Global FinTech Guide
Country Name
Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).


API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.


Attitude of the country towards online-banking services

The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego) undertakes a number of activities to support the development of financial innovation in the sector of online-banking. It decided to offer interested entities assistance also in the technological field. For this purpose, a virtual sandbox was launched in the IT infrastructure of the office, i.e. a test environment that allows simulating selected functionalities and services offered in the financial market. Test participants using the virtual sandbox have access to the IT infrastructure which allows them to verify their business assumptions in controlled conditions of the test environment.

The first UKNF virtual sandbox made available to interested entities allows them to simulate a number of banking operations and test solutions based on the Open API interface which is compliant with the Polish API standard. An entity planning to offer an innovative financial payment service can apply to the Innovation Hub Program, where they will be able to consult their idea and test its functionality in an ICT test environment that simulates the basic services provided for in the PSD2 Directive, i.e., PIS, AIS and CAF.

Legal affairs

Obligations and requirements to provide online-banking services described above

Online-banking services are mostly regulated by the Banking Act (prawo bankowe) and Payment Services Act (ustawa o uslugach platniczych), which implements the PSD2 directive into the Polish legal system. 

FinTechs' activities in the area of AP-Banking are mainly regulated by the Payment Services Act, which implements the PSD2 directive into the Polish legal system. The act established a separate category of entities providing payment services, collectively referred to as third party provider. This category coexists alongside service providers such as banks, payment institutions or payment services bureaus. On this basis, third parties can provide two types of services: the initiation of a payment transaction (Payment Initiation Service, “PIS”) or access to account information (Account Information Service, “AIS”).

Activity as an AIS provider is a regulated activity and requires prior registration in the register of payment service providers and electronic money issuers kept by the Financial Supervision Authority. The entry in the register is subject to a fee of PLN 616 (approx. EUR 130).

In the case of PIS and AIS services, a Financial Supervision Authority permit to operate as a domestic payment institution (“KIP”) is required. The cost of the licensing process is EUR 1,250.

The initial capital required to operate as a domestic payment institution providing PIS and AIS services is EUR 50,000. AIS-only services are not subject to minimum capital requirements.

A bank may be established in the form of a joint stock company and a cooperative bank, after obtaining a license from the Polish Financial Supervision Authority

The application should include confirmation of payment of stamp duty in the amount equivalent to 0.1 per cent of the share capital (for a bank in the form of a joint stock company) or the share fund (for a cooperative bank)

The initial capital of a bank may not be lower than EUR 5 million. In the case of cooperative banks whose founders have expressed their intention to affiliate with a selected affiliating bank, the initial capital may not be lower than the PLN equivalent of EUR 1 million.

In addition, banks are subject to the European Union's CRR regulation governing capital requirements.

Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area


Economic conditions

Market size for online-banking services and biggest companies in this business area

At the end of 2021, banks had 22.4 million active electronic banking customers. 43.4 million bank customers had an agreement enabling access to electronic channels. 

Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area

In the Polish banking sector, due to the scale of its innovation, mobile banking – which in Western Europe is developed by technology companies – is developed by the banks themselves. As a result, the possibilities of introducing innovative services by non-bank FinTechs may be relatively small in Poland compared to other countries, where e-banking solutions have not yet been fully developed. However, Polish consumers are friendly towards modern financial services, so there is still a lot of potential to explore the market. 



© 2022, WKB Wiercinski, Kwiecinski, Baehr. All rights reserved by WKB Wiercinski, Kwiecinski, Baehr as author and the owner of the copyright in this chapter. WKB Wiercinski, Kwiecinski, Baehr has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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