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Small Payment Institution (MIP)

Want to know how to become an MIP? Get help from the experts!

We support companies
in achieving MIP status.

Our lawyers will assist you in obtaining an MIP registration and legally operating a Small Payment Institution. Below you will find the main requirements, obligations and benefits of having an MIP.

What is a Small Payment Institution?

A small payment institution (MIP) is an extremely attractive solution for entrepreneurs who want to provide payment services, including in the FinTech sector.

Unlike traditional National Payment Institutions (NIPs), MIPs do not require an intricate licensing process and only require a entry in the register of payment services. With this significantly simplified procedure, entrepreneurs can achieve MIP status much faster, while benefiting from simplified regulatory requirements.

MIPs are an attractive way of doing business in the FinTech sector.

Small payment institutions may provide the following payment services: money transfer, acquiring, execution of payment transactions (including credit transfer, direct debit, standing orders) maintenance of payment accounts, issuing (issuance of payment instruments), as well as payment credit.

As an MIP you are subject to the supervision of the Financial Supervision Commission (FSA). This means that you have to meet certain standards for supervised institutions, such as reporting or protection of user funds. At the same time, however, by being a legitimate payment service provider, you gain additional credibility in the market

What are the requirements to become a Small Payment Institution?

The requirements for registering a Small Payment Institution are simplified compared to those for a KIP.

Any entity based in Poland that fulfils the conditions of the Payment Services Act can become one.

Small payment institutions are not required to have a certain start-up amount, e.g. share capital, except when required by a specific legal form (for example, a limited liability company must have a share capital of min. PLN 5,000.

There is no requirement to have a specific legal form, so a small payment institution can be either a limited liability company, a limited partnership, a joint-stock company or a sole trader.

Nor does the MIP need to hold or maintain specific own funds.

The most important thing is to go through the MIP registration procedure correctly

Our law firm will assist you in correctly completing the form and collecting the documentation.

What services can you provide as an MIP?

carry out money transfers (direct debits, credit transfers)
execute money transfers
accept payments by payment instruments (card, code, payment gateway, etc.).
credit payment transactions
provide a payment gateway
operate payment accounts (hold users' funds with a view to effecting payment transactions)
function as an exchange office for payment transactions
carry out hybrid activities*

* Hybrid activity means that you can have MIP status and at the same time provide financial and non-financial services. Example: a marketplace portal that processes all payments in-house (i.e. they take place through its own system).

Three main limitations of the MIP

Despite its many benefits, the Small Payment Institution imposes three restrictions on you:

  1. 01

    The principle of territorial limitation, under which you can
    operate exclusively in Poland.

    This means that you must "lock in" to the territory of Poland with a given payment transaction. However, you can still serve non-residents provided that you comply with the principle of territoriality of cash circulation.

  2. 02

    The maximum amount held on a payment account in a given
    the point in time of funding per user may not exceed EUR 2 000.

    This refers to funds held on a payment account, i.e. those that will not be transferred by means of a payment transaction within D+1

  3. 03

    You may not exceed an average monthly turnover in 12 months
    amounting to EUR 1 500 000 (EUR 18 million per year).

Check whether you need to become a Small Payment Institution

Consider becoming a Small Payment Institution if:

  • you come into possession of cash in order to transfer it to another person,

  • you provide so-called payment gateways or other tools to accept payments,

  • you run an online exchange office (kantor online)

  • you mediate the transfer of money between users

  • you issue payment instruments (e.g. gift cards)

  • you provide acquiring services, i.e. intermediation in non-cash transactions initiated by the purchaser of a good or service

  • you carry out payment transactions against the funds made available to you under the credit facility.

  • you store user funds for settlement (e-purse)

Obtain MIP status with the help of a law firm

You do not have to apply for entry in the register of payment services yourself. Individual submission attempts often generate a lot of questions from the Financial Supervisory Commission (FSC). The FSC requires the use of legal language that complies with the Payment Services Act, which sometimes conflicts with the more colloquial style you may encounter with self-submitted applications, resulting in the need for corrections and additions. This situation often delays the registration process.

At RPMS Law Firm, we guarantee a full service in the registration of a Small Payment Institution (MIP). We specialise in the financial technology (FinTech) sector. Our team will not only conduct an analysis, prepare the necessary documentation and guarantee comprehensive legal support, but will also tailor its approach to the specifics of your business. Taking into account the industry, the type of services offered and the unique needs of your business.

In the event of a possible decision to transform the MIP into a National Payment Institution (NIP), we offer support in the process of adaptation and implementation of the relevant solutions.

What do we offer? Full service MIP

Cooperation with the RPMS law firm includes:

  • an application for entry in the MIP Register and its annexes,
  • preparation of the AML procedure and risk assessment,
  • relieving the entrepreneur of the burden of intricate formalities,
  • legitimacy of solutions,
  • organisation of the business as required,
  • Comprehensive legal support following registration as an MIP.

Wondering what it is like to obtain an entry as an MIP?

Take a look at what this process looks like:
Krok 1

Describe your business idea to us - you can do this by email, phone call or online meeting.

This will allow us to assess whether an MIP is the right solution for your business - it may be worth considering a KIP or even operating legally outside of the supervision of the FSA. We will answer questions about the process of obtaining registration as an MIP and discuss the scope of our services, tailoring to your individual needs. We are covered by legal professional privilege.

Krok 2

We will provide a summary of the findings from step 1 in the form of an offer tailored to your needs, together with an estimated cost and lead time.

If the offer meets your expectations, we will proceed once the contract is concluded.

Krok 3

Stage of work on the application to the FSA

We start this stage by arranging a meeting with you. During this meeting, we discuss the factual and legal situation. We ask you about your ideas for a Small Payment Institution (MIP) in terms of services, the objectives you want to achieve and the nature of the infrastructure you have.

As a result of the amendments to the Payment Services Act of September 2023, a number of documents are added to the application, such as:

  • Programme of activities,
  • Financial plan,
  • Anti-Money Laundering (AML) procedure with risk assessment and annexes,
  • Statements to the supervisory authority,
  • Risk management procedures.

Preparing documentation is not just paperwork, it is a key step in organising your business. We do not use templates, but create practical and tailored documents for your business. The entire process of creating the application and annexes usually takes between 2 and 4 weeks.

Krok 4

Submission of an application to the FSA and the stage of proceedings before the FSA

From the moment you apply for an MIP, we officially act as your legal representatives, representing you in the registration proceedings before the FSA. This means that we are responsible for the course of the proceedings, including providing any clarifications, communicating with the FSA and dealing with any formalities.

According to the current regulations, the FSC proceedings should take up to three months from the submission of the application, but may be prolonged in case of additional questions from the FSC. Our experience shows that the FSA can act quickly, approving an application even within one month, especially for business models with which they are already familiar.

While the FSA is busy analysing the application, we start the process of creating the so-called client documentation. This typically includes terms and conditions for the provision of services, a model contract, a privacy policy, and a content analysis of the website for regulatory compliance (particularly relevant for MIP businesses based on the provision of electronic payment services).

We also propose additional activities, depending on your needs and the nature of your business. This may include extensive documentation of RODO compliance, filling bank questionnaires concerning the account for the MIP or certified AML training. We are committed to tailoring our offering to your actual needs, so we do not use pre-packaged 'packages' but focus on providing solutions that are relevant to achieving MIP status.

Krok 5


We monitor the registration process in the register of payment service providers. If the name of the entity appears in the register, this means that the application has been approved and Small Payment Institution status has been granted.

Krok 6

Correspondence with the FSC following an alert

Once an entry is obtained, we respond to the so-called sector letter of the FSC and comprehensively complete the documentation, enabling the MIP to start ongoing operations.

We provide the entrepreneur with instructions on monitoring relevant aspects, reporting procedures and other key issues.

As part of our offering, we also offer ongoing support for MIPs, available at affordable flat-rate prices (e.g. PLN 500 net/month). This allows the MIP to have a permanent link to specialists overseeing the fulfilment of reporting obligations to the FSA. Some MIPs, after receiving post-entry instructions, opt for self-service, reporting only in the case of more complicated issues, such as receiving a so-called supervisory letter (commonly referred to as a shepherd letter) from the FSA.

For details of the current service offering, we encourage you to explore the following tabs.

Does it seem complicated and expensive to you?

The procedure itself is quite intricate, but we will guide you through it from A to Z. Once you have obtained an entry, you will have your business organised and ready to go. The costs associated with the entry are around £20,000 - depending on the amount of work required for your MIP.

Law firm services for MIP -
What can we do for you?

The services we provide to small payment institutions include:
  • Day-to-day operation of the Small Payment Institution

    The Firm offers comprehensive services to small payment institutions, specialising in the provision of advisory and legal services - our experience includes representing clients before the Financial Supervision Authority (FSA) in the processes of obtaining authorisations to provide payment services, entries in registers and in various administrative proceedings.

    We provide support in obtaining the relevant FSA authorisations, but also in servicing the client-small payment institution after entry in the register of payment service providers. The firm also deals with the development and implementation of internal procedures in accordance with the provisions of the AML and Terrorist Financing Law (AML), or the creation of internal documentation such as risk management and internal control systems.

    In view of the dynamic legislative changes in Poland and the European Union, we offer monitoring of changes in legislation and suggestions for implementing appropriate solutions or adapting existing processes. We also provide other compliance services, overseeing the compliance of internal procedures and documentation, which allows clients to adapt to changes in advance and maintain high efficiency of the services provided. Our client can rest assured that their company complies with all regulatory requirements and that their business is conducted in compliance with the applicable regulations.

  • Ongoing advice

    Small Payment Institutions often face accounting and tax challenges, especially related to their specific activities in the area of payment intermediation and lending services. A variety of uncertainties may arise in particular when an MIP is engaged in hybrid activities that differ in the manner of settlement compared to payment transactions.

    Clients often raise questions about the VAT exemption, the revenue identification aspects of holding users' funds, the ring-fencing of MIP bank accounts to protect users' funds, and issues related to the MIP operating model itself, such as the intermediation of payments or the transfer of donations between users.

    We operate in an area of specialisation, offering experience and consultancy support. Our team has accounting expertise, ready to assist you and your accountant in resolving any concerns that may arise in the course of running this type of business.

  • AML training for Small Payment Institution

    In a dynamic financial environment where Anti-Money Laundering (AML) regulations play a key role, Small Payment Institutions need to be well prepared for change and to maintain compliance with current regulations. That is why we provide dedicated AML training, focused on the specific needs of Small Payment Institutions.

    The AML Training for Small Payment Institutions is designed to provide the practical knowledge and tools necessary to effectively implement and maintain AML procedures. The programme includes a discussion of key issues related to AML and terrorist financing, as well as the presentation of current guidelines from the Financial Supervision Commission (FSC) and changes in legislation.

    The training will enable participants to understand the nature and requirements of AML and provide practical guidance on implementing effective procedures. Participants will gain knowledge of the latest FSA regulations and guidelines, enabling them to adapt their institutions' operations to current requirements. The training will also focus on effective risk management, helping MIPs to identify, assess and mitigate potential risks. A dedicated training approach will take into account the specific needs of your company, enabling practical implementation of the knowledge gained.

  • Audit of MIP activities

    Auditing the operations of a Small Payment Institution (MIP) is a key process to improve operations and safeguard against risks. In today's dynamic financial environment, auditing is becoming an indispensable tool to ensure stability and compliance with applicable regulations.

    The audit allows potential non-compliance to be eliminated, strengthening the MIP's financial security. Analysis of operations allows more efficient solutions to be implemented, contributing to time and resource savings. Identifying areas for optimisation improves profitability and financial efficiency. Analysis of financial safeguards allows for an effective response to potential risks.

    In summary, auditing MIP operations is an investment in stability, regulatory compliance and operational efficiency.

  • Assistance in responding to letters from the FSA and with reporting obligations

    Responding to sectoral letters from a supervisory authority, such as the Financial Supervision Authority (FSC), is a key element of an institution's effective cooperation with the supervisory authority. Our services help to respond to sectoral correspondence effectively and in accordance with the KNF's requirements. Thanks to our experience and individual approach, we enable institutions to respond adequately to all enquiries and guidelines, while safeguarding their compliance with the applicable regulations.

    As a Small Payment Institution, you will be subject to a number of reporting obligations - primarily to the Financial Supervision Commission, but also to the General Inspector of Financial Information, the Financial Ombudsman and possibly also to the National Clearing House. We will support you in fulfilling these obligations.

  • Tax advice for MIP

    In light of increasing tax challenges, Small Payment Institutions (MIPs) need comprehensive tax advice to effectively manage their finances and remain compliant with current legislation. Our dedicated tax advice to MIPs covers a wide range of services, focusing on tax optimisation and risk minimisation.

    Our tax consultancy for Small Payment Institutions (MIPs) focuses on key areas such as tax optimisation, compliance, tax planning and providing personalised solutions for small businesses. We operate with a customised approach, dedicated to understanding the specificities of MIPs, supporting them in effectively managing their tax burden, minimising legal and financial risks and strategic planning tailored to their unique needs and objectives.

    Our services are designed to promote financial efficiency by optimising tax costs, while providing peace of mind by ensuring full compliance with current legislation and an optimal tax situation. A practice based on a flexible approach to each client enables MIP to make the most of our knowledge and experience. Tax advisory services for Small Payment Institutions are a key element of effective financial management and maintaining compliance with current tax legislation, enabling them to achieve sustainable growth in a dynamic financial environment.

    Apply for a consultation

    You will ascertain whether you should set up a Small Payment Institution.

Meet our team specialising in payment institutions, Fintech and Compliance

Kamila Wasilewska

Fintech industry enthusiast and practitioner for over 10 years

Experienced professional who has served as an in-house lawyer for payment institutions. Currently, she successfully manages proceedings concerning KIP, MIP, BUP and foreign institutions before the Financial Supervision Authority, successfully obtaining registrations and licences for clients. As Compliance and AML Officer, he is responsible for the comprehensive organisation of the business, ensuring that the procedures created are effectively implemented. He oversees ongoing reporting and provides legal solutions, especially for Small Payment Institutions.

Marcin Staniszewski

Serves the Fintech sector, specialising in legal solutions for IT

Represents clients in proceedings before the FSA. She has in-depth knowledge of internal risk management regulations and RODO. She enthusiastically shares practical insights, supporting businesses in the effective implementation of compliance solutions, ensuring that their business is effectively aligned with regulatory requirements.

Dominika Orlinska

FinTech lawyer specialising in AML and blockchain regulation

She specialises in the law of financial institutions and payment services, with a particular focus on modern technologies (FinTech) and combining them with blockchain and crypto-asset solutions. She has an in-depth knowledge in the area of AML/CFT regulation and is also educated in the area of English law. She is actively involved in projects related to the licensing and registration of payment service providers. She is fluent in English, which enables her to serve foreign clients effectively.

Our MIPs

Wondering if your idea falls under the MIP and want to structure the business well as a supervised entity?

Below you will find examples of services provided by MIPs listed in the FSC register with our assistance.


Payment gateway focusing on brokering donations to artists


Remittances carried out on behalf of large entities that post employees to work in PL and service providers that use Polish IT companies


Payment gateway with subscription elements in payment for SaaS services


System for accepting donations (donations) for influencers and gamers


Payment services in support of payment institutions, including payment credit services (for faster delivery of funds to the customer


E-portfolios (payment accounts) and the intermediation of transactions for and/or on behalf of prison inmates


Payment services of payment for goods and services using cryptocurrency exchange cooperation (cryptocurrency payment)


Payments in the factoring industry


Raising funds and donating them on a crowdfunding platform

Check if you can become a Small Payment Institution?

  • Do you have to be a company to become an MIP?

    No, the legal form of the business is arbitrary.

    We have also served MIPs that are sole proprietorships. Most often, however, it is incorporated companies (limited liability companies) that apply for MIP status due to the desire to limit liability. It also happens that a special purpose vehicle is set up under an MIP when we run another entity engaged in a different field of activity.

  • Do I have to operate as a company for a certain period of time to apply for MIP?

    No, there is no such requirement in the regulations. 

    We also know from practice that even a company that has been in existence for a month can successfully apply for registration as an MIP

  • Will the MIP be struck off the register when I have not been in business for some time?

    No, the regulations do not provide for such consequences.

    However, it should be borne in mind that even the non-performance (de facto) of any activities as an MIP (e.g. the provision of a money transfer service) does not exempt the MIP from reporting obligations.

  • Do I need to report when I have not yet executed transactions?


    Even the non-performance (de facto) of any activities as an MIP (e.g. the provision of a money transfer service) does not exempt the MIP from reporting obligations.

  • To which authorities do I have to fulfil my reporting obligations as an MIP?

    As an MIP, you will be subject to a number of reporting obligations - primarily vis-à-vis the Financial Supervision Authority, but also the General Inspector of Financial Information, the Financial Ombudsman and possibly also the National Clearing House. We will support you in fulfilling these obligations.

  • Does an MIP need to have a bank account with a Polish bank?

    Yes, regulations provide for such an obligation.

  • Can the MIP carry out foreign transfers?

    No, according to the territorial limitation rule, MIP can only provide payment services in Poland.

    This means that you must "lock in" to the territory of Poland with a given payment transaction. However, you may still serve non-residents provided that you comply with the aforementioned territorial restriction rule.

  • I do not maintain payment accounts. Am I subject to a limit of €2,000 per user?

    No. This restriction only applies to MIPs that provide a payment account service.

    Only a small payment institution that provides the service of accepting cash deposits and making cash withdrawals from a payment account and all the operations necessary to operate the account may hold users' funds on users' payment accounts, with the total amount of funds accepted for one user at any time not exceeding the equivalent in Polish currency of EUR 2,000.

  • Can the MIP work with the KIP?

    Yes, nothing prevents a small payment institution from cooperating with a national payment institution. 

    In some cases, this may even be necessary.

  • Can MIPs deal with cryptocurrencies?

    No, the legal form of the business is arbitrary.

    We have also served MIPs that are sole proprietorships. Most often, however, it is incorporated companies (limited liability companies) that apply for MIP status because they want to limit their activities. It also happens that a special purpose vehicle is set up under an MIP when we run another entity engaged in a different field of activity.

  • Does the MIP need to employ staff?

    No, the regulations do not provide for such an obligation.

    An entrepreneur with MIP status may or may not employ workers. If it does - there is also no restriction on the basis for such employment.

  • Can the MIP be controlled for AML?

    Yes, it is perfectly possible for the relevant control authorities to audit a small payment institution for compliance with its AML/CFT obligations.

    This is due to the fact that small payment institutions are obliged institutions within the meaning of the AML and terrorist financing law of 1 March 2018, as a result of which they have obligations such as, inter alia, having an AML policy, carrying out CDD procedures, including, above all, KYC, in relation to their customers, or training their employees in terms of AML.

  • Does the MIP have to keep special accounts?

    No, the regulations do not provide MIPs with specific accounting obligations.

    It will therefore depend on the legal form of the business, the preference of the entrepreneur and other circumstances unrelated to the MIP.

  • Can there be foreigners on the board of the MIP or among the partners?

    Yes, shareholders and board members in a small payment institution can be foreigners, as well as foreign business entities (e.g. companies).

  • What is the difference between an MIP and a BUP (payment service bureau)?

    The main difference between an MIP and a BUP is the scope of the business. The MIP provides a better solution for entrepreneurs who plan to operate on a larger scale. A Small Payment Institution provides an opportunity to test the payment services business, which is beneficial for entrepreneurs who would like to prepare a possible application for authorisation for a national payment institution. As mentioned above, the average of the total amount of payment transactions over the previous 12 months carried out by the BUP (including agents through which payment services are provided) must not exceed the amount of €500,000 per month. For MIPs, this limit is €1,500,000 per month.

  • What is the official fee for registration?

    Obtaining an entry is subject to a stamp duty of PLN 616.

  • What services cannot be provided by an MIP?

    A small payment institution may not provide a payment initiation service (PIS) and an account information service (AIS)

Do you have any questions? Contact us

Do you need support for the MIP? Contact us

The topic of MIP is broad and complex. It also generates a high risk of mistakes being made. Fortunately, you do not have to explore these issues on your own.

Benefit from the experience and knowledge of specialists. Contact us for assistance in registering and operating a Small Payment Institution.

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