KEY TAKEAWAYS
- The proposal to abolish small payment institutions is a supervisory comment submitted on 15 July 2026 during consultations on a draft bill, not a law and not the government’s own proposal.
- If adopted as drafted, SPI holders would have twelve months to apply for a full payment institution authorisation and eighteen months to stop providing payment services.
- New registrations would become impossible fourteen days after the act is published, far earlier than the rest of the changes take effect.
- A full authorisation requires initial capital of EUR 125,000 for the main range of payment services, compared with no capital threshold at registration.
- The regime exists because Poland used an option under Article 32 PSD2; Sweden withdrew from the same option in 2024.
As of 7 August 2026, nothing has changed. A registered small payment institution in Poland can operate exactly as before. What exists is a proposal from the financial supervisor, submitted during consultations on a draft bill, and if it were adopted as written, holders would have twelve months to apply for a full authorisation and eighteen months to wind down.
What has actually happened, and what has not
On 15 July 2026 the Polish Financial Supervision Authority’s office sent a letter to the Ministry of Finance asking that the draft bill currently in progress be extended to remove small payment institutions from Polish law. The letter carries the reference DBR-DBRZ2.071.2.2026.PK and comes with a fully drafted set of provisions attached, not a general request.
Three things follow from that, and they matter more than the headlines suggest.
This is a comment submitted during consultations. It is not part of the bill the Ministry of Finance itself prepared. The bill has not been adopted by the government and has not reached parliament. Until it does, the rules governing small payment institutions remain fully in force.
At the same time, the proposal is specific enough to plan around. It sets out exact deadlines, and one of them is much shorter than the coverage has suggested.
The registration route would close almost immediately
Most reporting has focused on an eighteen-month transition (see below for more details on that). That figure is real, but it does not apply to everything.
The provisions that govern how a company applies for registration, and how long the supervisor has to process that application, would be repealed fourteen days after the act is published. Everything else waits eighteen months. Registration would still be a legal requirement for providing payment services, but the procedure for obtaining one would no longer exist.
The practical effect is straightforward. New small payment institutions would stop being possible almost at once, while companies already registered would keep their status for another year and a half. The entry door closes first; the market is wound down afterwards.
If you are considering acquiring or setting up an SPI in Poland, treat that route as closing rather than open. The proposal may change, but planning around a two-week window is not planning.
Two deadlines that matter if you already hold a registration
The transitional rules work in two steps.
The general rule gives registered companies eighteen months from the day the act enters into force to stop providing payment services. That is the default outcome for a holder that does nothing.
The exception is the one worth acting on. A company that applies for a full payment institution authorisation within twelve months is not covered by the wind-down rule. It may continue operating under the existing regime until the supervisor decides on the application. That last part is well drafted: the risk of a long authorisation process does not fall on the applicant.
One detail shows how unsettled this still is. The same draft bill separately extends new obligations to small payment institutions, requiring them to apply banking rules on suspending transactions where a crime is suspected. So one document in this process adds duties for SPIs while a comment on that document removes the basis for their existence. The two were plainly not coordinated.
Holding an SPI registration and unsure what comes next?
Your matter is handled directly by the attorney, not passed to an account manager. Tell me where the company stands and I will tell you whether it is time to price the capital requirement and start on the documentation.
Why the supervisor wants removal rather than tighter supervision
The argument in the letter is not that the rules are too lenient. It is that the registration procedure leaves almost nothing to assess.
Registration is an administrative-technical act rather than a decision. The supervisor may refuse it only where the application is incomplete and has not been completed in time, or where the information given does not match the facts. That second ground cannot cover anything forward-looking, which is to say the business plan, the risk procedures or the description of how client funds will be protected. Criminal record checks on management take place after registration, not before it. The supervisor cannot make registration conditional on an assessment of whether the applicant is fit to run the business.
The figures in the letter, all as at 14 July 2026, are the second half of the argument. There were 147 registered small payment institutions. Since 2018, 291 companies have held a registration; 47 of them applied for a full authorisation and 10 obtained one. In the second half of 2025, 15% of holders accounted for 80% of all transactions by number. The active market is a couple of dozen companies, and the rest of the register is a long tail.
Moving to a full payment institution authorisation
The route out is a payment institution authorisation under Article 60(1) of the Polish Payment Services Act. It is a change of regime rather than an upgrade of paperwork.
Article 64(1)(1)(a) requires initial capital of EUR 125,000 where the company intends to provide any of the main payment services. A narrower range of services carries a lower threshold. The application itself calls for a business plan and financial projections covering at least three years, together with a description of the risk management and internal control framework and the internal policies that give it effect.
I have worked directly on national payment institution authorisation proceedings and on advising companies holding an SPI registration (Mateusz Świtalski, attorney-at-law, PZ-5181). In practice these proceedings ran around twelve months, and some longer. They stalled most often in the same three places: risk management documentation, AML procedures, and financial projections.
That is what makes the twelve-month window shorter than it looks. The deadline applies to filing, not to being authorised, so on paper there is room. But assembling documentation that survives review takes months of work before anything is filed. In practical terms the clock starts when the proposal becomes credible, which is now, rather than when the act enters into force.
If you bought a registered company rather than built one
This is a common situation and worth addressing directly, because the supervisor’s letter describes the pattern openly: registrations obtained through intermediaries, sold on, and held by owners based outside Poland.
The calculation here differs from an operating business in one respect. What was bought was the registration itself, and under the proposal that asset simply disappears at the end of the transition. Everything required for a full authorisation, the capital, the documentation and the ongoing obligations, applies in exactly the same way regardless of how the company was acquired. There is no shortened route for existing holders.
Three things are worth checking first. Whether the company is actually processing transactions, because prolonged inactivity is already a ground for removal from the register under the current rules. Who sits on the management board and whether those people are in a position to run an authorised institution. And whether reporting obligations to the supervisor have in fact been met, since the letter identifies missing and inaccurate reporting as one of the most common problems it sees.
If the honest answer is that the company was never intended to trade, an orderly exit is worth considering well before any deadline forces one.
Where EU law stands
Small payment institutions exist in Poland because the country used an option available to member states under Article 32 PSD2. Using that option is voluntary, and nine other states did so; Sweden withdrew from it in 2024, giving its holders a transition period to obtain a full authorisation or stop.
At EU level the option is not disappearing. The PSD3 compromise text agreed in April 2026 keeps an exemption for small payment service providers available to member states and adds a duty to notify the Commission when it is used. PSD3 has not yet been published in the Official Journal, so it is an agreed text rather than law.
Keeping an option available, however, is not the same as requiring it. Poland is free to withdraw, and the Swedish precedent shows how that is done.
What to do now
Nothing in the proposal binds anyone yet, and it may be rejected, reshaped or moved into a separate bill. What will not change is that preparing a credible authorisation application takes months, and that the decision of whether to pursue one is better made early than under a deadline.
If the company is trading and the business works, the sensible next step is to price the capital requirement and review the documentation against what a full application demands. If it is not trading, the useful question is what an orderly exit looks like.
This text is current as of 7 August 2026. The clearest signals of what happens next will be the next version of the draft bill and the report on consultations, both published by the Polish Government Legislation Centre.
Frequently Asked Questions
Yes. As of 7 August 2026 the rules on small payment institutions are fully in force and a registered company can provide payment services as before. The proposal to remove them is a comment submitted by the supervisor during consultations on a draft bill that the government has not yet adopted.
Registration is still available under current law. However, the proposal would repeal the provisions governing how a company applies for registration only fourteen days after the act is published, while other changes wait eighteen months.
Twelve months from the day the act enters into force. A company that does not apply within that period would have eighteen months to stop providing payment services. Both deadlines come from transitional provisions proposed by the supervisor, not from law currently in force.
A company that filed its PI application in time may continue operating under the existing regime until the supervisor issues a decision. The risk of a lengthy authorisation process does not fall on the applicant.
No. Small payment institutions exist because Poland used an option available to member states under Article 32 PSD2, and using that option is voluntary. Sweden withdrew from it in 2024. The PSD3 compromise text keeps the exemption available to member states but does not require it.