DLK Legal advised Kontomatik in proceedings before the Polish Financial Supervision Authority

DLK Legal advised Kontomatik sp. z o.o. on obtaining a license for a provider of access services to the information on account and entry into the register kept by the Polish Financial Supervision Authority (PFSA). The DLK Legal team was led by associate Krzysztof Korus, J.D., while Kontomatik Group was also advised by the following lawyers: Bartosz Wyżykowski, Szymon Zych and Mikołaj Cegłowski. Advisory services for Kontomatik included a strategic approach to the PSD2 transition period, preparation of the application and representation in the registration proceedings.

Kontomatik is the only Polish entity that has been registered with the PFSA as the Account Information Service Provider Only (AISPO). Previously, Kontomatik Group (Kontomatik UAB) obtained a similar status in Lithuania, becoming the first Central European Fintech to obtain the AISPO status under the PSD2 Directive. DLK Legal also advised in the proceedings before the Bank of Lithuania. Kontomatik belongs to Kreditech Group and collaborates with banks and lending institutions from Poland and other EU countries. It also offers a platform for managing personal finances – Kontomierz.pl.

– Our success before the PFSA is, among other things, the result of many years of experience of DLK Legal in license and registration cases before the PFSA – says Krzysztof Korus. – In the past year alone, we have advised on six completed small proceedings for a small payment institution (MIP) status for the purpose of large and innovative business models. During that time, we have already conducted a total of more than a dozen proceedings before the EU supervisory authorities, including cases for obtaining a license of a payment institution, electronic money institution, the so-called reauthorization, entry into the register of small payment institutions, lending institutions and credit intermediaries.
DLK Legal is a leading market advisor in licensing proceedings in Poland. Since 2012, DLK Legal has successfully participated in dozens of proceedings to obtain or extend a license or registration in the register of payment service providers and lending institutions. In addition to the proceedings before the Polish Financial Supervision Authority, DLK Legal also advised in proceedings before supervisory authorities of other EU member states.

The account information access service is one of the two new payment services regulated under the PSD2 Directive. It involves accessing information about the customer’s online payment accounts (e.g., their bank accounts or electronic wallets) and consolidating the retrieved data to fulfill a purpose agreed upon with the user (e.g., to evaluate their financial situation) by Kontomatik. Account data are retrieved using the access channel of the institution that maintains such accounts (e.g., through electronic banking or a special interface). Although the PSD2 regulations require “only” registration by the AIS provider (and not licensing as in the case of banks or payment institutions), in practice, the scope of requirements and the nature of the proceedings are similar to licensing procedures.

Lawyers involved in the project:

Krzysztof Korus
attorney-at-law, partner Krzysztof Korus

Mikołaj Cegłowski
attorney-at-law, senior associate Mikołaj Cegłowski

Szymon Zych
attorney-at-law, partner Szymon Zych

Bartosz Wyżykowski
attorney-at-law, partner Bartosz Wyżykowski

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