Instant payments in euros from 2026! New obligations for banks and fintech companies

On 9 December 2025, the Council of Ministers adopted a draft act amending certain laws related to the functioning of the financial market and the protection of its participants. One of the key elements of the draft is the implementation into the Polish legal framework of EU regulations on instant euro payments, resulting from Regulation (EU) 2024/886 of the European Parliament and of the Council, the so-called Instant Payments Regulation (IPR).

New responsibilities for PSPs: instant transfers in euros and verification of the payee (VoP)

The objective of the IPR is to introduce a standard for instant euro transfers executed in less than 10 seconds, available 24/7/365, for both consumers and businesses. The new regulations are intended to increase the efficiency and competitiveness of payment services and to facilitate cross-border settlements within the European Union, including for entities outside the euro area.

The draft act provides for the alignment of Polish law with EU requirements, in particular through:

• ensuring that payment service providers (PSPs) are able to offer instant euro transfers at no higher cost than standard credit transfers;
• imposing an obligation to provide the Verification of Payee (VoP) service,e. beneficiary verification, aimed at reducing the risk of errors and fraud;
• harmonising the rules governing the operation and availability of instant euro transfers on the Polish market with those applicable in other EU Member States.

Although the IPR is directly applicable, its implementation requires adjustments and supplementary provisions in national law, in particular with respect to supervisory arrangements, the competences of competent authorities, and administrative sanctions.

This is intended to ensure the effective functioning of financial supervision and efficient market administration at the national level. The draft act also includes other regulatory amendments, inter alia in the areas of financial market supervision, restructuring, and prudential regulations.

What obligations await Polish payment service providers in connection with IPR?

For Polish payment market participants, the timelines resulting from the IPR are of key importance. Although the final dates of certain obligations may still be clarified during the legislative process, according to the EU timetable payment service providers from non-euro area Member States will be required to implement the new obligations gradually – initially with respect to the receipt of instant euro transfers, followed by their sending and execution, together with the implementation of the Verification of Payee mechanism.

The new regulations represent a significant operational and regulatory change for banks, payment institutions, and electronic money institutions operating on the Polish market. Their implementation will require adjustments to IT systems, operational procedures, and internal and external documentation, including terms and conditions and customer service rules, as well as compliance and AML/CFT procedures.

The implementation of the Verification of Payee service may constitute a particular operational challenge.

Schedule for the implementation of instant transfers in euros in accordance with the IPR

The draft act has been submitted for further parliamentary work. It is expected that the national provisions will enter into force in mid-2026.

According to the timeline set out in the IPR, payment service providers from Member States whose currency is not the euro will be required to:

• from 9 January 2027– offer the service of receiving instant euro transfers;
• from 9 July 2027– offer the service of sending and executing instant euro transfers, together with the implementation of the Verification of Payee mechanism.

New obligations regarding instant transfers in euros may require a thorough review of operational and regulatory compliance

If you operate in the banking, fintech, or payments sector, now is the right time to prepare for the changes resulting from the IPR. Contact our team to analyze how the new regulations will affect your business.