Unjustified Removal of MIPs from the KNF Register – Our Law Firm’s Prompt Intervention Prevented Serious Consequences

On June 2, 2025, the Polish Financial Supervision Authority (KNF) published a statement announcing the removal of several small payment institutions (MIPs) from the official register.

The decisions were based on Article 142(1)(11) of the Payment Services Act, which provides that an institution may be removed from the register if it has not conducted payment activities for at least 12 consecutive months.

We also reported on the matter on our website here.  

During our review of the KNF’s announcement – and thanks to our continuous monitoring of the MIP register – our Fintech team quickly identified a serious irregularity. Among the institutions listed as removed were four companies that had been registered only a few months earlier and are under our firm’s ongoing regulatory supervision.

These entities include:

• NOTA sp. z o.o.
• GTXN POLAND sp. z o.o.
• NEXWAVEPAY sp. z o.o.
• BERGOPAY sp. z o.o.

However, according to applicable regulations, the grounds for removal due to inactivity can only apply after 12 months, which was clearly not the case for these companies.

Despite this, as of the date of the announcement – June 2 – the publicly available MIP register confirmed that the above companies had indeed been removed.

Our Law Firm Response and Prompt Correction by the KNF

Given our detailed knowledge of the registration timelines and the operational launch stages of our clients, we were certain that none of the companies in question had remained inactive for 12 months, contrary to what was implied in the KNF’s justification. Accordingly, the legal basis cited by the Authority was not applicable in this case.

We therefore immediately submitted a formal request to the Parallel Banking Department of the KNF, seeking urgent clarification and verification of the affected data.

That same day, the KNF responded, confirming that the removals had been the result of a technical error. The entries for our four clients were immediately reinstated in the register.

Register Monitoring and Swift Action – Key to Protecting MIP Interests

This case highlights the importance of ongoing regulatory monitoring and effective communication with supervisory authorities, especially in situations requiring a prompt response.

Without our law firm’s immediate intervention, the unjustified removals could have led to serious reputational and business risks for the affected institutions.

Once again, this incident underscores the need for supervised entities to engage experienced legal counsel and ensure that their status in public registers is continuously monitored.

If your institution needs support, please feel free to contact our Fintech team.