License type	Small Payment Institution — Mała Instytucja Płatnicza (MIP)
Regulator	KNF — Komisja Nadzoru Finansowego
Monthly transaction limit	€1.5 million (PLN equivalent)
Client account holding limit	€2,000 per client
Minimum capital requirement	None
Territorial scope	Poland only — no EU passporting
Our services	Buy ready-made, sell existing, register from scratch, upgrade to API

Buy, Sell or Register a Small Payment Institution – SPI(MIP) in Poland

A Small Payment Institution — known in Polish law as Mała Instytucja Płatnicza, or MIP — is the simplest way to enter the regulated payment services market in Poland. No minimum capital requirement. Simplified registration with KNF. And a path to a full Authorized Payment Institution license once your business grows.

We buy and sell Polish SPIs. We register new ones from scratch. We handle the SPI-to-API upgrade when clients outgrow the regime. Whether you are looking for a ready-made entity that lets you start operating in days, or you want to build a clean payment institution from the ground up, this page covers everything you need to know — and everything the market gets wrong about how this license actually works.

What Is a Small Payment Institution (MIP) in Poland?

The MIP regime exists under the Polish Payment Services Act (Ustawa o usługach płatniczych) and is supervised by the KNF — Komisja Nadzoru Finansowego, Poland’s financial supervision authority. It was introduced as a simplified entry point for companies that want to provide payment services without the full regulatory burden of an Authorized Payment Institution (API).

A Polish MIP can provide the following payment services: execution of payment transactions (including transfers of funds on a payment account), execution of payment transactions where the funds are covered by a credit line, issuing payment instruments and acquiring payment transactions, and money remittance.

What a MIP cannot do: account information services (AIS) and payment initiation services (PIS) are not available under this regime. Those require an Authorized Payment Institution license.

The key constraint is volume. A Polish MIP may not exceed €1.5 million in average monthly payment transactions over the preceding 12 months. This is stricter than most other EU member states — the standard threshold under PSD2 Article 32 is €3 million per month. Poland set its own, lower ceiling. If your business crosses that line, you need to apply for a full API license — something we handle as well, and something worth planning for from the start.

There is no minimum share capital requirement for a MIP. The holding limit per individual client account is €2,000. Registration is with the KNF, and the entity must be a Polish company — typically a sp. z o.o. (limited liability company).

One more point that is critical and often misunderstood: a Polish MIP can only provide payment services on the territory of Poland. Not the EU. Not the EEA. Poland only. This matters so much that it gets its own section.

The Biggest Misconception About SPIs — in Poland and Across the EU

There is a claim that circulates widely in the market — from intermediaries, consultancies, and even some law firms that should know better — that a Small Payment Institution can operate across EU member states. That once you have an SPI license in Poland, you can serve clients in Germany, France, or anywhere else in the European Union.

This is not true. And it is not a matter of interpretation.

Under PSD2, passporting rights — the ability to provide payment services in another EU member state on the basis of your home country licence — apply exclusively to fully authorised Payment Institutions. A Small Payment Institution, registered under the Article 32 exemption, does not hold a full authorisation. It holds a registration. And that registration is strictly territorial: it allows you to provide payment services within the member state where you are registered, and nowhere else.

This is not unique to Poland. An SPI registered in Lithuania operates in Lithuania. An SPI in the Czech Republic operates in the Czech Republic. The simplified regime was designed for small, domestic payment service providers — not for cross-border operations.

Why does this matter for you? Because if you are buying a Polish SPI with the expectation that you will serve clients across Europe, someone has misled you. And that someone is either uninformed or not acting in your interest.

If your business requires cross-border EU operations, what you need is an Authorized Payment Institution (API) license with passporting, or an EMI license. We handle both. But we will not sell you a MIP and pretend it does something it cannot do.

Buy a Ready-Made Polish SPI

Unlike the Polish VASP register — which closed permanently on 30 December 2024 — the SPI regime remains open. New Small Payment Institutions can still be registered in Poland. That said, registration takes time, and not every buyer wants to wait four to six months before they can start operating.

This is where ready-made SPIs come in.

We maintain our own clean SPIs — entities set up by us, with no operational history, no clients, no debts, no pending KNF inspections. These are built specifically for resale. Clean from day one.

We also broker SPIs on behalf of third-party sellers who have granted us a sell-side mandate. These are existing businesses, and buying one is treated the way any business acquisition should be: with proper due diligence. We assess the company’s regulatory standing with KNF, its financial position, any outstanding liabilities, and the AML documentation. You will know exactly what you are getting before you commit.

What is included in a typical acquisition: a complete AML/CFT documentation package, all KNF registration records, and we can arrange virtual IBANs (individual payment accounts) for the acquired entity — something that many SPI buyers need and few intermediaries can actually provide.

The transfer itself follows standard Polish corporate procedure: a share transfer under commercial law, processed through S24 — the same mechanism used for shelf company sales. No KNF approval is required for a change of ownership. KNF only gets involved when registering a new SPI from scratch, not when an existing one changes hands. This means the transfer is fast — a matter of days, not months.

One point that needs to be stated plainly. Some providers in this market advertise that they sell SPIs with a “ready-made management board” or nominee directors. This is illegal under Polish law. Poland does not permit nominee services. Any entity sold must be taken over by the buyer’s own management board. If someone is offering you a Polish SPI with nominees included, they are either ignorant of the law or deliberately breaking it. Either way, that is not someone you want handling your regulated financial institution.

Sell Your Polish SPI

If you own a Small Payment Institution and want to sell it, we can represent you.

The most common reason people come to us with a sell mandate is straightforward: the business did not develop as planned. The SPI was registered with a specific business model in mind, the model did not work out, and now the owner wants to exit. Sometimes it is a strategic decision — the company is upgrading to a full API license and the MIP entity is no longer needed. Whatever the reason, we handle the sell-side process from initial assessment to closing.

What we need from you at intake: your expected price, and an honest assessment of the company’s condition. That means regulatory standing — has KNF raised any queries, conducted any inspections, flagged any issues? Financial position — are there debts, outstanding obligations, pending claims? We will tell you candidly whether your price expectation is realistic for the current market. If it is too high, we will explain why and what range is achievable.

Valuation is driven by market knowledge and timing. We see enough SPI transactions to know what buyers are currently willing to pay. How quickly you want to sell also matters — a patient seller who can wait for the right buyer will achieve a higher price than someone who needs to close within weeks.

We work on a markup basis: we agree the terms before we begin, and there are no surprises. If you have a Polish SPI to sell — or an SPI in another EU jurisdiction — contact us.

Register a New SPI from Scratch

Buying ready-made is faster. But fresh registration has its own advantages, and for many clients it is the better path.

Here is the reality: when someone sells an SPI, it is usually because the business did not go well. That means the entity often comes with some combination of regulatory loose ends, incomplete AML documentation, legacy liabilities, or a KNF file that is not entirely clean. Due diligence will reveal these issues, and a buyer needs to assess whether they are acceptable. Some are. Some are not.

A fresh registration avoids all of that. You start with a clean Polish company, a clean KNF registration, and an AML framework designed specifically for your business model. No inherited history.

What we do for you: we prepare the complete KNF application file — business plan, internal governance, AML/CFT policies and procedures, compliance framework. We provide an AML Officer for the duration of the registration process, because KNF requires one from the moment the application is filed. We liaise with KNF throughout their review and handle any follow-up queries. After registration, we provide ongoing regulatory support.

The timeline question. In 2026, a realistic estimate is four to six months from application to registration. Anyone telling you three months is either working with a different definition of “registration” or simply not telling the truth. On the other end, a registration stretching to a year or more does happen — but almost exclusively when the applicant has not thought through what payment services they want to provide and why. We resolve that in the preparation phase, before anything is filed with KNF.

Ready-Made or Fresh Registration — Which Makes Sense for You?

This is not a question with one right answer. It depends on how quickly you need to operate, what condition of entity you are willing to accept, and how much you are prepared to spend.

Speed: a ready-made SPI transfer completes in days. A fresh registration takes four to six months. If you need to be operational next week, there is only one option.

Cost: sellers of ready-made SPIs typically expect a price in the range of three to four times what a fresh registration costs. That premium buys you speed and an immediate operational entity. Whether it is worth it depends on your revenue timeline.

Condition: a fresh registration gives you a clean slate — no regulatory history, no inherited AML gaps, no due diligence surprises. A ready-made SPI may be perfectly clean (ours are), but third-party entities require careful assessment.

Customisation: with a fresh registration, the payment services registered with KNF are tailored to your business plan. A ready-made SPI comes with whatever services the previous owner registered — which may or may not match what you need.

We advise on this during the initial consultation. Sometimes the answer is obvious. Sometimes it takes a conversation to work through the specifics. Either way, you will not be pushed toward one option because it is easier for us — you will get the recommendation that fits your situation.

SPI to API Upgrade — Planning Your Growth

The €1.5 million monthly transaction limit is the natural ceiling of the Polish MIP regime. When your business approaches that threshold, the next step is an Authorized Payment Institution (API) license — a substantially more powerful licence that removes the volume cap and, critically, allows EU-wide passporting.

We handle the SPI-to-API upgrade process with KNF. It is a significant step up in regulatory requirements: higher capital thresholds, broader governance documentation, more demanding compliance infrastructure. The process takes a minimum of one year.

Some of our clients buy an SPI with the API upgrade already in mind. They use the MIP as a fast market-entry vehicle — start operating under the simplified regime while the API application is being prepared and processed. This is a legitimate strategy, and in certain business models it makes good sense. Whether it applies to your situation depends on your projected transaction volumes and how quickly you expect to hit the €1.5 million limit.

For the full picture of what an API license involves, see our Authorized Payment Institution (API) page.

SPI Licenses Across the EU

Poland is not the only EU member state with an SPI regime. Under PSD2 Article 32, each member state can choose to implement a simplified registration framework for small payment institutions. Most countries that have done so set the transaction threshold at €3 million per month — double Poland’s limit.

We hold sell-side mandates for SPIs in several EU jurisdictions, including Sweden, Estonia, Lithuania, Latvia, the Czech Republic, and Spain. If your business needs a higher transaction ceiling than Poland offers, or if you want an SPI in a specific country for operational reasons, we can source it. Same service, same professional standard.

We also assist with fresh SPI registration in these jurisdictions. Local regulatory requirements vary — registration timelines, documentation standards, and specific supervisory expectations differ from country to country — and we guide you through the process for each.

A note on Luxembourg: we receive frequent inquiries about SPI licenses in Luxembourg. Luxembourg does not have an SPI regime. The CSSF — Luxembourg’s financial regulator — only authorises full Payment Institutions and Electronic Money Institutions, both of which require meaningful initial capital. If you are looking for a payment license in Luxembourg, contact us and we will advise on the correct path.

Frequently Asked Questions

What is a Small Payment Institution (MIP) in Poland?

A Mała Instytucja Płatnicza (MIP), or Small Payment Institution, is a regulated entity registered with the KNF under the Polish Payment Services Act. It can provide payment services — including payment execution, money remittance, and payment instrument issuance — within Poland, subject to a monthly transaction volume limit of €1.5 million. Unlike a full Authorized Payment Institution, a MIP has no minimum capital requirement and follows a simplified registration procedure.

Can a Polish SPI provide payment services outside Poland?

No. A Polish MIP can only operate within Poland. Passporting rights under PSD2, which allow a payment institution to provide services across the EU, apply only to fully authorised Payment Institutions — not to entities registered under the Article 32 small payment institution exemption. This applies to all EU member states: an SPI registered anywhere in the EU is restricted to the territory of that member state.

How long does it take to register a new SPI in Poland?

In our experience, four to six months from application to KNF registration. Claims of three months are not realistic under current KNF processing timelines. Longer timelines — up to a year — typically result from the applicant not having a clear business model at the outset, which causes repeated rounds of KNF follow-up.

Do I need to provide my own management board when buying a Polish SPI?

Yes. Polish law prohibits nominee director services. When you acquire an SPI — or any Polish company — you must appoint your own management board. Any provider offering a “ready-made board” or nominee directors as part of an SPI sale is proposing an arrangement that is illegal under Polish law.

What is the difference between a Polish SPI (MIP) and an Authorized Payment Institution (API)?

The SPI operates under a simplified regime: Poland-only territorial scope, €1.5 million monthly transaction limit, no AIS or PIS services, and no minimum capital. The API is fully authorised: EU-wide operations via passporting, no transaction volume cap, the full range of payment services including AIS and PIS, and significantly more demanding compliance requirements. Most businesses start with an SPI and upgrade to an API as they grow.

What happens to Polish SPIs under PSD3?

Existing SPIs are expected to be grandfathered under PSD3. The forthcoming regulation is not designed to eliminate the small payment institution regime but to harmonise it across member states. We monitor all regulatory developments in this space and advise clients on any changes that may affect their licensing.

Contact Us

Whether you are looking to buy a ready-made Polish SPI, sell an existing one, register a new MIP from scratch, or upgrade from SPI to API — we handle the process from start to finish.

Contact us for a confidential consultation:

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📧 Email: filip.z@zalewskiconsulting.pl
📞 Phone: available on request

Zalewski Consulting — payment institution transactions handled by a regulatory lawyer, not a sales team.