COREDO > SPI Licence in Poland — Small Payment Institution

SPI Licence in Poland — Small Payment Institution

Poland is one of the most attractive fintech jurisdictions in Central and Eastern Europe, offering advanced digital infrastructure and transparent regulation of payment services. The Small Payment Institution (SPI) status allows companies to launch payment businesses in Poland through a simplified registration procedure without minimum share capital requirements, making it a popular solution for fintech startups and emerging projects.

Since 2016, COREDO has been assisting clients with SPI registration in Poland, providing full support — from preparing documentation to liaising with the KNF and launching operations.

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Cost of the service
from 60 000 EUR

Regulatory Framework

The activities of small payment institutions in Poland are regulated at two levels of legislation — European and national.

At the European Union level, the primary act is the Second Payment Services Directive PSD2 (Directive (EU) 2015/2366), which establishes uniform rules for payment institution activities across the EU. PSD2 defines the types of payment services, client fund protection requirements, and information security standards. The Directive was transposed into Polish national legislation through the Act on Payment Services (Ustawa o usługach płatniczych) of 19 August 2011, with subsequent amendments.

The national regulator is the Komisja Nadzoru Finansowego (KNF) — the Polish Financial Supervision Authority. KNF maintains the register of payment service providers and electronic money issuers, in which all registered SPIs are entered. The regulator also carries out ongoing supervision of small payment institution activities and monitors compliance with established limits. The official website of the regulator: knf.gov.pl.

An important change was the amendments to the Act on Payment Services that came into force on 29 September 2023, which tightened a number of requirements for SPIs, including those related to documentation and internal control procedures.

Advantages of Registering an SPI in Poland

Registering an SPI in Poland offers a number of significant advantages that make this format attractive for fintech companies at an early stage of development.

The absence of minimum share capital requirements

unlike an NPI, where the minimum capital ranges from EUR 20,000 to EUR 125,000 depending on the types of services provided, no such requirement is legally established for an SPI. This significantly lowers the barrier to market entry.

A simplified registration procedure

instead of obtaining a licence (zezwolenie), as in the case of an NPI, an SPI undergoes a registration (rejestracja) procedure in the KNF register. The registration process takes up to 3 months from the date of submission of a complete set of documents and is less formalised.

Low cost of entry

the state fee for registration is 616 PLN (approximately EUR 145), making an SPI the most budget-friendly option for entering the payment services market in the EU.

Scalability

an SPI can be used as a launchpad for a subsequent transition to an NPI licence, enabling expansion of activities across the entire European Union through the passporting mechanism. The company gains the opportunity to test its business model in real conditions, build a client base, and accumulate operational experience.

A developed fintech ecosystem in Poland

the country has one of the largest fintech ecosystems in the region, with over 380 active fintech companies as of 2025. This creates a favourable environment for partnerships, talent acquisition, and integration with existing payment infrastructure.

Transparent legislation

the Polish legal system is characterised by clarity and predictability, facilitating business operations and interaction with the regulator.

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Requirements for Obtaining SPI Status

To register as a Small Payment Institution, the applicant must meet a number of requirements established by the Act on Payment Services and KNF regulations.

Legal form:

the applicant may be a natural person, legal entity, or organisational unit without legal personality to which the law grants legal capacity. The company must be registered in the National Court Register (KRS) or the Central Register of Business Activity (CEIDG).

Management requirements:

persons managing the SPI must have an impeccable business reputation and no criminal record. Furthermore, managing persons must not have official ties to Russia or Belarus. At least some members of the management board must be proficient in the Polish language.

AML/CFT compliance:

an SPI is an obligated entity (instytucja obowiązana) under the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing. This means mandatory appointment of an AML/CFT compliance officer, implementation of customer identification procedures (KYC), transaction monitoring for suspicious activity, and document retention for 5 years.

Client fund protection:

the SPI is required to ensure adequate protection of client funds by holding them in a separate bank account or through insurance.

IT infrastructure and security:

the applicant must demonstrate adequate technical means and information security procedures for the protection of client data and operational continuity.

Cost of COREDO Services

Registration of a Small Payment Institution (SPI) in Poland

from EUR 60,000 + VAT

Preparation of the business plan and financial plan.
Development of internal policies and procedures (including AML/CFT).
Compilation of the complete document package for submission to KNF.
Communication with the regulator at all stages.
Advisory support until a positive decision is obtained.

SPI to NPI (National Payment Institution) upgrade

from EUR 180,000 + VAT

This transition removes the restrictions on transaction volume and territory of activity, opening access to the entire European Economic Area market through the passporting mechanism.

The cost depends on a number of factors, including the complexity of the client’s business model, the beneficial ownership structure, and the volume of documentation required.

Payment Terms

Payment for COREDO’s SPI registration services in Poland is made in stages according to a 40-40-20 scheme:

Stage 1 (40%) — advance payment upon signing the contract. After the first payment is made, the COREDO team begins work on document preparation and the business plan.

Stage 2 (40%) — payment upon submission of the document package to KNF. By this point, all necessary documents, policies, and procedures have been prepared, and the package is submitted to the regulator for review.

Stage 3 (20%) — payment upon receiving a positive decision from KNF and entry of the company into the register of payment service providers.

This payment structure allows the client to manage costs and provides mutual motivation for the successful completion of the project.

Comparison of SPI with Other Types of Payment Licences in Poland

When choosing a form of payment business in Poland, it is important to understand the differences between the available options. Below is a comparative table of SPI and NPI — the two main forms of payment institutions in the Polish jurisdiction.

Parameter	SPI (Small Payment Institution)	NPI (National Payment Institution)
Procedure	Registration in the KNF register	Licensing (zezwolenie) by KNF
Minimum capital	Not required	From EUR 20,000 to EUR 125,000
Transaction limit	EUR 1,500,000/month (12-month average)	No restrictions
Client fund limit	EUR 2,000 per client	No restrictions
Territory of activity	Poland only	EEA (passporting)
PIS/AIS services	No	Yes
Processing time	Up to 3 months	From 3 to 12 months
COREDO service cost	From EUR 60,000 + VAT	From EUR 180,000 + VAT

An SPI is the optimal choice for companies that are starting a payment business in Poland and operating with limited transaction volumes. As the business grows beyond the established limits, the company can transition to an NPI licence, which provides access to the entire European Economic Area market.

For more details on the National Payment Institution, see NPI Licence in Poland. A general overview of financial licensing in the country is available on the page Financial Licences in Poland.

Document Checklist for SPI Registration

To submit an application for registration as a Small Payment Institution with KNF, the following document package must be prepared:

Applicant details: company name, registered office address, KRS or CEIDG number, contact information, and a statement from the company representative confirming the completeness and accuracy of the information provided.

Business plan and financial plan: an activity programme describing the planned payment services and a financial plan for a period of at least 12 months, taking into account the established transaction limit of EUR 1,500,000 per month.

Organisational description: company structure, description of the management system, distribution of functions and responsibilities, information on the use of agents (if applicable).

Risk management procedures: risk management policy, internal control procedures, description of information security measures.

AML/CFT documentation: internal anti-money laundering and counter-terrorist financing procedure, customer identification policy (KYC), description of the transaction monitoring system.

Information on management and shareholders: personal data of board members and principal shareholders, documents confirming the absence of criminal records, information on business reputation.

Customer complaint handling rules: internal regulations for receiving and handling complaints from payment service users.

Client fund protection measures: mechanism for holding and protecting client funds (separate bank account or insurance).

Confirmation of state fee payment: receipt of payment of the stamp duty of 616 PLN to the Warsaw city administration.

All documents must be submitted in electronic form that allows content search. COREDO provides full preparation of the entire document package in accordance with KNF requirements.

SPI Registration Procedure

The process of registering a Small Payment Institution in Poland involves several sequential stages.

Preliminary consultation and business model analysis.

The COREDO team conducts a detailed analysis of the client’s planned activities, determines the range of necessary payment services, and assesses the business model’s compliance with SPI requirements. At this stage, the application preparation strategy is formulated.

01

Documentation preparation.

COREDO specialists develop the complete document package: business plan and financial plan, organisational description, internal policies and procedures (AML/CFT, risk management, data protection, complaint handling). In parallel, the applicant company is prepared for regulatory requirements.

02

Application submission to KNF.

The compiled document package is submitted in electronic form to the Financial Supervision Authority. The state fee is paid simultaneously. From the moment a complete application is submitted, KNF has 3 months to make a decision on registration.

03

Application review and communication with KNF.

During the review process, the regulator may request additional documents or clarifications. COREDO ensures prompt preparation of responses and maintains ongoing communication with KNF. If the application is found to be incomplete, KNF sets a deadline of at least 7 days for supplementation.

04

Registration and entry in the register.

After successful completion of the review, KNF enters the company in the register of payment service providers and electronic money issuers. From that moment, the SPI is entitled to begin providing payment services within Poland.

05

The overall process timeline is 3 to 6 months, including the documentation preparation stage.

Our Experts

SPI registration in Poland is supported by the leading specialists of COREDO’s legal team.

Pavel Kos

Head of Legal. Has been working at COREDO since 2017, heading the legal team since 2020. Specialises in financial institution licensing, including payment institutions in Poland and other EU jurisdictions. Possesses deep knowledge of Polish and European regulatory legislation.

Basang Ungunov

Lawyer. Has been working at COREDO since 2022. Holds a Master of Laws (LLM) degree. Participates in the preparation of licensing documentation, legal expertise, and client support in interactions with regulators.

Frequently Asked Questions

Is minimum share capital required for SPI registration in Poland?

No, Polish legislation does not establish minimum share capital requirements for Small Payment Institutions. This is one of the key differences between an SPI and an NPI, for which the minimum capital ranges from EUR 20,000 to EUR 125,000 depending on the types of services provided.

How long does SPI registration take?

KNF is required to review a complete application and make a registration decision within 3 months. Including the documentation preparation stage, the overall process takes from 3 to 6 months.

Can an SPI operate outside Poland?

No, an SPI is entitled to provide payment services only within Poland. To operate in other EEA countries, an NPI licence must be obtained, which grants passporting rights. COREDO offers SPI to NPI upgrade services.

What happens if the SPI exceeds the transaction limit?

If the average monthly transaction volume over the preceding 12 months exceeds the equivalent of EUR 1,500,000, the SPI is required to notify KNF within 30 days and submit an application for an NPI licence or adjust its scale of operations. The SPI may continue operating during the NPI application review period.

What payment services can an SPI provide?

An SPI is entitled to provide most payment services: maintaining payment accounts, transfers, direct debits, issuing payment instruments (cards, BLIK), merchant acquiring, and money remittances. The exceptions are payment initiation services (PIS) and account information services (AIS).

What is the difference between an SPI and an NPI?

An SPI differs from an NPI in several key parameters: no minimum share capital requirements, restriction on territory of activity (Poland only), limits on transaction volume and client funds, and a simplified registration procedure instead of full licensing. At the same time, an NPI provides access to the entire EEA market and has no operational restrictions.

Is the SPI required to comply with AML/CFT requirements?

Yes, an SPI is an obligated entity under the Polish Act on Counteracting Money Laundering and Terrorist Financing of 1 March 2018. This entails the appointment of an AML compliance officer, implementation of KYC procedures, transaction monitoring, and document retention for 5 years.

Can an SPI subsequently be converted to an NPI?

Yes, this is one of the strategic scenarios for using an SPI. A company can begin operations as a Small Payment Institution, build its client base and operational experience, and then submit an application for an NPI licence to expand its activities to the entire EEA market. COREDO offers a comprehensive SPI to NPI upgrade service starting from EUR 180,000 + VAT.

Get Started with COREDO

SPI registration in Poland is a fast and accessible way to enter the payment services market. The COREDO team provides full legal and regulatory support throughout the process — from business plan development and documentation preparation to communication with KNF and post-registration support. The company has been operating since 2016 and has extensive experience in interacting with the Polish regulator.