Poland KNF Small Payment Institution (MIP) License in 2026
A 2026 deep dive into the Polish MIP regime: Small Payment Institution registration under KNF, EUR 1.5M monthly volume cap, EUR 2k per-client cap, 3-month review, PLN 616 fee, and the upgrade path to a full Payment Institution.
The Polish MIP: fast entry to CEE payments
The Komisja Nadzoru Finansowego (KNF) is the Polish Financial Supervision Authority. It licenses credit institutions, PIs, EMIs, investment firms, insurance and pensions. For payment services Poland operates two categories:
- Krajowa Instytucja Platnicza (KIP). The National (full) Payment Institution, corresponding to PSD2-authorised PI with EU passport.
- Mala Instytucja Platnicza (MIP). The Small Payment Institution, corresponding to PSD2 Article 32. Domestic-only, no EU passport, lighter file.
MIP is the most-used Polish payment licence, with hundreds of registrations since the regime opened. It is popular with Polish-market-only fintechs, BaaS projects, domestic wallet apps and SaaS monetisation products.
Let's discuss your project and see how we can launch your Polish payment product together
Request demoMIP thresholds and caps
These caps are tighter than the EU Article 32 norm (EUR 3M/month). Poland uses lower numbers to match the domestic market. Breaching either cap triggers an upgrade obligation to KIP (full PI).
Process, fees and timeline
- Incorporation. Polish sp. z o.o. (LLC) or SA (joint-stock). Registered office in Poland.
- File preparation. List of payment services, diagrams with service descriptions, organisational arrangements for tracking monthly volumes, business and financial plan for year one, description of non-payment activities.
- Filing fee. PLN 616 (indicative, around EUR 140).
- KNF review. Typically 3 months from a complete file. Real-world 3 to 5 months end-to-end.
- Ongoing supervision fee. Up to 0.025% of total transaction value, plus reports on volumes, AML and KYC.
A full KIP (Krajowa Instytucja Platnicza) file runs closer to the EU norm: EUR 20k/50k/125k capital, 3-month statutory clock, full EU passport, 6 to 12 months end-to-end in practice.
Substance and AML
- Management board. Polish corporate governance standard applies; at least one director with banking or fintech experience recommended.
- AML. Full Polish AML Act, MLRO appointed, risk-based transaction monitoring.
- Substance. Real Polish office, local operations, local AML officer.
Poland's MiCA transposition is currently blocked by a presidential veto of the Crypto-Asset Market Act (December 2025). For crypto services the Polish MiCA CASP pathway is not yet formally open in 2026, creating significant uncertainty for Polish crypto operators. Payment services under MIP/KIP are not affected.
Ship a Polish MIP product with Crassula
Crassula provides the domestic Polish payments core: ledger, Polish IBAN provisioning via partners, KYC and AML, safeguarding, KNF-ready reporting. The same platform scales to a full KIP application when the MIP cap approaches.
FAQ
EUR 1.5 million monthly average volume over the preceding 12 months, and EUR 2,000 total across all client accounts per client. Breach triggers an upgrade to full KIP.
Not under the payment-services law. Only the minimum share capital under the Polish Commercial Companies Code applies (PLN 5,000 for sp. z o.o., PLN 100,000 for SA).
3 months from a complete file statutory. Real-world 3 to 5 months end-to-end. Filing fee PLN 616.
No. MIP is domestic-only. For EU operations an upgrade to KIP (full PI) is required.
The Polish Crypto-Asset Market Act was vetoed in December 2025, leaving MiCA CASP authorisation pathway uncertain in 2026. Payments under MIP and KIP are unaffected.
Crassula provides the Polish payments core: ledger, Polish IBANs via partners, KYC and AML, safeguarding, KNF-ready reporting, and an upgrade path to full KIP.
