SEMI license in Poland

A small e-money license in Poland is a solution addressed to entrepreneurs who supply remittance services as part of their business activities. It corresponds to all the actions necessary to maintain an account, such as depositing or withdrawing money, transferring funds or making money transfers. In the case of SEMI, the average monthly amount of such transactions cannot exceed EUR 1,500,000 per year.

According to the clarifications of the law, a SEMI can be defined as an entity – a legal entity or an organizational unit that is not a legal entity, but which is granted legal capacity by the Law – that has been entered into the register of establishments with e-money and conducts business activities that provide any payment services, except for initiating payment orders or accessing account info.

Requirements for SEMI license in Poland 

• Company identification data (company details, articles of association).
• List of provided payment services.
• Financial statements.
• Business plan for a period of at least three years (including marketing and operational plans).
• Financial plan for a period of at least three years.
• Confirmation of availability of funds.
• Description of the risk management and internal control system.
• Structural diagram of the company and group, if the applicant is a member of such a group.
• Identification data of managers and persons with a qualifying interest in the company.
• Evidence of whether the applicant and the persons entitled to the reasonable and stable management of the payment institution.
• Identification data of auditors and audit firms.
• Proof of liability insurance or bank guarantee.
• Proof of compliance with technical standards for strong client authentication and common and secure open communication standards.
• Confirmation of payment of the authorization fee.
• List of the applicant’s agents, if the applicant plans to supply remittance services through agents.
• List of branches of the applicant, if the applicant plans to supply payment favors in branches.
• Also, there is no requirement for share capital.

Capabilities of SEMI license

• Issue of e-money
• The possibility of users using electronic money as a unit of account to pay for services/goods of third parties
• Opening of sub-accounts for Clients within the corporate account of the Payment Service Provider
• Services that allow users to place cash in a checking account
• Services that allow users to withdraw cash from a checking account
• Execution of payment transactions and money transfers
• Account Information Services
• Link existing payment bank cards to the Client’s sub-accounts and issue cards of major vendors (VISA, MC)

Benefits for fintech businesses in Poland

SEMI-licensed companies have the same rights as regular payment institutions. They can carry out payment transactions both online and offline.

An institution can open sub-accounts for its clients within its bank account, which gives it the ability to create accounts. Clients, in turn, can exchange cash for the electronic equivalent of coins and banknotes issued by the company and store them in their account.

Documents that need to be prepared to obtain a SEMI license in Poland

To get SEMI license in Poland, the KNF will send the authority a request for a list of internal documents and several statements, among other things:

• business plan for the first year of operation of a SEMI,
• financial plan for the first year of operation of a SEMI,
• risk management procedures,
• internal AML procedure,
• a description of organizational solutions that allow you to calculate the total monthly volume of provided payment services,
• the procedure for monitoring and considering security incidents and customer complaints,
• rules for working with clients’ funds,
• description of information provided to users of payment services,
• proof of current address, 
• provision of services exclusively in Poland, 
• compliance with the limit of the average total amount of payment transfers.

Registration of a SEMI in Poland for sale

A correctly completed and paid application for registration of a SEMI can be submitted both electronically and in a traditional way.

If the applicant wants to solve this problem online, he or she can use the Electronic Public Administration Services Platform through the box of the Office of Financial Supervision.

However, the application for registration of a SEMI can also be sent by regular mail to the address of the Financial Control of Poland. The application can also be submitted in person to the Office of the FSA of Poland in Warsaw.

Activities of SEMI

As part of its activities, a SEMI can carry out all operations necessary for maintaining a payment account. In particular, cash deposits and withdrawals from payment accounts are allowed. Its work allows you to transfer funds to the account of the selected provider and carry out monetary transactions.

It is worth knowing that a SEMI in Poland license for sale can issue its own payment instruments, as well as execute payment orders with their help.

A small EMI can keep the funds of its users in its payment accounts. It should be noted that the total amount of funds accepted per user at any time cannot exceed the equivalent of 2,000 euros. This amount is calculated on the basis of the average exchange rate announced by the National Bank of Poland effective on the last day of the month preceding this day.