COREDO > Licensing > Financial Licences in the EU > Financial Licence in Poland: Obtaining Through KNF

Financial Licence in Poland: Obtaining Through KNF

Poland is one of the largest financial markets in Central and Eastern Europe. Obtaining a financial licence from the Polish regulator — Komisja Nadzoru Finansowego (KNF) — grants access to the EU market through the EU-passporting mechanism.

Since 2016, COREDO has supported clients in obtaining financial licences in Poland with a full cycle: from selecting the licence type and structuring the company to liaising with KNF and ensuring AML compliance.

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Cost of the service
from EUR 60,000

Regulatory Framework: KNF and Key Directives

The financial sector regulator in Poland is Komisja Nadzoru Finansowego (KNF) — the Polish Financial Supervision Authority (knf.gov.pl). It carries out licensing and supervision of banks, payment institutions, electronic money institutions, investment firms, insurance companies and pension funds.

Polish legislation has implemented the key EU directives in the financial services sector:

PSD2 (Directive (EU) 2015/2366 on payment services) — entered into force in Poland on 20 June 2018. It regulates the activities of national payment institutions (NPI/KIP) and small payment institutions (SPI/MIP).
EMD2 (Directive 2009/110/EC on electronic money institutions) — the basis for EMI licensing in the EU; minimum share capital of EUR 350,000.
MiFID II (Directive 2014/65/EU) — regulates investment activities, brokerage services and asset management.
CRD IV (Directive 2013/36/EU) — regulates banking activities; minimum initial capital of EUR 5,000,000.
MiCA (Regulation (EU) 2023/1114) — regulates CASP activities (crypto-assets); fully applicable from 30 December 2024.
AMLR (Regulation (EU) 2024/1624) — a single rulebook for AML/CFT, applicable from 10 July 2027.

KNF is a member of the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA), ensuring uniform application of EU regulatory standards.

Comparison of Financial Licence Types in Poland

Poland offers a wide range of regulated financial licences. Each type is intended for a specific category of financial services and has its own requirements for capital, structure and the acquisition process.

Licence Type	Abbreviation (PL)	Regulator	Min. Capital	Timeline
Electronic Money Institution	EMI / KIP (EMI)	KNF	EUR 350,000	12–24 months
National Payment Institution	NPI / KIP	KNF	EUR 20,000–EUR 125,000	12–24 months
Small Payment Institution	SPI / MIP	KNF	No requirement	2–3 months
Bank	Bank	KNF (KNF + NBP)	EUR 5,000,000	18–36 months
Broker / Investment Firm	Dom Maklerski	KNF	EUR 50,000–EUR 730,000	12–18 months
Fund Management Company	TFI	KNF	EUR 125,000–EUR 300,000	12–18 months
Insurance Company	Zakład ubezpieczeń	KNF	EUR 2,500,000–EUR 3,700,000	18–36 months

COREDO specialises in obtaining licences for payment institutions (NPI, SPI, EMI) — the most in-demand in the fintech and international payment services sector.

Requirements for Obtaining a Financial Licence

Requirements vary depending on the licence type. Below are the requirements for the most in-demand types — NPI/EMI and SPI.

NPI/EMI: legal form and office
A legal entity registered in Poland (typically spółka z o.o. or spółka akcyjna), with a registered office and premises in Poland.

NPI/EMI: share capital
For NPI — from EUR 20,000 to EUR 125,000 depending on the scope of services; for EMI — EUR 350,000.

NPI/EMI: business plan
A detailed plan for at least 3 years, including financial projections, marketing strategy and description of services.

NPI/EMI: risk management and AML/CFT
Procedures for identifying and managing operational, credit and market risks, an internal AML policy and the appointment of an MLRO (Money Laundering Reporting Officer).

NPI/EMI: management qualifications
Executives must have an impeccable business reputation and professional experience in the financial sector.

NPI/EMI: technology and insurance
Evidence of compliance with strong customer authentication (SCA) requirements in accordance with PSD2 RTS, and civil liability insurance or a bank guarantee to cover obligations to clients.

SPI: form, capital and registration
SPI is a simplified form of regulation for small payment services: a legal entity or entrepreneur registered in Poland, with no minimum capital. The application is filed with KNF; the review period is up to 3 months.

SPI: limits and upgrade
The average monthly volume over 12 months must not exceed EUR 1,500,000, and a client account may hold no more than EUR 2,000. If the limit of EUR 1,500,000/month is exceeded, the company must apply for NPI within 30 days.

According to the European Banking Authority (EBA), among all EU regulators KNF demonstrates the longest authorisation process for NPI and EMI — on average 20–24 months. This is due to high requirements for completeness of documentation. SPI does not have EU-passporting rights and cannot provide services outside Poland. An upgrade to NPI is required for international operations.

Licence Acquisition Procedure

The process of obtaining a financial licence in Poland includes several key stages.

Consultation and structure selection (1–4 weeks)

COREDO conducts a detailed analysis of the client’s business model, determines the optimal licence type (SPI, NPI or EMI) and the structure of the Polish legal entity. At this stage, the project strategy and preliminary documentation plan are developed.

01

Company registration (2–4 weeks)

Incorporation of a Polish company (sp. z o.o. or S.A.) in the Krajowy Rejestr Sądowy (KRS), opening a corporate bank account, formation of share capital.

02

Documentation preparation (2–4 months)

Development of the business plan, financial projections, internal policies (AML/CFT, risk management, internal control, SCA), collection of documents on directors and shareholders. COREDO ensures the development of all documentation in accordance with KNF requirements.

03

Application submission to KNF

Submission of the complete document package to KNF. The application is submitted in written form through the KNF reception office or via the regulator’s official portal.

04

KNF review (9–24 months)

KNF reviews the application, sends requests for additional documents or clarifications. COREDO promptly responds to all queries and represents the client’s interests before the regulator.

05

Licence issuance

Following a positive decision by KNF, the company is entered into the register of payment institutions. From this point, the company is authorised to carry out licensed activities, including submitting passporting notifications to other EEA countries.

06

For SPI the procedure is simplified: submission of a registration application to KNF, review period — up to 3 months.

Licence Details: EU Passporting of Polish NPI and EMI Licences

One of the key advantages of a Polish NPI/EMI licence is access to the EU-passporting mechanism.

Licence Type	Legal Basis	What It Provides
NPI passporting	PSD2, Art. 28	Notification to KNF → host country regulator; services across the entire EEA
EMI passporting	EMD2, Art. 3 + PSD2, Art. 28	Issuance of electronic money and payment services in the EEA without additional licences

Passporting is carried out through KNF: the licensed company submits a notification, KNF forwards it to the host state regulator, after which the company may commence operations.

COREDO Service Fees

COREDO provides a full range of services for obtaining financial licences in Poland. Service fees are determined by the type and complexity of the licence.

COREDO Service	Fee
NPI/EMI licence (from scratch)	from EUR 180,000 + VAT
New SPI + upgrade to NPI/EMI	from EUR 60,000 + upgrade EUR 180,000 + VAT
Ready-made SPI + upgrade to NPI/EMI	from EUR 180,000 (upgrade) + VAT
SPI separately	from EUR 60,000 + VAT

The SPI package includes registration of a Sp. z o.o. with the minimum share capital and registration of the beneficial owners in the CRBR register. It also covers preparation of the SPI application documents, submission of the application and support of the licensing process with KNF.
Note: COREDO service fees do not include share capital, government fees and KNF charges, or corporate account opening costs. All prices are quoted excluding VAT.

Payment Terms

The payment schedule is set in the service agreement.

Minimum Regulatory Capital

Regulatory capital amounts are established by EU directives and are mandatory — they are not included in COREDO service fees and must be deposited into the company’s account separately.

Licence Type	Min. Regulatory Capital	Legal Basis
EMI	EUR 350,000	EMD2 (2009/110/EC), Art. 4
NPI (money transfers)	EUR 20,000	PSD2 (2015/2366), Art. 7(a)
NPI (payment initiation)	EUR 50,000	PSD2 (2015/2366), Art. 7(b)
NPI (full range)	EUR 125,000	PSD2 (2015/2366), Art. 7(c)
SPI	No requirement	—
Bank	EUR 5,000,000	CRD IV (2013/36/EU), Art. 12
Investment firm (broker)	from EUR 50,000	MiFID II (2014/65/EU)

Comparison with Other Jurisdictions

Here is how Poland compares with other jurisdictions on the points that most often decide where to apply.

Criterion	Poland	Compared with other jurisdictions
Market	Warsaw is a recognised financial centre of the region	One of the largest financial markets in Central and Eastern Europe and among the top 5 CEE fintech markets by number of registered payment institutions
Authorisation time for NPI and EMI	Long, because KNF sets high requirements for the completeness of documentation	According to the EBA, KNF has the longest authorisation process among EU regulators
EU passporting	A holder of a Polish NPI or EMI licence may provide services throughout the EEA through the notification-based passporting mechanism under Article 28 of PSD2	Access to 30+ markets without obtaining separate licences
Legislation	The Polish Act on Payment Services (Ustawa o usługach płatniczych) is a direct implementation of PSD2	Transparent and predictable rules simplify understanding of the requirements for foreign companies
Talent pool	A significant pool of specialists in finance, IT and law	Reduces the company’s operational costs
EU and Schengen membership	A Polish company operates within the single legal framework of the EU	Access to European payment systems (SEPA, TARGET2) and the protection of EU law

For a quick start, a Small Payment Institution needs no minimum capital and is registered within 2–3 months, with a later upgrade to NPI.

Required Documents

The following document package is required to submit an NPI/EMI licence application to KNF:

Company charter and incorporation documents

Business plan for at least 3 years with financial projections and marketing strategy

Financial plan with budget forecasts

Documents confirming the availability of share capital

Description of the organisational structure and corporate governance

Identification data of directors, shareholders (including UBO) and information on their reputation

Description of the risk management and internal control system

Internal AML/CFT policy and KYC/KYB procedures

Evidence of technical capabilities (SCA, IT infrastructure)

Civil liability insurance policy or bank guarantee

Office lease agreement in Poland

Criminal record clearance certificates for directors

Documents prepared in foreign languages must be translated into Polish and notarised.

Advantages of Working with COREDO

Focus on payment institutions

COREDO specialises in licences for payment institutions — NPI, SPI and EMI, the most in-demand types in fintech and international payment services.

Full cycle from company to licence

COREDO registers the Sp. z o.o., records the beneficial owners in the CRBR register, prepares the documents, submits the application and supports the licensing process with KNF.

Documents and dialogue with KNF

COREDO develops all documentation in accordance with KNF requirements, responds promptly to the regulator’s queries and represents the client’s interests before KNF.

A path from SPI to NPI or EMI

COREDO helps choose the optimal path for the client’s business model: a quick start with SPI and a later upgrade to NPI or EMI for operations in the EEA.

Experienced team

Projects are led by experienced lawyers specialising in financial licensing, corporate law and compliance, up to the launch of passporting in the EEA.

Contact us

Our Experts

Financial licensing projects in Poland at COREDO are led by experienced lawyers with specialised expertise.

Pavel Kos

Head of Legal at COREDO. Specialises in financial licensing, corporate law and compliance. Has been with COREDO since 2017, heading the legal team since 2020.

Alena Mach

Executive Director

Nikita Veremeev

Founder & NED

Gregory Lutsenko

Head of Compliance

Frequently Asked Questions

Which licence type is suitable for launching a payment service in Poland?

For a quick start, SPI is optimal (registration within 2–3 months, no capital requirement, limit of EUR 1.5 million/month). For international operations and scaling, NPI or EMI is required — they grant EU-passporting rights. COREDO helps choose the optimal path based on the client’s business model.

How long does it take to obtain an NPI licence in Poland?

According to EBA data, KNF is among the regulators with the longest review periods — on average 9–24 months. The timeline depends on the completeness of the submitted documentation and the regulator’s workload. SPI registration is significantly faster — up to 3 months.

Is it possible to start with SPI and then upgrade to NPI?

Yes, this is a classic strategy for the Polish market. SPI allows you to quickly launch a payment service in Poland, test the business model and then upgrade to NPI upon reaching the EUR 1.5 million/month limit or when there is a need to enter EEA markets.

Is a physical presence in Poland required?

Yes, KNF requires that the company be registered and have a real operational office in Poland. The physical presence requirement helps KNF to exercise supervision and interact with company management.

Can a foreign citizen serve as director of a Polish financial company?

Yes, foreign citizens may hold executive positions. However, they must meet KNF requirements for qualifications, reputation and professional experience in the financial sector.

What happens if SPI exceeds the EUR 1.5 million/month limit?

Within 30 days of exceeding the limit, the company must apply for NPI with KNF. Until obtaining the NPI licence, the company may continue operating under the SPI regime but must immediately initiate the upgrade.

Does a Polish NPI licence extend to other EU countries?

Yes, through the EU-passporting mechanism under PSD2 (Art. 28), a Polish NPI may provide services in all 30 EEA countries — via a notification procedure through KNF without obtaining separate licences in each country.

What is the KNF government fee for reviewing an NPI application?

The KNF government fee for reviewing an NPI/EMI application is PLN 616 (stamp duty). This is an administrative charge unrelated to COREDO service fees.

Get a Consultation on Financial Licensing in Poland

Ready to start a financial licensing project in Poland? COREDO specialists will provide a consultation, assess your business model and propose an optimal licensing strategy.

We support clients at every stage — from selecting the structure to obtaining the KNF licence and launching passporting in the EEA.

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