What is it and how can you get it?

Small Payment Institution

A Small Payment Institution (SPI) is a regulated activity in the field of payment services, introduced into the Polish legal system by the Payment Services Act.

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This solution is dedicated to entities, in particular FinTech startups, that intend to provide payment services on a limited basis and scale, without having to go through the complex licensing process required for a National Payment Institution (NPI).

Obtaining SPI status requires entry in the relevant register maintained by the Polish Financial Supervision Authority (PFSA) This entry legalizes activities such as maintaining payment accounts, executing money transfers, and acquiring, within strictly defined statutory limits.

Why is it worth it?

Benefits of obtaining SPI status

Registering as an SPI offers a number of benefits for entrepreneurs planning to enter the payment services market:

Unlike PFSA, the law does not impose a minimum initial capital requirement for SPI.

The process of obtaining an entry is faster and less formal than the procedure for obtaining a NPI permit. The PFSA has three months to review a complete application.

SPI allows technological and business solutions to be tested in a regulated environment before a decision is made to apply for a full PFSA license.

Operating under the supervision of the Polish Financial Supervision Authority strengthens the trust of customers and contractors (including banks).

Who can register a Small Payment Institution?

Any entrepreneur can apply for entry in the SPI register, regardless of the legal form of their business. This means that SPI status is available to:

natural persons conducting sole proprietorship (JDG),

partnerships (e.g., general partnership, limited partnership),

capital companies (limited liability company, joint-stock company, simple joint-stock company).

Key subjective requirements

Persons managing SPIs must possess the appropriate characteristics (in particular, they must not have been convicted of any of the crimes specified in the Act).

The entrepreneur is obliged to implement organizational solutions ensuring compliance of activities with legal regulations.

Step by step

How to register a Small Payment Institution?

The procedure for obtaining an entry in the SPI register is an administrative procedure conducted by the Polish Financial Supervision Authority. It consists of the following stages:

Preparation of application documentation

A key stage requiring the preparation of detailed documents, including a description of payment services, a cash flow diagram, a business plan and financial plan for the first 12 months, AML/CFT procedures, and a description of the risk management system.

Submitting an application to the Polish Financial Supervision Authority

The application, together with a complete set of attachments and proof of payment of the stamp duty in the amount of PLN 616, shall be submitted to the Polish Financial Supervision Authority electronically via ePUAP or in traditional form.

Verification procedure

The PFSA conducts a formal, legal, and substantive analysis of the submitted documentation. During this time, the supervisory authority may request the applicant to supplement any deficiencies or provide additional explanations. Professional handling of this stage is crucial for the smooth running of the process. We know of cases where the process of obtaining an entry in the SPI register took over a year. That is why it is so important to prepare documents with the help of an experienced expert.

Entry in the register

If the assessment of compliance with statutory requirements is positive, the PFSA enters the entity in the SPI register.

You want to ensure that your application complies with legal requirements and increase your chances of quick registration.

Feel free to contact our experts from the Banking & Finance department.

Maciej Raczyński

Legal advisor, Partner

Required documents and fees

The basis for obtaining an entry is the submission of documentation to the Polish Financial Supervision Authority confirming readiness to conduct business in accordance with regulations. The most important documents include:

A detailed description of the planned payment services and the scheme for their provision.

A business plan and financial plan for the first 12 months (rather than 3 years, as in the case of PFSA).

A description of organizational solutions for the protection of users' funds.

Internal anti-money laundering and counter-terrorist financing (AML/CFT) procedure, in accordance with the AML Act.

Risk management system.

Details of managers and documents confirming their clean criminal record.

The stamp duty for entry in the SPI register is PLN 616.

We will prepare a set of documents for you in accordance with the requirements of the Polish Financial Supervision Authority.

Request Document Preparation

Regulatory conditions of SPI

Limits and restrictions on SPI activities

The activities of a Small Payment Institution are subject to significant statutory restrictions:

Territorial restriction: An SPI may only provide services within the territory of the Republic of Poland. It is not possible to “passport” services to other EEA countries.
Transaction volume limit: The average monthly amount of payment transactions executed over the last 12 months may not exceed the equivalent of EUR 1,500,000.
User funds limit: The maximum amount of funds stored for a single user at any given time may not exceed the equivalent of EUR 2,000.

Obligations after entry in the register

Obtaining SPI status entails a number of ongoing reporting and regulatory obligations, including:

Application of AML/CFT procedures and transaction reporting (obligations of the obligated institution).
Ongoing compliance monitoring and operational and security risk management.
Reporting to the Polish Financial Supervision Authority (quarterly and annual reports on transaction volume and value, and payment fraud).
Compliance with DORA requirements.
Ensuring the protection of funds entrusted by users.
Compliance with statutory activity limits and notification of the Polish Financial Supervision Authority of any significant changes.

Registration time and risks of refusal

Preparation of documentation – usually 2–3 weeks, depending on the complexity of the business model.
Proceedings before the Polish Financial Supervision Authority – The statutory deadline is 3 months from the date of submission of a complete application. In practice, this period may be extended in the event of requests to supplement deficiencies.

Risks and threats

Pitfalls associated with SPI registration

Payment services are supervised by the Polish Financial Supervision Authority. It is important to be aware that providing payment services without the required authorization is punishable by a fine of up to PLN 5,000,000 and even imprisonment for up to two years, or both penalties combined.

The decision to choose SPI as a form of conducting business in the area of payment services should be preceded by a thorough analysis of the business model carried out with an experienced legal expert. In some cases, the SPI model is doomed to failure from the outset, and the only appropriate formula for conducting business in the area of payment services will be to obtain a license to operate as a so-called national payment institution. This applies in particular to situations where an entrepreneur assumes and formulates assumptions in a financial program that indicate that the limits applicable to SPI will be exceeded, and in situations where an entrepreneur intends to conduct business outside the territory of the Republic of Poland.

It should also be remembered that a SPI may be removed from the register if it does not conduct any payment services activity for a period of 12 consecutive months or does not commence the provision of such services within 12 months from the date of registration. In addition, a similar sanction may apply to those SPIs that fail to fulfill numerous timely obligations (reporting to the Polish Financial Supervision Authority on the amount and number of payment services, submitting financial statements, etc.).

The most common reasons for prolonging proceedings or refusing registration

Formal errors and incomplete application documentation.

Insufficient or inadequate risk management or AML procedures.

Incorrect classification of services provided or errors in the description of cash flows.

PFSA reservations regarding the financial plan or stability of the financial model.

Minimize the risk of rejection and delays with the support of our law firm's specialists.

We provide professional representation in proceedings before the Polish Financial Supervision Authority.

Frequently asked questions (FAQ)

On average, from several weeks to three months, depending on the completeness of the documents. The statutory deadline for the Polish Financial Supervision Authority (PFSA) to review a complete application is three months.

No – operations are limited to Poland. Providing services in other EEA countries requires obtaining a license to operate as a so-called National Payment Institution (NPI) and completing a notification procedure.

If the limit of EUR 1.5 million in average monthly transactions is exceeded, the SPI is required to notify the Polish Financial Supervision Authority (PFSA) immediately. Within 30 days, measures must be taken to adjust the scale of operations in order to return below the limit or to apply for a license to operate as a PFSA.

SPIs can provide most payment services, including maintaining payment accounts, executing transfers (including direct debits and standing orders), issuing payment instruments, and acquiring (accepting payments). However, SPIs cannot provide open banking services (AIS and PIS).

Specialization in FinTech and PayTech: We have many years of experience in providing legal advice to the financial sector and serving regulated entities.
Success in proceedings before the Polish Financial Supervision Authority: We effectively represent clients in registration and licensing processes before the Polish Financial Supervision Authority and the Polish Investment Authority.
Comprehensive support: We provide full legal services – from business model analysis and documentation preparation to ongoing regulatory advice after registration.
Practical knowledge of supervisory requirements: We have an excellent understanding of the PFSA's expectations, current legal requirements, and market trends.

For over 10 years, we have been advising domestic and foreign entrepreneurs, with payment services being our main area of expertise. Our experience includes several dozen entries in the register of small payment institutions. In addition, we are proud to have obtained an entry for a client providing account information services (AISP) as well as a license to operate as a so-called National Payment Institution (PFSA).

In our cooperation, we strive to place primary emphasis on understanding the client's business model and long-term relationships with the client for whom we have obtained an entry in the register of small payment institutions. Therefore, clients who decide to work with us to obtain an entry in the SPI register not only receive a professionally and efficiently prepared set of documents, but we also guide them through the entire administrative procedure at the Polish Financial Supervision Authority (PFSA). After obtaining the entry, they receive from us a summary of the basic recurring obligations necessary for the lawful and timely fulfillment of the statutory obligations of the SPI. What is more, we constantly monitor the current supervisory positions of the PFSA and provide relevant information and guidance in this regard.

Legal status as of 10 September 2025

Free consultation

If you want to start operating as a Small Payment Institution or have questions about SPI registration, please contact us.

We will help you quickly and securely obtain an entry in the PFSA register.

RSP Legal Law Firm
Your support in SPI registration.

Maciej Raczyński

Legal adviser, Partner

Phone number

+48 603 969 569

E-mail

maciej.raczynski@rsplegal.pl