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 and e-money services Poland has three licence types:
- 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.
- Krajowa instytucja pieniądza elektronicznego (national EMI). The e-money institution authorised by KNF, with initial capital of at least the PLN equivalent of EUR 350,000. It issues e-money and provides payment services with an EU passport.
MIP is the lightest Polish payment licence. It suits Polish-market-only fintechs, BaaS projects, domestic wallet apps and SaaS monetisation products.
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MIP 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 depending on the services, a 3-month statutory clock from a complete file and a full EU passport. KNF charges the PLN equivalent of EUR 1,250 when it grants the authorisation. A KIP with at least EUR 125,000 of capital may also issue e-money, in Poland only, as long as average e-money outstanding stays under EUR 5 million (art. 73a of the Payment Services Act). Above that you need a national EMI authorisation.
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 still has no national law implementing MiCA. The President vetoed the crypto-asset market bill three times (December 2025, February 2026 and June 2026), and in September 2026 the Sejm failed to override the third veto. MiCA itself applies directly, but as of October 2026 Poland has no designated national competent authority for crypto-asset service providers, so there is no Polish CASP authorisation to apply for. The MiCA transitional period for existing crypto providers (Article 143(3)) ended on 1 July 2026 at the latest. Payment services under MIP/KIP are not affected.
Ship a Polish MIP product with Crassula
Crassula provides the technology for a domestic Polish payment product: ledger, accounts with Polish IBANs through connected providers, KYC through integrated identity providers, transfers, client limits and price lists. KNF reporting, AML and safeguarding stay with your compliance team. The same platform carries over 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.
Poland has no national MiCA implementing law yet. The President vetoed the crypto-asset market bill in December 2025, February 2026 and June 2026, and no national competent authority for CASPs has been designated, so a Polish CASP authorisation is not available as of October 2026. Payments under MIP and KIP are unaffected.
Crassula provides the technology: ledger, Polish IBANs through connected providers, KYC through integrated identity providers, transfers and price lists, with the same platform carrying over when you upgrade to a full KIP. Reporting to KNF and AML stay with your team.
