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DLK Legal advises Kardynał&Kardynał on obtaining the first TPP-only payment institution licence in Poland
Warsaw Office
Ogrodowa City Gate
ul. Ogrodowa 58
00-876 Warsaw
tel. +48 22 652 26 18 

warsaw@dlklegal.com

Cracow Office
ul. Jana Kilińskiego 2
30-308 Cracow
tel. +48 12 315 18 41

cracow@dlklegal.com

DLK Legal successfully advised Kardynał&Kardynał sp. z o.o. on obtaining a license from the Polish Financial Supervision Authority (PFSA) for providing payment initiation services (PIS) and account information services (AIS) as a payment institution. The DLK team working on the licensing process was headed by Bartosz Wyżykowski and supervised by the partner dr. Krzysztof Korus. Also advising on the project were Szymon Zych, Bartosz Gauza, Aleksandra Księżak and Mikołaj Cegłowski.

The project for Kardynał&Kardynał included comprehensive drafting and implementation of documentation and internal procedures necessary for a payment instutition’s operations, drafting the application, and representation in the proceedings before the PFSA. Dr. Krzysztof Korus, DLK Legal partner, says: “This is the first time a payment institution license has been obtained in Poland to cover only PIS and AIS services. This confirms that the value of open banking extends to business models from outside of the core of the financial industry. This always is a challenge, though, since it requires the fulfillment of a number of formal requirements of a “full” payment institution license, while the business potential of TPP services is truly immense”.

Kardynał&Kardynał is an accounting and bookkeeping company. In 2018 the firm was distinguished by Forbes as one of the most rapidly developing company in its region. The company intends to use PIS and AIS services to provide its customers with the top innovative accounting solutions. Its TPP license is a great step to meet the technological challenges in a highly competitive business environment.

Payment initiation services and account information services are two new categories of payment services regulated by PSD2. Both services are usually provided through a dedicated interface of the user’s bank and their providers are supervised by financial authorities. PIS and AIS enable development of new products and services based on the initiation of payment transactions and processing of data related to user’s payment accounts.