KNF Tacit Approval for RAISP, MIP and BUP Registration from 2027 

From 1 January 2027, inaction by the Polish Financial Supervision Authority in certain registration proceedings will no longer automatically prevent an undertaking from commencing business in the payment services market. Once the statutory period has expired, the undertaking will be able to begin operations despite the absence of a formal entry in the register, provided that it submitted a complete application and the Polish Financial Supervision Authority neither made the entry nor issued a decision refusing registration.

KNF Inaction Allows MIP, BUP and RAISP to Begin Operations

The Act of 11 June 2026 amending certain acts to simplify administrative procedures in matters resolved by way of administrative decisions or dealt with by tacit approval introduces into the Polish Payment Services Act a specific mechanism applicable to proceedings concerning registration as an account information service provider providing exclusively account information services (RAISP), a small payment institution (MIP), or a payment services office (BUP).

If the Polish Financial Supervision Authority does not make the relevant entry in the register or issue a decision refusing registration within the statutory period, the applicant will be entitled to commence business by operation of law. For RAISPs and MIPs, this effect will arise on the day following the expiry of four months. For BUPs, it will arise on the day following the expiry of 45 days.

Complete Application Triggers the KNF Tacit Approval Deadline

The completeness of the documentation will be decisive for the application of the new mechanism. The statutory period will run from the date on which the Polish Financial Supervision Authority receives an application that does not require supplementation. The Authority will be required to notify the applicant of the date on which such an application was received.

As a result, a request to remedy deficiencies or submit additional documents may postpone the commencement of the statutory period. Merely submitting an application will therefore not be sufficient to benefit from the deemed approval mechanism. The applicant will need to provide documentation that satisfies all statutory requirements.

Commencing business operations prior to entry in the KNF register – new rules

The amendment also regulates the applicant’s position during the period between commencing business following the expiry of the statutory period and the formal entry being made by the Polish Financial Supervision Authority.

The supervisory authority will be required to make the entry without undue delay. Until then, the undertaking will be treated as an entity carrying on business on the basis of an entry in the relevant register. The register will subsequently indicate the date on which business commenced as determined by the expiry of the statutory period.

The applicant will be able to prevent this legal effect by withdrawing the application no later than on the last working day preceding the expiry of the relevant period.

New deadlines for RAISP, MIP and BUP applications from 2027 onwards.

The new provisions will not apply to applications submitted before 1 January 2027 that remain pending on that date. Such proceedings will continue to be conducted under the existing rules.

How to Use KNF Tacit Approval Effectively

• verify that the application and all required attachments are complete;
• prepare a timetable for commencing business that takes into account the date of receipt of the complete application confirmed by the Polish Financial Supervision Authority;
• monitor correspondence from the Polish Financial Supervision Authority on an ongoing basis, in particular any requests to supplement the documentation;
• prepare the organisational structure, internal procedures and operational arrangements required to commence business effectively once the statutory period has expired.

The new mechanism should make registration proceedings more predictable and limit the adverse consequences of prolonged administrative processing. It does not, however, reduce the importance of properly preparing the application. In practice, the completeness and quality of the documentation will determine whether the applicant can effectively rely on deemed approval.

Prepare Your KNF Application for the 2027 Rules

We support entities planning to register as an RAISP, MIP or BUP in preparing comprehensive documentation, verifying requirements and liaising with the Polish Financial Supervision Authority. We also help to plan a timetable for commencing operations and to implement the procedures necessary to make effective use of the KNF’s tacit consent mechanism. Contact us to assess the readiness of your application and minimise the risk of delays in the registration process.