FinTech and payment institutions
SPI licence in Poland
We enter your company in the KNF register of small payment institutions: we draft the business model description, the risk management system, AML procedures and the financial plan. Or we source a company that already holds the status.
- A complete document pack built to the regulator's requirements
- Preparation 2–4 weeks, KNF review up to 3 months
- We answer KNF queries at every stage of the review
- We help you move up to KIP when the business outgrows the limit
- Fintech and crypto experience
- Warsaw office
- Reply in 15 minutes
- Fully remote
Pricing
Two routes to payment institution status
We prepare the full document pack for KNF — the business model description, the risk management system, AML procedures and the financial plan — and see the project through to entry in the register. Or we source a company that already holds the status.
Support in obtaining SPI license
For projects with a clear, transparent business model
the PLN 616 state fee is paid separately
- preparation 2–4 weeks
- KNF review up to 3 months
- Preparation of the full document pack for KNF
- Description of the payment services and the business process
- Financial plan for the first 12 months
- AML/CFT policies tailored to your business model
- Risk management system and turnover calculation methodology
- Support through to entry in the register, including replies to KNF queries
Shelf company with SPI license
When you need the status now, without waiting for KNF
depends on the company age and whether an account is open
- deal in 1–2 weeks
- status already in the register
- A ready Sp. z o.o. legal entity
- Registered address in Warsaw
- Bank account with a Polish bank
- Confirmation of entry in the KNF register
- Notarial or online transfer of shareholders and management
- State fees paid and an AML certificate
PLN 616 — the state fee for filing the application for entry in the register. The KNF supervisory fee — an annual payment that depends on the transaction volume for the year; the maximum rate is 0.025 % of the total. Registering the company itself, if you do not have one, is a separate service.
The basics
What MIP is, in plain terms
MIP (Mała Instytucja Płatnicza), known in English as a Small Payment Institution, is a status that lets a Polish company provide payment services on a limited scale within Poland after being entered in the register of small payment institutions maintained by the Polish Financial Supervision Authority KNF.
The legal basis is the Polish Payment Services Act, which implements the European PSD2 directive.
MIP does not require a KNF authorisation, only entry in the register provided the formal conditions are met. Entering the market is far faster and cheaper than classic licensing, but it caps your scale and geography.
The procedure is simpler — and that is exactly what misleads people. The requirements for the documents, the business model description and the AML procedures are serious, and treating the document pack as a formality is a common and expensive mistake.
When the status is needed
Who needs MIP
Under Polish law, MIP status is required by anyone who receives funds in order to transfer them to another person and holds those funds on their own account — even for the briefest moment.
Run a payment gateway — you need MIP. Run a marketplace where buyers' money passes through your account before you pay the seller — you need MIP.
Typical scenarios
- Fintech projects focused on the Polish market that do not need to passport services across the EEA
- Payment card issuers and local-scale e-wallet operators
- Money remittance projects with limited turnover
- Banking-as-a-Service platforms at launch, when transaction volumes do not yet justify the cost of a KIP licence
- Crypto and fintech companies that need payment functionality alongside VASP/CASP registration — accepting fiat payments and paying out to clients
- Marketplaces and trading platforms
On its own it does not permit services involving crypto assets. But crypto projects often use it as a complementary regulatory layer alongside registration as a crypto asset service provider.
Not sure MIP is the right status for your project?
Four questions about your business model, turnover and geography — and you will see which status fits: MIP, KIP or the separate e-money status.
Comparison
MIP or KIP — what is the difference
Two different statuses with different entry procedures. The choice depends on turnover, geography and whether you need to issue electronic money.
| Criterion | MIP — small payment institution | KIP — national payment institution |
|---|---|---|
| Type of procedure | Entry in the register (wpis do rejestru) | KNF authorisation (zezwolenie) |
| Minimum capital | Not set — general Commercial Companies Code rules apply, e.g. PLN 5,000 for an Sp. z o.o. | Set by law and depends on the scope of services: EUR 50,000–125,000 |
| Territory | Poland only | Poland and other EEA countries, with the right to passport services |
| Turnover cap | On average no more than EUR 1,500,000 of transactions per month over the previous 12 months — about EUR 18m a year | No regulatory cap |
| Issuing electronic money | Not allowed — that requires the separate MIPE status | Possible if additional requirements are met |
| Requirements for management | Only the absence of a criminal record for certain offences | Besides a clean record — proven experience and qualifications |
| KNF review time | Up to 3 months from filing the complete pack | Considerably longer, with a deeper review |
A platform built for MIP scales up. As it approaches the turnover cap, the company applies for a full KIP licence on the same organisational and technical base — the process does not start from scratch.
What MIP allows and what it does not
Permitted services
- Operating payment accounts
- Cash deposits to and withdrawals from an account
- Executing transfers and direct debits
- Card payments
- Issuing payment instruments
- Payment acquiring
- Money remittance
What MIP cannot do
- Services based on access to third-party accounts — account information (AISP) and payment initiation (PISP)
- Issuing electronic money — that requires the separate small e-money institution status
- Providing services outside Poland
- Having agents or branches abroad
Constraints
Three limits that decide everything
If your project does not fit inside them, MIP is not your option — and it is better to find that out before filing, not after.
Per month on average over the previous 12 months — about EUR 18m a year. If exceeded, the company has 30 days either to bring its scale back within the cap or to apply for KIP.
The maximum amount held at any moment on a single user's account. This is about the balance on the account — individual transfers may be larger.
Activity within Poland only. No agents or branches abroad. If you need to reach other EEA countries, that means KIP with service passporting.
Preparation
Requirements and documents
For the company and its management
Here MIP beats KIP on ease of entry. From the people running the company the law requires only the absence of a criminal record for a defined list of offences. There is no formal requirement for relevant education or experience running a financial institution — unlike KIP, where such experience is mandatory.
That said, the organisational structure must assign responsibility for:
- internal control
- correct operation of the IT system through which services are provided
- security incident management
The document pack for KNF
- A description of the planned payment services, including a business process diagram
- A description of the risk management system
- The methodology for calculating total monthly transaction volume — the regulator wants to see how the company monitors its own approach to the cap
- A business programme and a financial plan for the first 12 months
- A description of how user funds are safeguarded
- A description of the AML/CFT procedures, including the person appointed to oversee compliance
If the application or its annexes are incomplete, KNF issues a request to remedy the deficiencies with a deadline of no less than 7 days. Failing to supply the documents on time can be grounds for refusing entry in the register.
The procedure step by step
- Preparing the companyRegistering a Polish company, usually an Sp. z o.o., which will hold the status.
- Preparing the document packDescription of the services, the risk management system, the turnover calculation methodology, the business plan, the client funds safeguarding programme and the AML procedures. Usually takes 2–4 weeks.
- Filing the application with KNFTogether with the complete set of annexes.
- Review by the regulatorThe statutory deadline is up to 3 months from receipt of the complete pack. In practice, with additional queries, it can stretch to 6–8 months.
- Entry in the registerThe company is entered in the register of small payment institutions and can start operating legally.
In practice
Why applications stall and get refused
From our experience with these projects, the same reasons come up again and again:
- A superficial description of the payment services that does not match the real business model, plus a token business process diagram
- A boilerplate risk management system not tailored to the specific project
- An insufficiently detailed client funds safeguarding programme
- A criminal record among the management for offences on the statutory list
- An incomplete document set at the first filing — on its own this does not cause refusal, but it sharply extends the timeline because of additional KNF queries
Formally the procedure is simpler than KIP licensing, and that is precisely what misleads applicants. The business model description, the risk management system and the AML procedures must be substantive and match what the company actually does, not copied from a template. The regulator can tell.
FAQ
Frequently asked questions about MIP
Is MIP a payment licence in Poland?
Legally it is an entry (wpis do rejestru) in the register of small payment institutions maintained by KNF, not full licensing. The procedure is simpler and faster than obtaining a KIP authorisation, but the document requirements are still substantive.
How long does registration take?
About 3 months on average. Our team usually needs 2–4 weeks to prepare the documents. In practice KNF can enter a company in the register faster, but with additional queries the process stretches to 6–8 months.
Can an MIP issue electronic money?
No. Standard MIP status does not grant that right. Issuing e-money requires a separate status — a small electronic money institution (Mała Instytucja Pieniądza Elektronicznego).
Can a new company with PLN 5,000 capital obtain MIP?
Yes. Even a newly formed company with the minimum share capital can obtain the status. There are also no restrictions on companies registered online through the S24 system.
Does an MIP company need a bank account?
Yes. An MIP must hold a separate bank account for safeguarding user funds, and it must be opened with a Polish bank — with a Polish IBAN.
Can you move from MIP to KIP later?
Yes, and it is the standard growth path for payment projects: the company starts as an MIP with a lower barrier to entry and, as it nears the turnover cap, applies for KIP using the same organisational and technical infrastructure.
Is MIP suitable for a crypto project?
MIP alone does not permit crypto asset services. But crypto companies often use it as an additional status for accepting and processing fiat payments alongside registration as a crypto asset service provider (VASP/CASP).
What does your fee cover?
Drafting the payment services description and the business process diagram for your specific project, the risk management system and turnover calculation methodology, the business and financial plan for 12 months, the client funds safeguarding programme, AML/CFT procedures, filing with KNF and support at every stage including replies to the regulator. The state fee and the supervisory fee are paid separately.
Why this is worth delegating
We take on the payment services description and business process diagram, the risk management system and turnover methodology, the business plan for the first 12 months, the client funds safeguarding programme and AML/CFT procedures, the KNF filing and support at every stage of the review.
And if the business outgrows MIP, we help you move up to KIP on the same infrastructure.
What does your project do with client money?
What payment turnover do you expect?
Where will you operate?
Do you already have a Polish company?
MIP status
- Price: —
- Timeline: —
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