What is Small Payment
Institution in Poland?

Small Payment Institutions (SPIs), also known as Mała Instytucja Płatnicza (abbreviated “MIP”), are authorized to conduct small and medium-sized payment services operations in Poland. Nearly all payment services are available through Polish SPI, but there are some restrictions. These include operating only within Poland, limiting each client account to 2,000 euros, and capping the average monthly value of all transactions at 1,500,000 euros.

No initial capital is needed, unless there are special circumstances specified by Polish regulations such the Commercial Companies Code.

MIP is capable of managing payment accounts, transferring money via wire transfers, issuing payment instruments, acquiring, and offering money remittance services. Account information services (AIS) and payment initiation services (PIS) are not included. Services are only available in Poland. The registration process takes about three months, though it can be prolonged to six or eight months if KNF has enquiries about the application.

No particular limitations on stockholders. Foreigners may also serve as directors.

Almost all payment services are available from small payment institutions in Poland, including: maintaining payment accounts (which include cash withdrawals and the storage of user funds); conducting wire transfers from the account; conducting direct debits; issuing payment instruments (such as cards, BLIK, and other instruments like mobile applications); acquiring (such as facilitating the acceptance of cards or mobile applications, BLIK); and offering money remittance services.

The following payment services related to open banking are prohibited for small payment institutions: accessing account information (AIS) and initiating payment transactions (PIS).

Despite offering a wide range of payment services, small payment institutions have certain restrictions, like:

• Restricted Territory: it can only offer services in Poland, which includes branches of small payment institutions.
• Limited Client Funds: A client may only hold 2,000 euros in total across all payment accounts held by a small payment institution.
• Transaction Limit: the total monthly average of all completed payment transactions over the previous 12 months, including those conducted through agents, cannot be more than 1,500,000 euros.

A small payment institution must either apply for a national payment institution licence or reduce the size of its payment services business to meet the limit if its monthly transactions exceed 1,500,000 euros within 30 days after the end of the period in which the overrun occurred.
If a small payment institution maintains payment accounts for its customers, it may hold for one client funds not exceeding the value of EUR 2,000.
A small payment institution, including agents, may not conduct more than EUR 1,500,000 in monthly transactions on average over the course of the last 12 months.

In Poland, small payment institutions are required to safeguard the funds they receive from clients under the following guidelines: • funds received for payment transactions cannot be mixed with funds held by small payment institutions on any other account at any point during storage; • funds received for payment transactions that have not yet been transferred to the recipient by the end of the business day after the day of receipt must be either (i) deposited in a bank account designated for this purpose or (ii) invested in low-risk, safe, and liquid assets and deposited in a separate account for this purpose.

• Registration of legal entity LLC in Poland
• Check of desired name for your potential SPI
• Communication with KNF (Komisja Nadzoru Finansowego) (Polish financial regulator for SPIs) from A to Z regarding your application
• Preparation of policies and financial and business plans for SPI application
• Virtual address for one year

Additionally, we can help with getting PESEL (Polish tax number) for the client or qualified electronic signature (QES) for extra fee.

Price/Fee: 15.000 EUR