Poland has enacted legislation granting non-bank payment institutions and electronic money institutions direct access to its principal interbank payment systems, SORBNET3 and Elixir, after the President signed the amendment on 9 March 2026 and it was published in the Journal of Laws on 13 March. The measure enters into force 14 days after publication, implementing Article 35a of the EU Payment Services Directive into Polish law.
The new legal framework establishes the operational, compliance, and technical requirements that payment institutions and electronic money institutions must satisfy to participate directly in designated payment systems. Until now, only banks, the National Credit Union, and select financial market infrastructure operators could access SORBNET3 and Elixir. Non-bank providers relied on correspondent banking arrangements to route payments through the national infrastructure, adding cost and settlement latency to their operations.
SORBNET3 is the real-time gross settlement system operated by the National Bank of Poland, handling high-value time-critical interbank transfers. Built on ISO 20022 messaging standards, the system currently serves the NBP, 45 domestic banks, the National Credit Union, and several infrastructure operators including Krajowa Izba Rozliczeniowa, Krajowy Depozyt Papierow Wartosciowych, and Polski Standard Platnosci. Elixir, operated by KIR, is Poland's principal retail clearing system for credit transfers, direct debits, and settlement cycles.
The legislation represents a structural shift in the Polish payment market. Direct system access allows licensed non-bank institutions to clear and settle payments on their own account rather than depending on banking intermediaries, reducing processing costs and operational dependencies. For the broader market, wider participation could increase competition in payment services and accelerate the development of new products built on top of national clearing infrastructure.
Poland's approach follows a pattern seen across the European Union as member states transpose PSD2 provisions that require designated payment systems to open access to authorized non-bank institutions. The implementation comes as Express Elixir, Poland's instant payment system also operated by KIR, continues to grow rapidly, having processed 636 million transactions in 2024. Direct access to Elixir and SORBNET3 could enable payment institutions to build more efficient connections to both batch clearing and real-time settlement channels.
The practical impact will depend on the number of non-bank institutions that meet the technical and compliance standards required for direct participation. SORBNET3 in particular handles large-value payments above one million zloty, and the operational demands of real-time gross settlement require robust liquidity management and system resilience capabilities that not all licensed institutions may currently possess. The NBP and KIR will need to establish onboarding processes and technical testing regimes for the new participant category.