Small Payment Institution in Poland (MIP)

A small payment institution is the entry rung of Poland’s payment-services regime. It sits in a dedicated part of the Payment Services Act (Dział VIb, Art. 117f and following) and works by registration, not by full authorisation – which is why it is faster, cheaper, and lighter to stand up than a full payment institution, and why it comes fenced in by limits.

It fits three profiles: a startup testing a payment product on the Polish market before committing to a full licence; an established business that wants to add a payment service as a sideline; and any operator whose volumes genuinely sit below the caps and whose customers are in Poland. If your plan needs cross-border reach, passporting, or turnover above EUR 1.5 million a month, the SPI is the wrong instrument – go straight to a full payment institution (§10).

Two numbers define the whole regime and are worth fixing before anything else: EUR 2,000 held per customer at any time, and EUR 1,500,000 in average monthly turnover over the preceding 12 months. Everything below follows from those two ceilings.

An SPI may provide any of the payment services listed in Art. 3(1)(1)–(6) of the Payment Services Act: maintaining payment accounts, executing payment transactions (including card transactions and credit transfers), executing transactions funded by payment credit, issuing payment instruments, acquiring, and money remittance.

What it may not do is decisive. The statutory definition of an SPI (Art. 2(17b)) restricts it to services under points (1)–(6) and expressly excludes points (7) and (8) – payment initiation services (PIS) and account information services (AIS). If your product is an open-banking initiation or aggregation service, an SPI cannot carry it; you need a full payment-institution authorisation or a dedicated AISP registration.

One boundary to flag early: an SPI licence does not authorise crypto-asset services. Since the MiCA transition ended on 1 July 2026, crypto-asset services for the Polish market run through CASP authorisation obtained in another EU Member State and passported in – a separate track covered in crypto license in Poland >.

Per-customer balance – EUR 2,000

Art. 117h(3). The total funds an SPI holds for any single user, across all payment accounts, may not exceed the PLN equivalent of EUR 2,000 at any moment. The conversion uses the NBP average rate on the last day of the preceding month.

Turnover – EUR 1,500,000 average per month

Art. 117f(3)–(4). The average of the total value of payment transactions executed by the SPI (including through agents) over the preceding 12 months may not exceed the PLN equivalent of EUR 1,500,000 per month. The monthly figures are converted at the NBP average rate on the last day of the month before the one being measured (Art. 117f(4)).

Poland only

Art. 117f(2). An SPI’s activity may be carried on solely within the territory of Poland – no branches or agents abroad, and no PSD2 passporting. In practice, KNF reads this restriction to also constrain an SPI’s involvement in cross-border transfers where the counterparty’s provider sits outside Poland. Passporting is reserved for fully authorised payment and e-money institutions under other parts of the Act.

Breach either cap and the clock starts: you must either scale activity back within the limits or apply for a full payment-institution authorisation within 30 days (§09, §10).

The SPI regime is deliberately open on form and nationality. An SPI can be a limited liability company (sp. z o.o.), a joint-stock company (S.A.), or a sole proprietorship – whichever suits the business.

There is no residency or nationality bar on the founders. The only hard personal requirement is a clean criminal record for the person managing the SPI (Art. 117h(1)(2)) – see §07 for the exact scope. A Polish chair of the management board is advisable in practice but not mandatory. The one real exclusion runs the other way: ties to the Russian Federation or the Republic of Belarus can, under KNF practice, preclude registration or a director role.

Registration is a documentary process, not a negotiation. The application lists the payment services intended and the company’s identification data, and must be accompanied by the internal documents that let KNF see the business will run inside the rules:

• > a business plan for the first year of operation;
• > a financial plan for the first year;
• > risk-management procedures;
• > an internal AML procedure;
• > a description of the organisational solutions that let the SPI calculate its total monthly transaction volume (needed to police the EUR 1.5m cap);
• > rules for handling client funds.

The file is submitted on the official KNF form – electronically via ePUAP, by post, or in person. Once the application is complete, KNF registers the SPI within three months (Art. 117k(1)); activity may begin on the date of entry in the register (Art. 117k(2)), and KNF issues a certificate of entry (Art. 117k(3)). Where the file has gaps, KNF calls for completion and the clock runs from the supplement. Registration can be refused where the application is incomplete or inaccurate, or where the applicant was banned from business or struck from the payment-services register within the last three years.

The SPI is cheap to register and cheap to run at the level of state fees – the real budget goes into documentation and compliance, not into the licence itself.

• > Registration: a PLN 616 stamp duty (opłata skarbowa) on the register entry. That is the headline cost of getting registered.
• > Capital: none required by payment-services law (§08).
• > Ongoing supervision: an annual KNF fee capped at 0.025% of the prior year’s transaction value (§09).

Where the money actually goes is the documentation package – business plan, AML procedure, risk-management framework – and the ongoing cost of running AML and compliance once you are live. Budget for the build and the operation, not for the state fees.

Clean-record standard

Art. 117h(1)(2). The managing person must not have a final conviction for offences against the administration of justice, against economic turnover, against the circulation of money and securities, for financing a terrorist offence, for offences committed for material or personal gain, or for fiscal offences.

AML is not optional

And there is no "small firm" waiver. An SPI is an obliged institution (instytucja obowiązana) under the AML Act, so the standard governance designations apply regardless of size: senior management responsible for AML/CFT compliance (Art. 6), a management-body member responsible for implementing AML obligations (Art. 7), and an employee responsible for overall AML compliance – effectively the AML compliance officer / AMLRO (Art. 8). Operationally, the SPI must also maintain solutions that let it both compute its monthly transaction totals and discharge its AML obligations (Art. 117h(1)(1)).

The Payment Services Act sets no minimum share capital for an SPI. You capitalise it to the ordinary company-law minimum for whichever corporate form you pick, and to whatever level the business plan realistically needs – nothing more is imposed by payment-services law.

The PLN 1,000,000 figure that circulates in this context does not come from payment-services law at all. It is the minimum share capital for a lending institution (instytucja pożyczkowa) under Art. 59a(2) of the Consumer Credit Act, and it bites only if the SPI also provides consumer credit. Providing payment credit (kredyt płatniczy) as an ancillary to a payment transaction under Art. 74 of the Payment Services Act is a different thing and does not trigger it. The distinction matters: the moment you offer general consumer lending, you step into a separate regime with its own PLN 1m floor, paid in cash and not funded from credit, loans, bond issues, or undocumented sources.

One related constraint: an SPI may not finance its operations from credit, loans, bond issues, or undocumented sources, save for narrow exceptions (e.g. bank loans or loans from related entities that did not themselves obtain the funds by prohibited means).

An SPI is supervised by KNF and bears the cost: a supervision fee of up to 0.025% of the total value of the payment transactions it executed in the prior year (Art. 117u(1)).

Reporting runs on three tracks, and the destinations are commonly misstated – so precisely:

To KNF. Event-driven notifications within 14 days (Art. 117p) – breaching the EUR 1.5m limit, the initiation of criminal or fiscal proceedings against a managing person, and transfer-account details. A post-breach obligation (Art. 117q) – scale down or apply for a full payment-institution licence within 30 days. Periodic reporting (Art. 117r) – quarterly transaction data by the end of the month following each quarter, annual data by 31 January, monthly data during any limit-adjustment period, and financial statements after approval.

To GIIF. As an obliged institution: suspicious-transaction and suspicious-activity reports, high-value transaction data, and customer due-diligence records, plus cooperation with GIIF inspections.

To NBP. Limited. NBP’s direct role is confined to issuing settlement numbers (numery rozliczeniowe, Art. 4a); there is no separate periodic reporting obligation running from an SPI to NBP. (This corrects a common overstatement – SPI reporting flows to KNF and GIIF, not to NBP on a recurring basis.)

The SPI is a starting rung, chosen deliberately for its speed and low cost – not a permanent home for a scaling business. Two triggers push you off it: the EUR 1.5m monthly cap and the Poland-only scope. When either becomes binding, the next step is a full payment-institution (KIP) authorisation, which carries a real prudential regime – initial capital under Art. 64, safeguarding of client funds, a fit-and-proper board – but in return gives you higher volumes, EU passporting, and cross-border reach.

The move can also be forced. If an SPI breaches the turnover cap, Art. 117q gives it 30 days to either rein activity back inside the limit or file for a full payment-institution licence. Better to see the ceiling coming and plan the transition than to be pushed through it on a 30-day clock.

How the full authorisation works – capital, safeguarding, the KNF process – is covered on the payment institution licence hub >.

The EU’s 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 political agreement in November 2025, and the ECON committee approved the agreed texts in May 2026. As of mid-2026 they are close to adoption but not yet law: PSD2 and the existing framework still bind, and Poland’s SPI regime continues to rest on the current Payment Services Act.

Two things to watch once the package applies (indicative timing: the PSR from roughly 18–21 months after publication; PSD3 transposed within about 18 months). PSD3 is expected to fold e-money institutions into the payment-institution framework, and the national MIP category – a Polish creation under PSD2 – may be revisited on limits, reporting, and ICT/fraud safeguards to fit the new architecture. No fixed application date has been set in law yet; anyone building an SPI now should design with the direction of travel in mind rather than the exact dates.