SPI vs API in Poland - Which License Fits Your Fintech?

Why the SPI vs API decision is so important

For any foreign fintech planning to launch or scale payment services in Poland, the choice between a Small Payment Institution (SPI, in Polish: Mała Instytucja Płatnicza – MIP) and an Authorised Payment Institution (API / National Payment Institution – KIP) will determine your regulatory burden, time-to-market and long-term scalability.

Under the Polish Payment Services Act implementing PSD2, SPI and API are two distinct regimes with different limits on transaction volume, territorial reach, capital, internal governance and documentation.

For many founders, SPI is the most efficient way to test the Polish market, while API is the natural choice for building a pan-European payment platform with open-banking functionality and no hard transaction caps.

Small Payment Institution in Poland – quick snapshot for investors

A Small Payment Institution in Poland is a regulated entity that can provide almost the full catalogue of payment services (account keeping, transfers, card payments, acquiring, money remittance) but subject to strict quantitative and territorial limitations.

SPI can be operated in a very flexible legal form, including a limited liability company, joint-stock company or even sole trader, with no specific minimum initial capital beyond general company-law thresholds.

In practice, SPI is popular among start-ups and smaller providers – there are significantly more SPIs than fully authorised payment institutions on the Polish market, which reflects its role as a regulatory “sandbox” for smaller or earlier-stage businesses.

Key Small Payment Institution parameters

• The SPI can provide most standard payment services: maintaining payment accounts, executing transfer orders (including card and mobile payments such as BLIK), issuing payment instruments, acquiring and money remittance.
• Small Payment Institution cannot provide open-banking services such as Payment Initiation Services (PIS) or Account Information Services (AIS), which remain reserved for fully authorised institutions under PSD2.
• SPI can only operate within Poland, including via branches – there is no EU passporting of this license.
• Average monthly value of payment transactions for the previous 12 months must not exceed EUR 1,500,000, including transactions executed via agents.
• Funds held for any single user across all accounts must not exceed EUR 2,000, which materially constrains the business model for wallet-type solutions.

If an SPI exceeds the EUR 1,500,000 monthly average and cannot reduce volumes, it is obliged either to scale back or to transition to an API license within a short period, which requires careful planning of growth scenarios.

What is an Authorised Payment Institution (API) in Poland?

An Authorised Payment Institution (API / KIP) is a fully licensed payment institution under PSD2, subject to significantly higher prudential and governance standards but also enjoying much broader operational freedom.

Unlike SPI, API is not limited by a statutory monthly transaction cap nor by a per-client funds threshold, making it suitable for high-volume and scale-up models (e.g. B2B payment platforms, embedded payments, global merchant acquiring).

API must be established in a more robust corporate form (typically a limited liability or joint-stock company) and meet minimum initial capital requirements ranging from EUR 20,000 to EUR 125,000 depending on the services offered, mirroring PSD2 standards.

Crucially, API can provide open-banking services (PIS and AIS) and – once authorised in Poland – can usually passport its license across the EEA, unlocking a broader European strategy beyond the Polish market.

In practice, the licensing timeline for API is substantially longer than for SPI: obtaining a KIP license often takes around 1-1.5 years and requires extensive documentation on governance, risk, safeguarding and IT security.

SPI vs API at a glance – practical comparison

4.1. Services and open banking

From a product-design perspective, the most visible distinction is the ability to offer open-banking services under PSD2.

• SPI can provide core payment services (account keeping, direct debits, card payments, transfers, money remittance, issuing instruments, acquiring) but does not have access to PIS or AIS.
• API can provide the same core services and additionally PIS and AIS, enabling account-to-account payments and multi-bank aggregation tools central to many digital banking-like platforms.

For fintechs building open-banking or data-driven products, SPI’s lack of PIS/AIS is typically a deal-breaker and pushes them toward the API path from day one.

4.2. Territory and scalability

SPI is structurally designed as a local license, whereas API is a vehicle for pan-European expansion.

• SPI may only provide payment services on the territory of Poland, including through branches or agents.
• API, once authorised in one EU Member State and notified, can typically operate across the EEA via passporting, which is a key difference for investors planning a regional strategy.

As a result, SPI is best aligned with market-test or Poland-focused models, while API is the natural target for businesses aiming at multi-jurisdictional coverage from the outset.

4.3. Transaction and funds limits

SPI’s transaction and client-funds thresholds are hard legal caps and directly constrain your business plan.

• SPI:
  • average monthly value of all payment transactions (12-month look-back) ≤ EUR 1,500,000, and
  • funds held for one client across all accounts ≤ EUR 2,000.
• API:
  • no statutory transaction cap, and
  • no equivalent per-client limit, subject instead to general safeguarding and own-fund requirements.

Once your projections show that monthly volumes will consistently exceed the SPI cap, it is generally safer to plan for API from day one or, at least, to build a clear roadmap for transition.

4.4. Capital and governance

From a governance and prudential standpoint, API is much more demanding than SPI.

• Small Payment Institution:
  • no dedicated minimum initial capital beyond company-law thresholds (e.g. PLN 5,000 for a limited liability company), except where the SPI also grants consumer loans;
  • board members must have a clean criminal record, but KNF does not formally assess their experience and education at the Small Payment Institution stage.
• API:
  • minimum initial capital typically in the EUR 20,000-125,000 range, depending on the services provided;
  • KNF will normally look more closely at board experience, time commitment and risk-management capabilities, in line with PSD2 and general supervisory practice.

Both SPI and API must have an AML/CFT compliance function, but for SPI the regime is somewhat lighter and, in narrowly defined cases, certain functions can be allocated to senior management instead of a separate officer.

4.5. Documentation, supervision and timing

Even though Small Payment Institution is a “lighter” license, KNF still expects solid documentation and realistic business and financial plans.

• SPI registration:
  • application on KNF’s dedicated form;
  • business and financial plan for the first 12 months;
  • internal procedures (risk management, AML, incident and complaint handling, safeguarding, information-flow diagrams);
  • fixed stamp-duty fee of PLN 616 plus ongoing supervision fee up to 0.025% of annual transaction value.
• API authorisation:
  • far more extensive policies, governance documentation and IT/security materials;
  • proportionately higher internal costs of preparation and dialogue with KNF;
  • application fee equal to the PLN equivalent of EUR 1,250;
  • typical timeline around 1-1.5 years from complete file to decision.

In our experience, a well-prepared SPI file can be processed in roughly three months, with the fastest cases finalised within 3-4 weeks, while API remains a strategic, long-term project.

When is SPI the right choice?

SPI is typically the better fit when you need speed to market and your business model comfortably fits within SPI thresholds.

Common Small Payment Institution use cases include:

• Local or Poland-first payment products, where your initial focus is on acquiring Polish merchants or consumers.
• Start-ups validating a payment or wallet concept before raising capital for full authorisation and EEA scale-up.
• Businesses for which payment services are ancillary to a core non-financial activity (hybrid SPIs), such as platforms adding payment processing to an existing e-commerce or SaaS offering.
• Early-stage crypto-related businesses that combine SPI with VASP registration or a future CASP license, where payment flows are still relatively limited in size.

Small Payment Institution makes particular sense if your investors value regulatory learning: it allows your team to work under KNF supervision, build internal compliance culture and understand local expectations before committing to the heavier API track.

When is the API a better fit?

For many internationally backed projects, API is the end-state license, and the main strategic question is whether to go there directly or via an SPI “bridge”.

Going straight for API is often justified when:

• Your business model depends on open-banking (PIS/AIS) functionality, data aggregation or account-to-account payment flows.
• You expect to cross the SPI transaction cap very quickly, e.g. due to large enterprise contracts or high-volume B2B flows.
• Poland is your operational hub, but your strategy is inherently pan-European, relying on passporting to other EEA markets.
• Your investor profile (e.g. regulated financial sponsors or more conservative institutional investors) favours a single, long-term license rather than a two-step SPI→API path.

In such cases, it is often better to design governance, capitalisation and systems with the API end-state in mind, even if you initially consider a temporary Small Payment Institution to generate early traction.

Small Payment Institution → Authorised Payment Institution migration – planning the transition

Polish law allows SPI to apply for an API license at any time, not only when the statutory Small Payment Institution thresholds are breached.

A well-structured migration roadmap typically covers:

• strengthening the management board profile and board composition (including Polish-speaking members and risk-focused roles);
• upgrading internal control, risk management and compliance frameworks to API standards;
• aligning IT, safeguarding arrangements and outsourcing/cloud structures with KNF expectations for fully authorised institutions;
• planning capital injections, shareholder structure and source-of-funds documentation ahead of the API filing.

In recent years, our team has supported transitions from SPI to API under the tightened post-2023 regime, including the first Small Payment Institution license registered under the amended rules, which provides practical insight into KNF’s evolving approach.

Payment, crypto and MiCA – combining SPI/API with VASP and CASP

Many modern business models combine payment services and crypto-assets, which means that an SPI or API license is only part of the regulatory puzzle.

Until MiCA is fully in force, crypto exchanges and similar providers in Poland have generally operated under a VASP registration regime, which is significantly lighter than full licence-based systems but is progressively being replaced by the CASP framework.

MiCA will replace national VASP registrations with CASP licenses, imposing more stringent requirements on governance, capital, AML and disclosure – and requiring payment-crypto combos to synchronise their licensing strategy across both payments and crypto pillars.

For foreign investors, this makes Poland an attractive yet increasingly sophisticated hub: you can combine fast market entry via Small Payment Institution with a forward-looking plan for API and CASP, aligning your structure with EU-wide standards from the outset.

Supervisory environment – KNF’s role and expectations

Both SPI and API operate under the oversight of the Polish Financial Supervision Authority (KNF), which has a broad toolkit of supervisory and enforcement powers.

KNF can issue recommendations, impose financial penalties, request dismissal of managers or, in extreme cases, prohibit the institution from continuing its activity and order deletion from the relevant register.

SPIs must pay an annual supervision fee based on the value of payment transactions for the previous year, subject to a statutory ceiling of 0.025%, and may be refused registration or removed from the register if they breach legal requirements or provide incomplete or misleading information.

In assessing shareholders and senior management, KNF pays particular attention to any links with Russia or Belarus, which may trigger refusal of registration or later intervention under existing post-2022 policies.

How we can help – Small Payment Institution vs Authorised Payment Institution in Poland for your fintech

Choosing between Small Payment Institution and API is ultimately a strategic decision driven by your product scope, growth ambitions and investor expectations.

Our FinTech & Financial Regulation team advises foreign founders and investors across the full spectrum of Polish and EU payment and crypto regulation, from SPI/API design and licensing to VASP/CASP and MiCA – driven restructuring.

If you want to stay current on Polish and EU fintech developments, consider subscribing to our dedicated Fintech Newsletter, which regularly covers SPI/API, PSD2, MiCA and related regulatory changes.

For tailored advice on whether your business is better served by an Small Payment Institution launch or an immediate API application – and how to integrate payment and crypto licensing into a single scalable structure – you can reach our team directly via the contact details provided on our Fintech in Poland and Banking & FinTech practice pages.