Game-Changer for Fintechs: Direct Access to Elixir and SORBNET3 for Non-Bank Payment Institutions

Background: Modernisation of Payment Services Law in Poland

On January 23, 2026, the Sejm of the Republic of Poland passed an amendment to several acts regulating financial markets and consumer protection. The new legislation implements several provisions of the EU Payment Services Directive (PSD2) into Polish law, including rules on access to designated payment systems set out in Article 35a PSD2.

Scope of the Reform: Elixir and SORBNET3 in Focus

The adopted law introduces a legal framework that defines operational, compliance and technical requirements for payment institutions (PIs) and electronic money institutions (EMIs) seeking direct access to designated payment systems, including:

• Elixir- Poland’s principal interbank clearing system for retail payments, operated by KIR S.A., handling credit transfers, direct debits, and settlement cycles.
• SORBNET3- the National Bank of Poland’s (NBP) real-time gross settlement platform for high-value, time‑critical interbank transfers, built on ISO 20022 messaging standards for enhanced flexibility and interoperability.

Under the updated rules, PIs and EMIs may qualify to connect directly to these infrastructures, bypassing intermediaries and potentially improving efficiency, transaction settlement speed, and competitive positioning within the financial ecosystem.

Legislative Status and Next Steps

The amending act has been forwarded to the Senate of the Republic of Poland for further review. A session of the Senate Finance and Budget Committee is expected in the early days of February 2026.

Once adopted, the law will enter into force 14 days after its official publication. The precise effective date will be confirmed once the text is published in the Journal of Laws.

Strategic Implications for Payment Institutions

For PIs and EMIs operating in or entering the Polish market:

• Regulatory preparedness is essential to meet the criteria for direct system access.
• Operational frameworks, compliance management, API connectivity and system integration capabilities should be assessed against the emerging standards.
• As modern payment infrastructures evolve (e.g. ISO 20022 messaging and real-time settlement), organisations with direct access can leverage more granular transaction data, lower reliance on third parties, and improved control of payment workflows.

Why This Matters for the Fintech and Payments Sector

Direct participation in national payment systems represents a structural shift for non-bank players, supporting:

• Greater market competition by enabling alternative providers to offer services historically mediated by banks.
• Enhanced interoperability with established infrastructure and newer platforms aligned with global standards.
• Potential cost savings and operating efficiencies through reduced intermediary layers.

This development dovetails with broader EU initiatives under PSD2 and future directives aimed at enhancing security, transparency and innovation across the payments landscape.

What Should You Do Now?

If your organisation is considering applying for access to Elixir, SORBNET3 or similar systems:

• Begin gap analysis of your legal, compliance and technical readiness.
• Map your internal processes against the expected requirements under the amended law.
• Prepare documentation and engage with legal and technology advisors to build a robust submission strategy.

With extensive experience supporting regulated payment service providers, ftl is ready to assist in planning and executing readiness initiatives that align with both Polish obligations and broader EU payment frameworks.

Do you have any questions? Would you like to start preparing?

Our team supports payment institutions and fintech companies in adapting to legislative changes. We offer comprehensive legal, regulatory, and technological support based on many years of experience.

Contact us: [email protected]