COREDO > 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. The country attracts international fintech companies thanks to its well-developed regulatory infrastructure, transparent legislation and full membership in the European Union. Obtaining a financial licence from the Polish regulator — Komisja Nadzoru Finansowego (KNF) — grants access to the EU market through the EU-passporting mechanism.

COREDO has been supporting clients in obtaining financial licences in Poland since 2016. We provide a full cycle of services: 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 60 000 EUR

Regulatory Framework: KNF and Key Directives

The financial sector regulator in Poland is Komisja Nadzoru Finansowego (KNF) — the Polish Financial Supervision Authority. 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.

Types of Financial Licences 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.

Advantages of Financial Licensing in Poland

Poland is an attractive jurisdiction for fintech companies for a number of key reasons.

Access to the EU market through EU-passporting.

A holder of a Polish NPI or EMI licence may provide services throughout the entire European Economic Area (EEA) through the notification-based passporting mechanism in accordance with Article 28 of PSD2. This means access to 30+ markets without obtaining separate licences.

Transparent and predictable legislation.

The Polish Act on Payment Services (Ustawa o usługach płatniczych) is a direct implementation of PSD2, which simplifies understanding of the requirements for foreign companies.

Developed fintech market.

Poland ranks among the top 5 fintech markets in CEE by the number of registered payment institutions. Warsaw is a recognised financial centre of the region.

Accessible SPI model for launch.

A Small Payment Institution does not require minimum capital and is registered within 2–3 months — an optimal option for a quick launch with subsequent upgrade to NPI.

Highly qualified talent pool.

Poland has a significant pool of specialists in finance, IT and law, which reduces the company’s operational costs.

EU and Schengen membership.

A Polish company operates within the single legal framework of the EU, has access to European payment systems (SEPA, TARGET2) and benefits from the protection of EU law.

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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.

Requirements for NPI (National Payment Institution) and EMI

To obtain an NPI or EMI licence from KNF, the following conditions must be met:

Legal form: a legal entity registered in Poland (typically spółka z o.o. or spółka akcyjna)
Share capital: for NPI — from EUR 20,000 to EUR 125,000 depending on the scope of services; for EMI — EUR 350,000
Business plan: a detailed plan for at least 3 years, including financial projections, marketing strategy and description of services
Internal control and risk management system: description of procedures for identifying and managing operational, credit and market risks
AML/CFT procedures: internal AML policy, appointment of an MLRO (Money Laundering Reporting Officer)
Management qualifications: executives must have an impeccable business reputation and professional experience in the financial sector
Technical infrastructure: evidence of compliance with strong customer authentication (SCA) requirements in accordance with PSD2 RTS
Civil liability insurance or bank guarantee to cover obligations to clients
Registered office and premises in Poland

According to the European Banking Authority (EBA), among all EU regulators KNF demonstrates the longest authorisation process — on average 20–24 months. This is due to high requirements for completeness of documentation.

Requirements for SPI (Small Payment Institution)

SPI is a simplified form of regulation for small payment services:

Legal form: a legal entity or entrepreneur registered in Poland
Minimum capital: none
Transaction limit: the average monthly volume over 12 months must not exceed EUR 1,500,000
Client account limit: no more than EUR 2,000 per client
Registration: application to KNF; review period — up to 3 months
Upgrade obligation: if the limit of EUR 1,500,000/month is exceeded, the company must apply for NPI within 30 days

SPI does not have EU-passporting rights and cannot provide services outside Poland. An upgrade to NPI is required for international 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

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

COREDO applies a milestone-based payment schedule tied to key project stages:

First payment

(30–40% of the total fee): payable after signing the contract and before work begins — covers structuring, legal expertise and documentation preparation

Second payment

(30–40%): payable upon submission of the application to KNF

Final payment

(20–30%): payable upon receipt of the positive decision from KNF

This structure reduces the client’s financial risks and ensures project transparency at every stage.

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)

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 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.

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.

EU-Passporting for Polish 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.

Our Experts

Financial licensing projects in Poland at COREDO are led by experienced lawyers with specialised expertise. COREDO has been operating in the legal and compliance services market since 2016. During this time, we have supported hundreds of projects in Poland and across the European Union.

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.

Basang Ungunov

Lawyer at COREDO. Specialises in financial law and regulatory compliance. Handles licensing projects in Poland and other EU jurisdictions.

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.

Submit Application

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

COREDO has been operating since 2016. We support clients at every stage — from selecting the structure to obtaining the KNF licence and launching passporting in the EEA.