President Signs New Amendment: Payment Systems Open to Fintechs in Just 14 Days

On March 9, the President of the Republic of Poland signed the Act of January 23, 2026, amending certain acts related to the functioning of the financial market and the protection of its participants.

Today, March 13, the document was officially published in the Journal of Laws. This means the legislation will enter into force 14 days after its publication.
A completely new chapter is unfolding for the Fintech industry.

Direct Access to Settlement Infrastructure

A pivotal change for the market is the amendment to the Act on Settlement Finality in Payment and Securities Settlement Systems and the Rules of Oversight of these Systems.

Thanks to the new provisions, both payment institutions and electronic money institutions will officially be recognized as participants in payment systems. These changes are a direct result of transposing Article 35a of the PSD2 Directive into Polish law.

Rigorous Requirements for New Participants

The privilege of direct access to payment systems comes with increased supervisory obligations. Institutions applying for participation in such systems, as well as those already participating, must possess and constantly update specific documentation:

• A description of the measures taken to safeguard users’ funds.
• A description of the governance arrangements and internal control mechanisms regarding the provided services.
• A description of the solutions regarding the use of information and communication technology services.
• A winding-up plan in case of insolvency, tailored to the anticipated size and business model of the institution.

However, these entities are not left alone to interpret the regulations. Under the amended act, upon the request of a domestic payment institution or a domestic electronic money institution, the Polish Financial Supervision Authority (KNF) may issue an opinion confirming the compliance of the entity’s activities with the new requirements.

Exceptions to the Entry into Force Date

It is worth noting that the short 14-day vacatio legis period does not apply to all provisions. The legislator indicated that selected points amending the Act on Payment Services (Article 7, points 2, 3, 6, and 7) will enter into force with a delay, specifically on January 9, 2027. The regulations taking effect next year relate to instant credit transfers in EUR.

Time to Adapt Your Business!

The dynamic entry into force of the amendment means that payment and electronic money institutions must act swiftly. The required descriptions of procedures, control mechanisms, and winding-up plans are complex documents that will be subject to strict verification.

We invite you to contact our law firm’s team. We will help you efficiently prepare the necessary documentation, submit a request to the KNF for an opinion, and confidently enter the new market reality.