Eternity Law International News How a Small Payment Institution (SPI) in Poland Can Kickstart Your EU Payment Business

How a Small Payment Institution (SPI) in Poland Can Kickstart Your EU Payment Business

Published:
July 1, 2025
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Poland has recently gained considerable appeal as a base for financial start-ups in Central and Eastern Europe. Entrepreneurs refer to SPIs, also known as MIP, in this country as the entrance point in the local fiscal services market. For businesses looking to test new payment offerings without making a full commitment to the tougher demands of a full-fledged PI, SPIs are another option because of simplified demands and procedures, in addition to a flexible regulatory structure.

This article elaborates on the basics of running an SPI and why it is the best solution to buy an existing SPI company and what to consider in the acquisition process.

Key Regulatory Features of a Polish SPI

An SPI permit allows enterprises to provide a range of basic payment offerings—think domestic transfers, payment account management, card issuance, mobile wallets, and money remittance—within Polish borders.

While it comes with certain limitations (e.g. max €1.5M average monthly transaction volume, €2000 cap per client account, no open banking functions like PIS/AIS), the SPI structure is intentionally light-touch, designed to foster innovation and market experimentation.

There’s no hefty capital demand, the regulatory process is relatively fast (typically 2–3 months), and the corporate structure can be an LLC, JSC, or even a sole proprietorship.

How the Acquisition Process Works

Instead of registering an SPI from scratch, some founders choose to purchase a pre-licensed, operational SPI. It’s a shortcut that avoids months of paperwork and regulator back-and-forth.

Here are the key benefits:

  • Speed to market – Skip the KNF review queue and start operating almost immediately;
  • Lower legal risk – A vetted SPI has already passed regulatory scrutiny, reducing the risk of licensing rejection;
  • Infrastructure included – Many pre-packaged SPIs come with established AML policies, abidance structures, and even software integrations. That’s time and cost saved.

For multinational teams unfamiliar with Polish regulatory nuances, this route can mean the difference between a fast launch and a frustrating delay.

What to Look for When Buying an SPI-Licensed Company

No market in the world has service providers that can match in all ways the value and readiness for service provision as there is in the market. Due attention should first be paid to checking that the company is in good standing with the regulators, with no actions or fines pending from KNF. In this respect, confirmation will need to be sought from the supervisory body or advice from the legal side in order to confirm.

It is also necessary to verify that the amounts of transactions or the funds of the clients collected by the SPI have not exceeded a certain limit in the last few months. Exceeding €1.5 million in a transaction would thus result in its conversion to an NPI, which is radically more stringent in its licensing procedure.

Further, you may wish to ascertain whether the SPI has in its possession the requisite documentation for business and fiscal plans, AML policy, risk mitigation framework, and client onboarding procedures. Should it require updating, aligning, or duplication with the new services, another site—their updating—constitutes an activity of paramount importance and may give rise to a postponement of the project.

Take note of the company structure. Clear shareholders’ records, no linkages to high-risk jurisdictions, and a clear setup of governance: all this is required to keep KNF happy and for operational stability in the long run.

Conclusion

Starting SPI can be a smart way to enter a new place. It helps you move faster, learn the local rules, and make changes as you grow. With the right setup and careful planning, you can begin your journey smoothly and be ready for the next step when the time comes.

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