EMI licensing path in Poland.
EMI (E-Money Institution) licence in Poland is supervised by Komisja Nadzoru Finansowego (KNF). Time-to-licence is typically 9–12 months; EU/EEA passporting is available under EMD2 / PSD2.
What this licence allows.
Issue e-money (wallets, IBANs, prepaid cards); payment services where derived from e-money issuance.
KNF has accelerated fintech onboarding via the Innovation Hub. Polish AML rules add a few specific reporting obligations beyond AML5/6 baseline.
- Corporate structure + beneficial ownership (UBO ≤ 25%)
- Initial capital deposited in a regulated EU/EEA bank
- Three-line-of-defence governance model
- AML programme + transaction monitoring policy
- Risk-based KYC + sanctions screening process
- ICT-security questionnaire (DORA-aligned from 2025)
- Outsourcing register (BSS, payment partners, cloud)
Three paths to EMI in Poland.
Acquire EMI directly from KNF
Time: 9–12 months. Initial capital: €350,000 (in PLN equivalent). Full control, full obligations. Coreal helps with the IT-security questionnaire and three-lines-of-defence model.
Partner with an existing EU EMI
Use a sponsor EMI passport from another EU country (DE, FR, NL, etc.) and operate in Poland under freedom-of-services. Faster: 30–90 days vs 9–12 months.
Use the Coreal EMI passport
Coreal operates under its own EU EMI licence. Operator gets a fully-branded wallet without acquiring any licence. Ships in ~60 days.
Who is the EMI regulator in Poland?
Komisja Nadzoru Finansowego (KNF). They oversee authorisation, ongoing supervision and enforcement for EMI licence holders in Poland.
How long does EMI authorisation take in Poland?
Typically 9–12 months end-to-end. The bottleneck is usually the regulator's risk and IT-security questionnaire — plan for ≥4 months of regulator dialogue.
Can a Poland EMI passport into the rest of the EU?
Yes. Poland is an EU member state, so a EMI authorised here can passport into all 27 EU/EEA countries under EMD2 / PSD2.
Bring the perimeter,
leave with a brief.
Read the Wave-1 runbook first.
The full 90-day launch sequence — phases, partner-bank gates, who signs off when. No form to read it.
Read the runbook →INDICATIVE DATA · Numbers and timelines reflect public regulator filings, vendor documentation and our own delivery experience. Per-engagement values vary with operator profile, BSS vintage and regulatory perimeter. Engage early for a fitted estimate under NDA.