Immigration law

Small payment institution – Government to introduce heavier regulation

The list of legislative works of Polish Government now indicates a novel to the Payment Services Act, to be implemented in third calendar quarter of 2020. The planned changes revolve around two basic subjects: increasing the level of regulation for small payment institutions (SPI / MIP) and decreasing the regulation for payment services bureaus (BUP).

Currently small payment institutions can perform all kinds of payment services except for the so-called open banking – namely: (i) PIS or initiating payment transactions in a third party payment services provider and (ii) AIS or providing access to information about an account in a third party payment services provider. There certain limitations regarding passporting, value of funds placed on account and monthly average value of payment transactions performed.

The planned changes concerning MIP / SPI entities are:

  1. obligation to report AML/CFT related information to KNF
  2. obligation to inform KNF about non-payment-services-related operations (hybrid MIP/SPI)
  3. extending the list of information / documents submitted to KNF when applying for MIP / SPI entry
  4. introducing (further?) limitation of transaction value, however no details are provided

We invite you to contact our Law Firm, which offers services such as:

  1. payment services,
  2. representation in front of KNF,
  3. obtaining the status of small payment institution (MIP / SPI),
  4. obtaining the national payment institution license (KIP),
  5. legal design of internal systems and bye-laws so that they comply with EBA and KNF guidelines.
Author team leader DKP Legal Piotr Putyra
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