Amendment to payment services act in Poland

Published:
January 3, 2025
skyscrapers g41644188a 1280

The function of the Polish market of payment services is managed by the Payment Services Act (ustawa o uslugach platniczych) which plays a crucial role in maintaining a robust framework. With a view to ensuring the continued evolution and effectiveness of this legislation, an amendment was made on the 22nd of August 2023 by the Polish President Andrzej Sebastian Duda. It includes a 30-day vacatio legis and proposes important changes to the payment industry, including the activities of SPI.

Key Changes Introduced by the Amendment

By addressing any existing issues or limitations in the Act, the amendments seek to create a more robust and inclusive regulative ecosystem. The amendment brings forth a series of important modifications to the Act, namely:

  • updated descriptions of payment instruments and the method of issuing them;
  • changes in the licensing process of the authorized payment institution – the amendment cancels the obligation to obtain an assessment from Narodowy Bank Polski – which currently applies to those APIs that cover the acquiring service;
  • now Account Information Service Providers (AISPs) are required to warrant users’ claims with insurance, a banking or an insurer’s guarantee.

The below list of modifications includes more.

Innovations for Polish SPI

The next new components will broaden the range of papers comprising the SPI application:

  • an explanation of organizational techniques that make it possible to determine the overall value of payment operations (for the purpose of calculating the transactional limit of 1.5 million euro on avg. monthly).
  • Poland’s AML policy
  • Business plans, financial projections, risk management protocols, client money policies, and descriptions of ancillary services (such as currency exchange).

What are the anticipated consequences of the Amendment?

In fact, this could complicate and lengthen the period of licensing procedure. The ultimate assessments of the modifications, however, need wait for KNF, to create mechanisms for reviewing applications in the updated manner. The new stipulations will also refer to license processes commenced under the “previous” act but not yet completed as of the Amendment’s effective date.

Transaction limit increased during transfer (SPI to API)

The fact of filing an API licensing request, in the existing legit position, completely precludes the employemnt of this limitation for the applicants until the license processes are finally settled (e.g., by obtaining an API license). Beginning on January 1, 24, the SPIs that appealed for API licenses will fall into an expanded payment operation limit, but it will not surpass the value shared to KNF prior to sending the request. Briefly, for each SPI asking for an API authorization, a different limit will apply.

Non-extending the scope of the SPI license

The establishment of a prohibition on submitting requests to broaden the scope of an SPI license during the time that a specific SPI surpasses the transaction limit (often EUR 1.5 million per month) is the final significant modification for SPIs. The prolonged adaptive period states that this additional prohibition will also go into effect at the beginning of 2024.

When will the new provisions take effect?

The changes mark another chapter in the evolution of the payment services industry. With its potential to address current limitations and promote innovation, it is essential to recognize the importance of this legislative change. The two examples of extended transition stage stated above aside, the changes to the Act take effect 30 days after the novel was published on August 29, 2023. In order to be ready for impending changes from a compliance, regulative, business, and employment law standpoint, it is advised that your SPI start preparing.

Related insights

Singapore as a Regional Growth Hub in 2026: Why International Companies Still Choose It for Asia Expansion

By the year 2026, Singapore is anticipated to rise to prominence as a leading global center of commerce, capitalizing on the economic growth of Asia. Its political and social stability, well-established legal system, excellent infrastructure, and strong economic sector are just some of the causes why Singapore is highly looked upon for trade and investment….

Read more 04.06.2026

Company Formation in Germany 2026: How to Register a GmbH Step by Step

Germany, a prime European gateway, offers a stable commercial environment. The GmbH will see simplified company formation in Germany 2026 via digitalization. This guide explains how to register a GmbH: the founding procedure, legal prerequisites, and investor considerations.  Reasons for Opting a GmbH Registering a German GmbH enhances corporate protection and business reputation, is trusted…

Read more 02.06.2026

New Incorporation vs Shelf Company in Germany: Which Option Is Better for Foreign Investors?

Germany remains one of the most attractive countries in Europe for international business. A stable economy, a well-developed banking system, transparent corporate legislation and a high level of investment protection make the German jurisdiction highly sought-after among entrepreneurs from various countries. When entering the market, investors usually consider two options: registering a new legal entity…

Read more 02.06.2026

Buying a German Shelf Company: When a Vorratsgesellschaft Makes Commercial Sense

Demand for ready-made companies remains steady in the European corporate services market. Entrepreneurs are considering various options for rapid market entry: ready-made company in Belgium (BV) with BNP Paribas Bank Account for sale, structures for international payments, including ready-made companies with a bank account in Switzerland for sale, as well as ready-made companies in Germany…

Read more 02.06.2026

Ready-Made GmbH in Germany: The Fastest Route to Start Business Operations

Germany continues to be an enticing choice for entrepreneurs across Europe who seek legal certainty, easy access to the European Union marketplace, and a well-reputed business setting. International investors and companies that are growing often find that speed is very important when they are moving into the German market. This is where a ready-made GmbH…

Read more 28.05.2026

Gambling License in Malta

The gambling sector in Malta remains one of the most structured parts of the European iGaming market. Market participants often monitor transactions involving businesses for sale because licensed operators with an established structure may enter the market faster than newly formed entities. Interest also remains high in projects described as Bookmakers and Gambling for sale,…

Read more 18.05.2026

UK Online Gambling Changes 2026

The online betting and casino sector in the UK by 2026 is almost unrecognisable compared to what operators were accustomed to just a few years ago. The latest reforms have not only changed some rules here and there, they have revolutionised the whole landscape in which the platforms operate. Regulators have taken a firm step…

Read more 05.05.2026

Gambling Regulation Trends 2026: What Operators Must Know

Global interactive entertainment and wagering will undergo a sharp regulatory change in 2026. Multiple governments are stepping up their regulatory supervisions, rolling out new tax policies, tougher rules, and more protections for the consumers. These changes will affect bookmakers and the overall ‘business for sale‘ market, where being prepared for regulation becomes a key factor…

Read more 27.04.2026

Germany’s Digital Economy in 2026: Where Business Growth Opportunities Are

By 2026, the topic of ‘businesses for sale’ in Germany will increasingly intersect with digital transformation. We are no longer talking about isolated changes, but about a systemic restructuring of the economy, where a company’s value depends directly on its level of digitalisation, the quality of its data and its ability to scale without a…

Read more 24.04.2026

Why Argentina Could Be Your Smartest LatAm Payments Entry Point

Argentina has been known for its unpredictability and operational complexity for a long time. However, the country’s image is changing significantly today. This moment seems particularly interesting due to the timing of things. Economic stabilization, loosening of restrictions, and the presence of a very well-connected consumer base are all happening at the same time. For…

Read more 24.04.2026

Inside Argentina’s Payment Gateway Boom: Where New Providers Can Win

PSP sales license, a ready-made payment service provider company in Argentina for sale, business for sale – these phrases are appearing with increasing frequency in enquiries from investors who view Argentina as a gateway to the Latin American fintech market. The reason is simple: a combination of macroeconomic instability, high inflation and the digitalization of…

Read more 22.04.2026

Top Gambling Licenses: Full Guide and List of Best iGaming License Jurisdictions

Across the globe, governments apply strict rules concerning gaming operations, in particular, those that are carried out online, requiring that actors get officially-recognized licenses. The leading purposes of these criteria are, on one hand, to help consumers and, on the other hand, to fight the illegal activities, as well as to monitor tax revenues generated…

Read more 17.04.2026