AEMI license in Poland

March 13, 2023
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Today’s country, which has been a member of the EU from 2004, when supplying the issue of virtual money and remittance systems, must be controlled by the Second Directive of Europe and the demands of the GDPR adjustment. At the state level, the monetary controller (Financial Supervision Committee) has not formed liberal or proscriptive terms, whereas in basic the powers have a negative attitude towards electronic money.


The state provides financial technology with a large proportion of skilled workers. In addition, the labor market is known for low salaries and professionals with relevant experience.

From the sustainable development of the country to the payment service habits of the population and the growing number of migrants in Poland and local residents emigrating to other countries constantly in need of currency exchange, there are several factors that make Poland an excellent market entry for both B2B and service providers B2C.

Who needs an Authorised e-money license in Poland?

Authorised electronic money institution license in Poland is required for firms that carry out transfers with virtual money in state. According to the legislation, firms that supply virtual payment favors(in particular, payment on the site), as well as companies that work with e-currencies, must obtain an AEMI permit.

How to obtain AEMI license in Poland

Obtaining the AEMI permit is a straightforward procedure. Interested businesses can contact regulator directly or apply for the permission online. The application process requires providing info about the biz, such as its name, address, and the type of activities it engages in. The business must also provide a list of audiovisual works and favors that it plans to use.


The permissing procedure for virtual money establishment should provide information that allows the identification of directors and persons who directly or indirectly have a significant stake in the firm, indicating the size of the stake they hold.

In addition, the electronic money establishment must supply the KNF with documents and info that will allow it to assess whether the organization and persons mentioned above guarantee the prudent and stable administration of the AEMI, in particular:

  • Legal papers that allow you to assess whether managers have the needed education and professional knowledge to manage the actions of issuing and redeeming electronic money;
  • Info on conviction for a criminal or tax offense, on parole and disciplinary proceedings with the request of sanctions, as well as other completed administrative and civil proceedings against the applier or interested persons.

What do you need to get AEMI license in Poland?

In order for a remittance structure to comply with the EU Second Directive, the following conditions need to be met:

  • Produce a business sample for the first 36 months of work and describe the construction, governance arrangements and tools of the PS;
  • Acknowledging the capabilities and knowledge of the Council in the field of finances and virtual money;
  • Proofs of the source of funding for the work;
  • Demonstrate that the firm has the technical capability to provide PS (software, server, etc.), and customer remittance are secured;
  • Develop guidance on averting money laundering and report risk administration systems;
  • Obtain processing license, etc.

Documents needed

  1. Legal address;
  2. Articles of association, articles of association or memorandum of association;
  3. A list of electronic money favors (and possibly remittance services) that it intends to supply;
  4. A program of operations and a financial plan for a period of at least 36 month, which shows that the applicant is able to use adequate and proportionate systems, resources and procedures necessary for the proper performance of its actions, according to which the program of actions and the financial plan also indicate the planned average amount of electronic money in circulation;
  5. Confirmation of the availability of own funds in the needed amount;
  6. A explanation of the risk administration and internal control system specified in clause 3 of part 1 of Article 64, including approved internal rules in this area;
  7. A description of close ties between the applicant and other subjects, if any;
  8. If the intention is to supply a payment transaction initiation service, a document confirming liability insurance, a bank guarantee, an insurance guarantee or any other guarantee of the user’s requirements.

What is covered by each category of info and documents listed in points above is provided by the current Regulation of the Minister of Finance, Funds and Regional Policy regarding the detailed amount of information and the type and form of documents attached to the request for permission to operate as a domestic remittance establishment from November 13, 2020 (Legal Gazette of 2020, item 2225), issued on the basis of Part 3 of Article 61 of the UUP.

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