O czym mówiliśmy
On 2020-09-18 Cashless.pl examined the Polish Financial Supervision Authority (KNF), small payment institutions (MIP) and PSD2. The case mattered to businesses because such regulations shape not only the wording of legal documents, but also the design of sales, payments, security and customer-communication processes. The discussion focused on the practical consequences of implementation and the risks arising from an overly narrow or overly formal reading of the rules. The outlet asked Tomasz Klecor for comment on the topic of the publication.
Co podkreślaliśmy
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The scope of KNF expectations towards small payment institutions should follow from the Polish Payment Services Act.
Excessive elaboration of guidance documents may create obligations that the legislator did not expressly provide for.
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A ban on operating outside Poland does not have to mean a ban on every cross-border payment.
A transfer alone from a Polish account to a foreign account does not necessarily mean carrying out a business activity in another country.
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Small payment institutions need clear supervisory rules, since the registration model was meant to lower the entry barrier.
Imprecise supervisory practice may discourage fintechs from operating legally.