The Polish Financial Supervision Authority has published a template for KIP application

On October 17, 2022, the Polish Financial Supervision Authority published a template form that can be used to apply for a permit to provide payment services as a national payment institution. The regulator points out that the preferred form for submitting KIP application is electronic via the ePUAP platform.  The use of the form is voluntary – applicants can still shape the content of the application on their own and submit additional documents (information / explanations) not included in the form.

KIP application form

The form provided by the Polish Financial Supervision Authority (PFSA) covers both the issuance and modification of a permit to provide payment services as a national payment institution (PI). The application is accompanied by sample attachments concerning, respectively:

• the applicant (Annex A),
• persons managing the applicant (Annex B),
• stockholder/shareholders of the applicant who is a natural person (Annex C1),
• stockholder/shareholders of the applicant who is a legal entity (Annex C2).

The template provides guidance on, among other things, outsourcing policy; use of cloud computing services whose provider is a third party; description of organizational structure; risk management; incident management; content of procedure for documenting, monitoring, tracking and restricting access to sensitive payment data; business continuity plan; security policy.

The template includes an updated checklist of documents to be attached to the application.

On the practical side, the regulator specifies that the business program and financial plan should cover 3 full fiscal periods (example: if the KIP application is submitted on July 1, 2022, the above 2 documents should be prepared for the period January 1, 2023 – December 31, 2025) and an incomplete fiscal period covering the year in which the application is submitted (so, following the dates in the example, the financial plan should cover 3.5 years). Financial plan data must be presented at least quarterly.

Access to the form

The template form is available at https://www.knf.gov.pl/komunikacja/wnioski_formularze

Opinion of the form

The initiative of the Financial Supervision Authority should be appreciated. Standardization of the application and attachments aims at simplifying and standardizing the process of substantive evaluation of the application, which is increasingly time-consuming due to the high interest of national payment institutions. We hope that the joint effort of the regulator, and applicants will contribute to speeding up these administrative proceedings.

Questions or concerns – contact our law firm

If you have any questions or concerns, we encourage you to contact our office. Inquiries can be directed to: [email protected]