Integration of inFakt accounting with UniCredit accounts (embedded banking)

We advised inFakt on the project:

Negotiation of the main agreement with UniCredit regarding the provision of banking services directly in the inFakt online accountancy service

Embedded banking is one of the strongest trends in the global financial market. It involves providing banking services directly within other online services — marketplaces, platforms or industry-specific applications — so that clients can access banking services without leaving the service they are already using.

In the case of inFakt, we are talking about the “set up a business with a bank account” model: the user manages both accounting and banking functions exclusively from one service. The banking functionality is provided by UniCredit, operating in Poland through a branch, while the entire customer experience remains in the inFakt environment. The main challenge of embedded finance is reconciling two roles. Compliance obligations lie with the financial institution — in this case, UniCredit. However, it is actually the third-party online service provider — in this case, inFakt — that must implement them, even though it does not itself fall under banking regulations. Designing such a model requires precise allocation of tasks, responsibilities and risks between the parties, while ensuring full compliance with the law.

The project shows that mature embedded banking implementations in Poland are possible — provided the business model is built on solid legal foundations. Combining accounting and banking services in one service is a real benefit for entrepreneurs, and a well-constructed agreement and compliance architecture are a prerequisite for the success of such solutions.

DLK’s advisory included:

• Negotiation of the main agreement, including the main commercial terms, liability, termination of the agreement and exit plan, relationship with card organisations, marketing, regress.
• Advising on compliance with Polish banking outsourcing and banking secrecy legislation in the context of UniCredit’s activities through a branch in Poland.
• Advising on key compliance requirements, including strong customer authentication, complaints, DORA, GDPR, banking secrecy