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FINANCIAL LICENSE (EMI) IN POLAND

An EMI (Electronic Money Institution) financial license in Poland is a permit from the KNF (Komisja Nadzoru Finansowego), which gives the company the right to issue electronic money, open accounts for customers, and conduct payment transactions throughout the EU.

A company with an EMI license can:

  • issue electronic money (e-money);
  • open user accounts, store their funds;
  • carry out payment transactions, transfers, payment processing;
  • issue payment cards (physical or virtual);
  • operate in all EU countries thanks to EU passporting.

ADVANTAGES

  • Reputably strong EU jurisdiction with transparent rules

  • Possibility of passporting throughout the European Union

  • Transparent interaction with KNF (English support available)

  • Relatively moderate requirements for company structure

  • Well-developed banking system for EMI

  • Access to the entire EU market

  • The regulator's positive attitude towards financial technologies

  • Relatively low tax rate (effectively ~9–19%)

  • Access to European banking infrastructure (SEPA, SWIFT)

  • Effective corporate taxation (~5%)

  • Strong legal protection and support for finanicial technilogies companies

MAIN REQUIREMENTS

  • Minimum share capital €350,000 (for full EMI)

  • Legal form: Polish company (spółka z ograniczoną odpowiedzialnością – Sp. z o.o. or joint-stock company – S.A.)

  • Local presence: legal address and actual operational activities in Poland

  • Management: at least 2 directors with experience in finance/banking

  • KNF Fit & Proper Test checks the reputation and competence of owners and directors

  • Owners / UBO: full transparency of ownership, sources of funding

  • AML/CFT control systems, policy, risk management, IT security

  • Protection of client funds: Segregated accounts or client funds insurance

The procedure for obtaining an EMI (Electronic Money Institution) financial license in Poland, regulated by the Komisja Nadzoru Finansowego (KNF) - the Polish financial supervisory authority.

Regulator: KNF — Polish Financial Supervision Authority

Main legislation: Payment Services Act (Payment Services Act, 2011)

Implements EMD2 (2009/110/EC) and PSD2 (2015/2366/EU)

License types:

  • Small EMI: for local operations with limited e-money, no passporting
  • Full EMI: full license for issuing e-money and payment services throughout the EU, passporting

Package of documents for submission to KNF

Business documents:

  • detailed business plan (for 3 years);
  • description of products and payment services;
  • forecasts of income / expenses / profits;
  • description of cash-flow and movement of electronic funds

Corporate documents:

  • corporate documents (statut / umowa spółki);
  • Ownership structure, directors’ details and UBO;
  • Proof of origin of capital

Policies and internal procedures:

  • AML/CFT Policy;
  • Risk Management Policy;
  • Compliance & Internal Audit Policy;
  • IT / Cybersecurity Policy;
  • Safeguarding Policy (захист клієнтських коштів)

Technical and operational information:

  • description of IT management and data protection system;
  • instructions on KYC, customer onboarding;
  • agreement with the bank where client funds will be stored

KNF Application Procedure: 

  • Preparation of the document package (3–8 weeks of preparation depending on the complexity of the model)
  • Pre-application meeting
  • The KNF often recommends a meeting to discuss the business model and ownership structure before the official submission.
  • Submission of the official application
  • The application is submitted in Polish
  • All documents must be translated and notarized
  • Application fee: approximately PLN 4,600 (~€1,000)
  • Completeness Check The KNF checks whether all documents have been submitted.
  • Application review (Substantive Review)
  • Check business plan, financial forecasts
  • Assessment of management structure
  • Check AML/KYC procedures
  • If necessary, additional inquiries or interviews with managers

Duration of the process

  • Document preparation: 1–2 months
  • KNF review: 1 month
  • Full review: 4–6 months
  • Total: 5–8 months

Obtaining an EMI license

After approval:

  • The company is entered into the Polish EMI register (Rejestr Instytucji Pieniędzy Elektronicznych)
  • An official KNF certificate is issued For full EMI,
  • it is possible to activate EU passporting (via notification from regulators of other EU countries)

Post-licensing obligations: 

  • Annual financial audit AML/CFT reports to KNF
  • Maintenance of minimum capital of €350,000
  • Segregation of client funds Internal control and regular policy updates

WHAT IS  PASSPORTING

Passporting is a key concept in European Union (EU) financial regulation that opens up great opportunities for companies licensed in one EU country.

Passporting is the right of a financial institution licensed in one European Union or EEA country (e.g. Malta, Estonia, Lithuania, Poland) to provide its services in other EU countries without the need to obtain a new license in each of them.

Passporting is like a "European financial passport": get a license in one EU country and you can legally work in all 27 countries without new permits.

Advantages of passporting

  • No need to obtain a license in each EU country
  • Reduction of costs and time to enter new markets
  • Single compliance center and regulator
  • Transparency and customer trust across the ES

Types of passporting

  • Freedom to provide services (FPS): activity in other EU countries without a branch (via the internet or remotely)
  • Freedom of establishment (FoE): opening a representative office or branch in another EU country

How it works: ️

  • The company obtains, for example, an EMI license in Lithuania (issued by the Bank of Lithuania).
  • Then it submits a notification to the regulator (MFSA, KNF, FI, etc.) about its intention to provide services in other EU countries.
  • The regulator sends a notification to the relevant supervisory authorities of other countries.
  • After 1–2 months, the company can legally operate in these countries - open accounts, issue electronic money, make payments, advertise services, etc.

Example:

  • If an EMI company has a license in Estonia, it can, through passporting: Offer e-wallets to customers in Germany, France, Spain, etc.;
  • Operate under the same brand in all EU countries;
  • Not open a new company or obtain a local license.

What services can be “passported” :

  • Issuance of electronic money (e-money)
  • Provision of payment services (transfers, wallets, cards)
  • Currency exchange, FX services
  • Maintenance of payment accounts
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OUR TEAM

Yevhen Sarafanov

Owner and CEO LOCMAN ICS LTD

Ludmila Chilik

Corporate and tax lawyer (Europe, USA, East Asia, UAE)

2025-11-04T13:50:23+03:00