Poland · EMI (krajowa instytucja pieniądza elektronicznego)

A white-label banking app for e-money institutions authorised by KNF

People in Poland pay online with a six-digit BLIK code and send zloty to a phone number without a second thought. A new e-money app is measured against those habits from the first login. We supply the branded apps, the e-money ledger and the back office, and help you write the IT chapters of your KNF file.

Case Studies

See what teams build with Crassula.

Digital Banking · EMI (krajowa instytucja pieniądza elektronicznego)

What a Polish EMI can put in front of customers

Zloty and euro in one app

Multi-currency e-money accounts, each with its own balance and history. Customers switch money between PLN and EUR at the rate you set in your price list.

Cards with your name on them

A virtual card appears at sign-up and can be turned into plastic later. Freezing, unfreezing and spending limits sit in the app, while the card contract stays between you and the issuer.

Accounts for sole traders and small companies

Business onboarding with director and beneficial owner checks through connected providers, several users per company and payment batches that wait for a second approval.

Euro transfers across Europe

SEPA and SEPA Instant for euro payments, so a customer can pay a supplier in Germany or receive a refund from Spain from the same app.

Goal pockets that earn nothing

Vaults where customers set money aside for a holiday or a tax bill. They stay e-money and are labelled that way, since an EMI cannot pay interest.

What this licence does not cover

  • Interest on balances or deposit-taking. E-money is redeemable at par and is not protected by the Bankowy Fundusz Gwarancyjny deposit guarantee.
  • Loans funded from the money customers hold with you.
  • BLIK on day one. BLIK is a separate scheme run by Polski Standard Płatności, and joining it is a project for you and your rails provider, not a platform switch.
Your market

What the regulator asks about your IT

Each requirement, what the platform gives you for it and who owns it after launch.

1A legal person with its registered office in Poland

Back office roles and permissions, so your Polish management board approves customers, limits and exceptions, with each action logged.

You
2Initial capital of at least the PLN equivalent of EUR 350,000

A plain list of the e-money and payment services the platform performs, so your business plan, capital and own funds work from the same scope.

You, with your lawyers
3Planned average e-money outstanding in the business plan, then monthly figures for KNF

Balance data per account and currency from the reporting endpoints, so the figures you report start from the ledger.

Your finance team
4Safeguarding of funds received for e-money, protected no later than the fifth business day

Customer balances kept on a ledger you reconcile against the segregated account, guarantee or insurance you choose, with exports for the daily check.

Your finance team
5Strong customer authentication for login and payments

Two-factor verification in the web and mobile apps for sign-in and payment confirmation.

Crassula
6Customer due diligence under the Polish AML Act of 1 March 2018

Onboarding questionnaires by client type, identity checks through connected providers and client limits. Screening and monitoring run in your connected tools.

Your AML officer
7DORA ICT risk framework and register of information

Architecture, hosting, subcontractor and exit details for your ICT policy and the register KNF expects.

You, with our input
8Application and correspondence with KNF in Polish

Technical descriptions of the platform in English, structured so your translator can turn them into Polish chapters.

You, with our input
Poland

Payment rails and providers

Rails your customers can use

SEPA Credit TransferSEPA InstantSWIFTPLN transfers through your settlement bank (Elixir, Express Elixir)Card paymentsInternal transfers
24/7real-time processing, no batch window
60+payment and provider integrations connected
150+companies run on Crassula
15+languages the platform speaks
Poland

Dates to plan around

Rules that change what you have to build, in the order they apply.

  1. 17 Jan 2025

    DORA applies to Polish EMIs. Your file should show where the app stack sits in your ICT risk framework and register of information.

  2. 9 Apr 2027

    Polish EMIs that offer euro credit transfers must be able to receive instant euro payments.

  3. 9 Jul 2027

    The same EMIs must also send instant euro payments and check the payee name before a euro transfer leaves. In the euro area, EMIs have had to check payee names since October 2025. Poland, outside the euro area, follows here.

  4. 9 Jun 2028

    Last day on which a Polish provider may hold back instant euro payments sent from zloty accounts outside business hours.

  5. Around 2028

    PSD3 and the Payment Services Regulation are expected to apply and to fold e-money institutions into the payment institution regime.

EMI (krajowa instytucja pieniądza elektronicznego)

Preparing an e-money application for KNF? Bring us in before you file.

KNF has three months to decide, counted from the day your application is complete. Each request for more documents pushes that date back, so the IT chapters need to be right the first time. We set up an environment and write those chapters with you.

Talk to us about your application

Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.

  1. 01

    A platform you can demonstrate

    A configured environment to show the regulator, not slides.

  2. 02

    The technical part of your application, prepared

    IT architecture, customer authentication, ICT risk and DORA register data, outsourcing and business continuity sections, ready for translation into Polish.

  3. 03

    Providers lined up

    Banking, safeguarding and KYC providers from our network, matched to your licence.

A customer checking her banking app in a café.
Digital Banking

A Warsaw launch, step by step

Picture a team building an account for people who moved to Poland for work. They are paid in zloty, keep savings in euro and send money to relatives elsewhere in the EU. The founders set up a Polish company, raise the capital and open their KNF file with a branded demo: a PLN and an EUR account, a virtual card and a SEPA Instant payment that lands in seconds.

While KNF reviews the file, the team tests onboarding in Polish and English, signs a safeguarding agreement with a Polish bank and agrees how zloty transfers will run through that bank. BLIK goes on the roadmap as a second phase, discussed with their rails provider once the licence is granted.

Background reading: the Poland KNF payment licensing guide and our overview of EMI licensing in the EU.

Poland · EMI (krajowa instytucja pieniądza elektronicznego)

FAQ

The questions teams ask us before a first call.

Not covered here?Bring your question to a demo with our team.
What does an e-money authorisation in Poland cost?
You need initial capital of at least the PLN equivalent of EUR 350,000. The Payment Services Act caps the authorisation fee at the PLN equivalent of EUR 1,500, and once authorised you pay an annual supervision contribution of up to 0.075% of your average e-money outstanding.
How long does KNF take to decide?
The Act gives KNF three months from the day it receives a complete application or the missing documents. KNF can ask for further information along the way, so the real timeline depends on how complete the first submission is.
Do we have to work with KNF in Polish?
Plan on it. Under the Polish Language Act, Polish is the official language of public bodies, so your application and correspondence should be in Polish. Our technical sections are written in English and laid out for a translator.
Is a full EMI the only way to issue e-money in Poland?
No. A national payment institution with at least EUR 125,000 of capital may issue e-money in Poland only, as long as its average e-money outstanding stays under EUR 5 million. A product that aims to grow or serve other EEA countries needs the full e-money authorisation.
Can customers pay with BLIK or to a phone number?
BLIK had more than 20 million active users and handled about 2.9 billion transactions in 2025, according to its operator, so customers will ask for it. The platform runs SEPA and SEPA Instant by IBAN, with zloty transfers through your settlement bank. BLIK and phone-number payments depend on your scheme and rails arrangements, and we scope that connection with you.
Do the instant payment rules cover zloty transfers?
No. The EU Instant Payments Regulation covers euro credit transfers only. Instant zloty payments run through Express Elixir, operated by KIR, and reaching it depends on your settlement bank.
Poland · EMI (krajowa instytucja pieniądza elektronicznego)

What a Polish EMI can put in front of customers

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