:

• > Own funds (art. 76 of the Payment Services Act; PSD2 art. 9). Held at all times at the higher of the initial capital or a figure computed under one of the PSD2 methods (A – fixed overheads; B – payment volume; C – income indicator), set by ministerial regulation. KNF can require up to 120% or permit down to 80% of the calculated level based on risk (art. 76(4)–(7)). A KIP providing only PIS is exempt from the ongoing own-funds requirement (art. 76(1)).
• > Supervision and reporting. KNF supervision under Dział VI of the Payment Services Act, periodic and event reporting, and cooperation with inspections.
• > DORA. As a financial entity, a KIP is subject to the ICT risk-management, incident-reporting, and operational-resilience requirements of Regulation (EU) 2022/2554, now reflected in the ICT and incident definitions of art. 2 of the Payment Services Act.
• > Keep the licence live. The authorisation lapses if the KIP does not commence payment activity within 12 months of issuance, or ceases payment activity for more than 6 consecutive months.

The line between a payment licence and a crypto licence runs straight through e-money tokens. Under MiCA, an EMT referencing an official currency is deemed to be electronic money (art. 48 of MiCA), and MiCA art. 70(4) is explicit that a crypto-asset service provider may provide payment services connected to its crypto services only if it is authorised under PSD2. So the moment value moves between unrelated parties, a crypto product can quietly become a regulated payment service needing PI or EMI authorisation on top of a CASP licence – a boundary the EBA confirmed in its 2025 opinion on the MiCA/PSD2 interplay.

This is work I have run from inside a regulated exchange, not advised on from the outside. I identified that allowing EMT transfers to third parties would amount to an unauthorised payment service under MiCA and PSD2, and restructured the product so transfers were limited to accounts belonging to the same client. On a crypto-payments gateway, I screened the settlement flows and had a stablecoin that was not authorised under MiCA removed, closing a flow that would otherwise have been an unauthorised payment service. Where a product needs both sides, the CASP and the payment-services analysis have to be run together. The crypto side of that boundary is covered on the crypto licence hub >.

The EU payment-services package – PSD3 (a directive replacing PSD2 and folding in the E-Money Directive) and the PSR (a directly applicable regulation on conduct, fraud, and access) – reached provisional political agreement in November 2025, with the ECON committee approving the compromise texts in May 2026. As of mid-2026 they are not yet in force: PSD2 and EMD2 still govern, and the Polish KIP/EMI regime rests on the current Payment Services Act.

Three shifts to plan for once the package applies (indicative timing: the PSR roughly 18–24 months after entry into force; PSD3 transposed within about 18 months). First, EMIs fold into the payment-institution framework – the KIP/EMI split described here converges. Second, stronger fraud rules – verification of payee (name/IBAN matching), expanded liability for impersonation fraud, and obligations on platforms that carry fraudulent content. Third, open banking moves toward open finance, with more consistent API-access and interface-supervision requirements. No fixed application date is set in law yet; build now with the direction of travel in mind.