Digital Banking

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.

  • Branded web, iOS and Android apps
  • E-money accounts in PLN and EUR
  • Cards through the issuer you contract
  • Interface texts you edit per language
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Back-office dashboard with accounts and balances
Mobile banking app in your brand

Case Studies

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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.

Mobile banking app with a branded Visa card added to Apple Wallet
Mobile banking app home screen with balance, Add money and Send buttons

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.

What the regulator asks about your IT

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

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

You

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

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

Your finance team

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

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

Crassula

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

Your AML officer

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

You, with our input

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

You, with our input
Compliance documents card with created, sent, verification and accepted steps

Payment rails and providers

Rails your customers can use

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

Dates to plan around

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

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.

9 Apr 2027

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

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.

9 Jun 2028

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

Around 2028

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

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.

01

A platform you can demonstrate

A configured environment to show the regulator, not slides.

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.

03

Providers lined up

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

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.

Policy document prepared for a licence application
Card over euro, pound and dollar balances

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.

Read the licence guides

FAQ

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.

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.

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.

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.

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.

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.

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