National Payment Institution

Only a legal person with its registered office in Poland that intends to carry out at least part of its activity here may become a KIP (Article 60 section 2 of the Polish Payment Services Act). The key conditions for obtaining the authorisation are:

• initial capital of at least EUR 125,000 (for most payment services), EUR 50,000 (only payment initiation services) or EUR 20,000 (only money remittance);
• a management board and supervisory board that meet the fit & proper criteria — adequate knowledge, experience and assurance of proper conduct of business;
• implemented AML/CFT, risk management and ICT security (DORA) procedures;
• a clear organisational structure with a defined split of responsibilities and a compliance function.

We help assess whether the entity meets the requirements and close any gaps before the application is filed.

The entire process consists of two stages:

• Preparation of the documentation — usually takes from 3 to 9 months, depending on the complexity of the business model and the availability of information on the client's side.
• Administrative proceedings before KNF — usually take from 2 to 4 years. KNF has a statutory 3 months to examine a complete application, but in practice it repeatedly requests further information, which suspends the running of the deadline.

The total time from the decision to apply for the licence until entry in the KIP register is usually 3 to 5 years. The schedule can be shortened by carefully preparing the application and communicating efficiently with KNF — we actively support our Clients at both of these stages.

Yes — a KIP is subject to the full supervisory regime. Unlike a small payment institution (limit of EUR 1.5 million monthly volume), a KIP can scale its activity without restrictions, but in return it must, among other things:

• file quarterly reports with KNF;
• file annual reports with NBP and the Financial Ombudsman;
• meet DORA requirements (digital resilience, ICT third-party management);
• maintain own funds at the required level and document their structure;
• keep AML/CFT procedures up to date on an ongoing basis and respond to KNF sector letters.

A properly designed organisational structure makes these burdens predictable and well manageable — which we take care of already at the pre-licensing stage.

The documents required to file an application for a KIP authorisation include, among others:

• Programme of operations — a description of the planned payment activity for 3 years, covering the business model, distribution channels and planned services;
• Financial plan — a forecast of the balance sheet, profit and loss account and financial ratios for 3 years;
• Risk management procedures — identification, measurement and control of operational, financial and regulatory risks;
• AML/CFT procedure — risk assessment, KYC rules, transaction monitoring and reporting to GIIF;
• Governance documentation — management board and supervisory board rules, description of the organisational structure, remuneration policies.

Depending on the business model, the application may require additional documents, e.g. on outsourcing, safeguarding of user funds, or hybrid activity. We prepare all the documentation on our side.

No — entry in the KIP register is only the beginning of regulatory obligations. The ongoing tasks of every KIP include, among others:

• reporting to KNF — quarterly and annual reports on payment activity;
• reporting to NBP — statistical data on payment services;
• reporting to the Financial Ombudsman — information on the number of complaints and how they were handled;
• updates of AML/CFT, risk management and ICT security (DORA) procedures — at least once a year or upon material regulatory changes;
• notifying changes to KNF — including changes in the scope of services, changes on the management board, acquisition of a significant block of shares;
• handling sector letters — KNF regularly sends KIPs letters requesting information or pointing out areas for improvement.

We support KIPs with all of these obligations as part of our ongoing service.

Yes — the act allows a KIP to carry out other business activity (a so-called hybrid payment institution, Article 74 of the Polish Payment Services Act). However, it is worth knowing that:

• KNF may order the payment activity to be carved out into a separate entity if the other activity endangers the protection of users or the stability of the institution (Article 68 of the act);
• the hybrid model requires a clear allocation of resources, risks and responsibilities between the payment activity and the rest of the business;
• a KIP may provide closely related ancillary services, e.g. currency exchange, safe-keeping of funds or operation of payment systems.

Each hybrid model requires careful design from a regulatory, operational and tax perspective — which we handle at the pre-licensing analysis stage.

Acquiring an existing KIP can be attractive when fast market entry is the priority — it allows you to skip the multi-year licensing process. It is, however, worth keeping in mind that:

• the buyer takes over the entity's regulatory history — including any past breaches, ongoing supervisory proceedings or irregularities identified by KNF;
• acquiring shares above a defined threshold requires prior notification to KNF (Article 72a of the act), and KNF may object;
• thorough legal, financial and regulatory due diligence is essential — review of AML procedures, the state of own funds and reporting history;
• after the acquisition, the procedures and organisational structure usually need to be adjusted to the new business model.

We carry out comprehensive due diligence and support the entire transaction process — from sourcing the target to notifying changes to KNF.

Yes — we serve National Payment Institutions from A to Z, also long after the authorisation is granted. Our post-implementation support covers, among other things:

• the first reports to KNF, NBP and the Financial Ombudsman;
• the response to the KNF sector letter, which newly registered KIPs typically receive shortly after entry in the register;
• updates of AML/CFT, DORA and risk management procedures in response to regulatory changes;
• ongoing consultations for Compliance and AML Officers — tough cases, operational decisions, reporting to GIIF;
• internal audits and compliance due diligence — verification of compliance with requirements and identification of gaps;
• representation before KNF in supervisory proceedings and correspondence with the authority;
• training for the team — both dedicated sessions and via our e-learning platform.