Banking & Fintech /

Small Payment Institution in Poland

On June 20th, 2018 new regulations of Polish act on payment services enter into force. The amendment introduces to sector of payments services in Poland new entity – small payment institution. Conducting business activity as a small payment institution is considered by the provisions of law as regulated activity. Therefore it requires appropriate license and approval issued by the Polish Financial Supervisory Authority (KNF).

Small payment institution

The small payment institution is an entity entered to the appropriate register, which provides at least one of services listed below:

  • accepting cash deposits and withdrawing cash from a payment account and exercising all activities necessary to conduct an account,
  • execution of payment transactions though i.a. direct debit, using a payment card or performing credit transfer services,
  • execution the payment transactions mentioned above in cash owed to the user due to the loan,
  • issuing payment instruments,
  • enabling acceptance of payment instruments,
  • providing a money transfer service,

while such entity does not provide the service within the scope of initiating a payment transaction, nor also the service related to the access to the account. As a result, the scope of services provided by a small payment institution is very similar to the scope of services of national payment institution (KIP).


An entrepreneur can conduct its business activity as a small payment institution only within the territory of Republic of Poland. Moreover, the total average amount of payment transactions from recent 12 months executed by small payment institution shall not exceed the amount of EUR 1,500,000 monthly. This amount contains also the amounts of transactions executed by small payment institution through its agents.

Entry to the register

Conducting business activity as a small payment institution requires entry to the appropriate register. The entry is made upon previous request submitted in writing and supplemented with specified documents. Request shall be submitted by an entrepreneur, who is going to obtain status of small payment institution. The activity of small payment institutions is supervised by KNF. It should be noted, that the procedure of obtaining an entry to the register of a small payment institution is much more simple than the procedure of obtaining the status of National Payment Institution (KIP) and lasts from 3 to 6 months. The small payment institution can be easily transformed to national payment institution.

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Author team leader DKP Legal Piotr Putyra
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