EMI license in Poland: e-money institution (EMI) requirements (2026)

President Karol Nawrocki vetoed a second legislative attempt (Bill 2064) to designate KNF as Poland's national competent authority under EU MiCA, arguing the bill threatened citizens' freedoms and state stability. Poland now risks losing the right to register crypto-asset service providers after the EU's 1 July 2026 deadline, making it the only EU member state without a functioning MiCA authority.

President Nawrocki vetoed the initial draft Act on the Crypto-Assets Market that would have transposed EU MiCA and appointed KNF as crypto-asset service provider overseer, creating a regulatory vacuum and forcing lawmakers to prepare a second bill. This was the first of two consecutive presidential vetoes blocking MiCA transposition.

The Act of 25 June 2025 amending financial-sector laws designated KNF as the competent authority for enforcing EU DORA (Regulation 2022/2554) in Poland, empowering it to issue binding orders, temporarily ban managers, and impose fines of up to PLN 20 million or 10% of annual revenue on non-compliant payment institutions, e-money firms, and other financial entities.

The Polish government published a new version of the draft Act on the Crypto-Assets Market via fintech.gov.pl to anchor EU MiCA into domestic law, specifying KNF licensing procedures, capital requirements, and conduct rules for crypto-asset service providers, this bill subsequently became the version vetoed in December 2025.

Amendments to the Consumer Credit Act introduced by the Anti-Usury Act (Dz.U. 2023 item 1028) took full effect, placing all registered fintech lenders and loan institutions under mandatory KNF supervision for the first time, with capital adequacy, reporting, and conduct requirements, a major expansion of the regulated fintech perimeter.

The Commission published paired proposals for Directive PSD3 and a directly applicable Payment Services Regulation, covering open banking enhancements, IBAN/name verification, strengthened fraud-liability rules, and streamlined payment-institution licensing. These proposals shape Poland's anticipated next payment-services legislative cycle.

The PSD2 Regulatory Technical Standards on Strong Customer Authentication became enforceable for Polish banks and payment institutions, mandating multi-factor authentication for online transactions and account access. This reshaped digital banking UX across Poland and compelled major investment in authentication infrastructure by all payment service providers.

Polski Standard Płatności (PSP), a consortium of PKO BP, Alior Bank, mBank, Bank Millennium, ING Bank Śląski, and BZ WBK/Santander, launched BLIK, a 6-digit-code instant mobile payment standard operating over existing banking infrastructure. BLIK became the dominant retail payment method in Poland, processing over 763 million transactions worth PLN 103 billion in 2022.

The Act of 19 August 2011 on Payment Services (Dz.U. 2011 No. 199 item 1175), transposing EU Directive 2007/64/EC, created the National Payment Institution (KIP) and E-Money Institution categories supervised by KNF, defined payment accounts and services, established consumer-protection and transparency obligations, and laid the regulatory bedrock for all subsequent fintech licensing in Poland.