Small Payment Institution vs Authorised Payment Institution in Poland - Choosing the Right Regulatory Route
Start with our SPI - API video
If you want a fast understanding of how the Polish SPI and API regimes differ, begin with the short explainer below - it outlines the practical consequences of each licence type for new and scaling fintechs. The session is led by our Managing Partner Piotr Putyra, recognised for his work in EU payments regulation and advisory to international investors.
In 2024, our team supported the registration of more than half of all SPIs granted in Poland, which means the guidance presented reflects first-hand KNF experience.
Watch our SPI vs API video here!
SPI or API? Understanding the Licensing Landscape
For foreign fintechs entering Poland, the choice between SPI and API defines the level of regulatory complexity you will face and shapes the timing and scale of your expansion. Both licences are built on the Polish implementation of PSD2, but they diverge sharply on transaction thresholds, territorial scope, capitalisation and internal structure.
For some projects, SPI provides a lean entry framework, while API caters to fintechs intending to operate at scale or deliver open-banking functionality.
SPI - a flexible entry model for early-stage and local operators
A Small Payment Institution enables providers to deliver a wide range of traditional payment services, but always within a fully domestic and quantitatively limited framework. The regime is intentionally light: SPI can operate through various corporate forms, and no dedicated capital requirement applies beyond the thresholds in the Commercial Companies Code.
In practice, SPI serves as a testbed licence - commonly selected by founders who want to validate their product or gradually build compliance capabilities before committing to the heavier API path.
Core characteristics of SPI
- SPI may offer a broad set of regulated functions, including payment account maintenance, transfers, card-based transactions, acquiring and money remittance.
- SPI may not offer PIS or AIS, which remain exclusive to fully authorised institutions.
- SPI can only operate in Poland, and the licence cannot be passported into other EEA jurisdictions.
- SPI must maintain monthly transaction volumes below EUR 1,500,000 (12-month average).
- SPI may hold no more than EUR 2,000 per user across all accounts.
Exceeding the statutory limits triggers an obligation either to scale down or to begin the SPI→API transition within a defined timeframe.
API - the full PSD2 licence for scalable and cross-border models
An Authorised Payment Institution is suited to businesses planning broader European scale, offering higher transaction volumes or integrating open-banking features. The licence carries more stringent requirements, but also removes the practical restrictions that accompany SPI.
API permits both PIS and AIS, making it the preferred choice for digital banking platforms, advanced payment architectures and account-to-account solutions.
Authorisation requires stronger capital, comprehensive governance documentation, IT-security materials and robust safeguarding arrangements. The application is also subject to a statutory fee equal to the PLN equivalent of EUR 1,250, as provided for in the Polish Payment Services Act. Typical review timelines range from 1 to 1.5 years, reflecting the depth of KNF’s assessment.
Small Payment Institution (SPI) vs Authorised Payment Institution (API) - Key Differences
| Category | Small Payment Institution (SPI) | Authorised Payment Institution (API) |
| Services & data access | Provides most operational payment services, but no PIS/AIS, limiting data-driven and open-banking models. | Provides full payment-service scope including PIS/AIS, enabling banking-like and A2A ecosystems. |
| Geographical reach | Activity strictly limited to Poland; no EEA passporting. | Can operate across the EEA via passporting after notification. |
| Transaction capacity | Subject to fixed limits: ≤ EUR 1.5m monthly average volume and ≤ EUR 2,000 per client. | No statutory caps; governed by safeguarding and own-fund rules. |
| Capital & management expectations | No PSD2-specific capital requirement; governance expectations are light, focused on clean criminal records. | Requires EUR 20,000–125,000 initial capital; KNF examines management competence, time commitment and risk oversight. |
| AML/CFT structure | AML required, with more flexibility in how functions are allocated. | AML required, typically requiring more formalised structures. |
| Documentation & supervisory process | Moderate package: 12-month plans, AML/risk procedures, PLN 616 fee; typical processing around 3 months. | Extensive framework: governance, IT/security, safeguarding, risk documentation; timelines around 1–1.5 years. |
When to Choose SPI?
SPI is a suitable route where fintechs seek fast deployment, have a strong Poland-first orientation, or view regulated payments as a complement to an existing non-financial activity.
Typical examples include testing wallet concepts, integrating payments into SaaS or e-commerce platforms, or launching early-stage crypto-adjacent products structured together with VASP registration.
SPI also helps organisations build an internal compliance foundation before progressing to a more demanding licence.
When to Choose API?
API is the licence of choice for models dependent on open-banking, significant transaction turnover or multi-jurisdictional growth.
It is also favoured by investors who prefer a single regulatory framework rather than a staged SPI→API progression. For such businesses, designing systems and governance with the API endpoint in mind ensures smoother scaling.
Moving from SPI to API
Polish law permits entities to apply for API at any time. However, once SPI thresholds are breached and cannot be reduced, the transition becomes mandatory.
A structured migration typically includes reinforcing board composition, aligning IT and outsourcing structures with KNF expectations, expanding internal controls and preparing for capitalisation consistent with API requirements.
Our team has guided SPI→API transitions since the post-2023 regulatory updates, including the first SPI registration under the amended framework.
Payments, crypto and MiCA
For many fintechs, payment flows interact with virtual asset services, making SPI/API licensing only one part of the regulatory picture.
Before MiCA takes full effect, crypto providers operate under the VASP registration regime. MiCA will replace it with the CASP licence, which imposes more detailed requirements on governance, AML and operational structures.
Poland is frequently chosen as a combined payments + crypto regulatory hub due to the compatibility of SPI/API and VASP/CASP frameworks.
Supervision by KNF
Both SPI and API fall under the supervision of the Polish Financial Supervision Authority (KNF). The regulator may issue recommendations, impose penalties or, in severe cases, restrict an institution’s operations.
SPIs pay an annual supervision fee calculated from their transaction volume, subject to a statutory cap of 0.025%. KNF also scrutinises shareholder backgrounds, particularly in cases involving links to Russia or Belarus.
How we assist fintech investors?
Selecting between SPI and API is a strategic call, tied to your operational design, scaling horizon and investor expectations.
Our FinTech & Financial Regulation team advises on SPI and API licensing, VASP/CASP navigation and MiCA - aligned structuring. To follow Polish and EU regulatory updates, you may subscribe to our Fintech Newsletter.