Digital Payments & Fintech - Poland

The KNF (Komisja Nadzoru Finansowego) supervises the payment-services market under the Act of 19 August 2011 on Payment Services, which transposed PSD2 (Directive (EU) 2015/2366); NBP oversees payment-system infrastructure (SORBNET2, TARGET).

Issuing e-money or providing payment services as a domestic EMI requires a KNF permit, with minimum initial capital of EUR 350,000; authorisation grants full EU/EEA passporting. A lighter 'small payment institution' tier operates Poland-only via entry in the KNF register.

Open banking was implemented via the Act of 10 May 2018 amending the Payment Services Act, enabling third-party providers to offer Payment Initiation (PIS) and Account Information (AIS) services with strong customer authentication; AISPs/PISPs are authorised/registered by the KNF.

Poland was an instant-payments pioneer: Express Elixir (KIR, launched 2012) settles PLN transfers in real time, and the BLIK mobile scheme settles via Express Elixir; KIR's Euro Express Elixir is SEPA Instant (TIPS)-compliant for euro payments.

BNPL providers fall under tightened consumer-credit rules: the Anti-Usury Act brought consumer-credit lenders under KNF supervision from 1 January 2024, and the EU Second Consumer Credit Directive (CCD II, to be transposed by 20 Nov 2025, applied from 20 Nov 2026) expands scope to capture BNPL.

Poland's MiCA-implementing Crypto-Asset Market Act (designating KNF as supervisor) was passed by the Sejm in late 2025 but vetoed by President Nawrocki on 2 December 2025; as of May 2026 Poland remains the EU's last member without finalised MiCA national legislation, leaving crypto-asset service provider licensing unsettled.