Fintech 2025

POLAND Law and Practice Contributed by: Wojciech Ługowski, Lawarton Lugowski Kapica Spolka Komandytowa

5.2 Regulation of Cross-Border Payments and Remittances

payment systems or alternative clearing mecha - nisms can be introduced, provided they meet regulatory standards and obtain the necessary approvals. BLIK BLIK is a notable example of a locally developed payment rail in Poland. It is a domestic mobile payment system that transforms cashless trans - actions, operating independently of global pay - ment networks (legacy card systems operators). It provides an alternative infrastructure for real- time digital payments and offers seamless inte - gration with the Polish banking system. BLIK supports in-store and e-commerce pay - ments, where customers authenticate trans - actions using a one-time code. It also allows ATM withdrawals and cash deposits without a physical card. Users can make P2P transfers using just a phone number and process instant bank transfers between accounts. The system enables recurring payments for subscriptions, bills and transactions via QR codes, facilitat - ing seamless integration with online and offline merchants. It recently introduced a contactless payment feature using NFC technology, enabling mobile payments without a traditional payment card. BLIK functions exclusively within Poland. Since its launch, it has become one of the country’s most widely used payment methods, surpassing card transactions in mobile banking apps. While currently limited to the domestic market, dis - cussions about its potential expansion to other European countries or integration with interna - tional payment networks are ongoing.

National and EU financial laws regulate Poland’s cross-border payments and remittances. Since Poland is a part of the Single Euro Payments Area (SEPA), the SEPA Regulation also applies. This Regulation allows relevant cross-border cashless payments in euros to be made similarly to domestic ones. The SEPA Regulation applies to all payments across the EU and several non- EU countries. Strict AML measures require customer due dili - gence and usage of KYC protocols. The execution and settlement of cross-border payments do not raise significant regulatory concerns, as the existing framework remains stable and well-defined. The primary focus of regulatory oversight is on AML and CFT compli - ance, ensuring transparency, risk mitigation and the prevention of illicit financial activities. 6. Marketplaces, Exchanges and Trading Platforms 6.1 Permissible Trading Platforms Poland’s fintech market allows various types of marketplaces and trading platforms, each sub - ject to specific regulatory frameworks. Traditional Stock Exchanges Traditional stock exchanges, such as the War - saw Stock Exchange (the “WSE” ), operate under the supervision of KNF and must comply with MiFID II regulations and the Act on Trading in Financial Instruments, ensuring transparency, investor protection and fair market practices. In addition to the main stock exchange, Poland has NewConnect, an alternative trading system

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