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”.

1. DLK LEGAL KORUS SP.K.
www.dlk.legal
dlk@dlklegal.com
Warsaw, ul. Ogrodowa 58, tel.: +48 22 652 26 18
Cracow, ul. Jana Kilińskiego 2, tel.: +48 12 31 51 841
DLK LEGAL ADVISES KARDYNAŁ&KARDYNAŁ ON OBTAINING THE FIRST TPP-ONLY
PAYMENT INSTITUTION LICENCE IN POLAND
Warsaw, 03.03.2021
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.
DLK Legal is a modern law firm focused on providing regulatory and transactional support for financial institutions and new
technologies clients. DLK Legal specializes in advising banks, payment institutions, e-money institutions, investment funds, and
firms on the insurance market, and their clients and service providers. We advise supervised entities on issues such as banking law,
payment services, compliance, AML, corporate law, IT law, personal data protection, and consumer law. DLK experts advise for
instance on projects at the point of convergence between banking and new technologies, on FinTech and new technologies deals,
on implementation of key legislation (PSD2, GDPR), and licensing processes in Poland and elsewhere. Due to membership of the
World IT Lawyers network, and in cooperation with the Fintech Lawyers Network, we are realising numerous projects with a cross-
border dimension. We are intensively involved in representing financial institutions and industry organisations in the Polish and EU
legislative process.