
CASP license in Poland
Poland has established itself as a favorable jurisdiction for obtaining a Crypto-Asset Service Provider (CASP) license, supported by a robust regulatory framework overseen by the Komisja Nadzoru Finansowego (KNF) or the Polish Financial Supervisory Authority. This body is responsible for supervising CASP companies, ensuring adherence to regulatory standards, and promoting a stable financial environment.
Over the last few years, the cryptocurrency market in Poland has shown significant growth dynamics and rapid adoption of innovations by the population. According to forecasts, in 2025 the number of users of virtual currencies in Poland will reach 7.91 million. The average amount of investment in digital assets is – zł1000, most often they are bought for long-term savings and further profits from price growth, participation in ICOs, or to make payments.
In Poland, cryptocurrencies do not have the status of a means of payment but fall under the definition of assets, according to the AML/CFT Act of 2018.CASP licenses in Poland became mandatory in 2025 as part of MiCA regulations. Poland offers cryptocurrency companies access to the EU market, transparent conditions and low transaction costs. The license opens up business prospects and strengthens Poland’s position as the fintech hub of Europe.Service packages for registration of CASP license in
There are 1,841 cryptocurrency companies registered in the Register of Entities in virtual currencies, with around 50 openings each year. More than 200 crypto-ATMs are operating across the country, and the number of companies accepting virtual assets as payment for goods and services is growing.
Poland’s CASP license is the key to entering the single crypto-market of the EU zone. The largest business platform with advanced financial services in Central and Eastern Europe has become attractive for many companies for several reasons: stable and clear legislative framework, digital regulatory process, low level of corruption, wide demand for virtual assets and services, wide choice among highly qualified IT specialists with optimal salary level, low operating costs.
Since 2006, the Polish Committee for Financial Supervision (KNF) has been the regulator of the financial environment. It is responsible for ensuring that all market participants comply with the standards of local and European legislation, licensing activities, maintaining registers, and training market participants.
According to the Cryptoasset Markets Regulation (MiCA), which all EU member states are obliged to comply with, the CASP license in Poland will be available in 2025.

What is a Poland CASP license?
The adopted MiCA Regulation comes into force on January 1, 2025, which means changes for crypto service operators across Europe. Now, companies holding a Poland crypto license must switch to a Crypto Asset Service Provider(CASP) License in Poland. To adapt to the new standards when applying for a new license in Poland, there is a transition period until June 30, 2025, after which it will be illegal to operate a crypto business with a VASP.
Key points to be considered by VASP holders to successfully obtain MiCA CASP:
- The amount of equity capital depends on the business model, the services provided by the operator, and the specific class (Class 1 – €50000, Class 2 – €125000, Class 3 – €150000). Importantly, it is not only about the business model but also about the types of services provided.
Annex IV of the MICA describes in detail what each class of crypto operator can offer its clients. For example, Class 1 operators are provided with the ability to legally handle customer orders, accept and transmit their orders, and also provide consulting services. Class 2 providers (authorized capital – €125,000), in addition to Class 1 services, are granted the right to provide custodial services, as well as to exchange fiat and/or crypto-coins. The most extensive range of services is provided only by a Class 3 operator, with a contributed share capital of €150000 (all services including the operation of the trading platform). - Having a bank account in the EU for transaction processing and financial compliance is mandatory for all companies wishing to obtain CASP. In addition to complying with Directive 2015/2366, AML/KYC procedures, the MICA Regulation introduced additional rules for consumer protection as well as ensuring market integrity.
- Local presence / physical office to ensure effective management (substance rules) and at least one of the directors must be a resident of the EU (in this case Poland).
- VASP operators will not automatically be eligible to provide CASP services in the EU. VASP was introduced by the FATF and operated globally, however, CASP is based on MICA regulations and covers the wider activities of AML/KYC-compliant operators in the EU market. Accordingly, VASP operators are required to apply for CASP during the transition period (each jurisdiction has its deadline) to continue to operate throughout the EU area.
- CASP license grants passporting rights, which means that it is possible to operate in the whole EU zone without obtaining additional licenses in each of the countries.
Service packages for CASP in Poland
Legal Frameworks Setup
- Reviewal of the business model and adjust the business plan
- Compliance management framework development
- Internal governance and control framework
- Risk management framework development
- Business continuity management framework development
- ICT and security framework development
- Financial reporting framework development
- Travel Rules implementation into legal frameworks
- Customer relations framework development
- Development of a training program
- Supervision over implementation policies
- Communication with regulators (guiding through the application process, answering their requests, asking for clarifications regarding the implementation of regulations, etc.);
- Management of certain processes (e.g., passporting, investigations, trademark registration, etc.);
- Participation in meetings regarding frameworks implemented (e.g. workshops for risk assessment, etc.);
- Drafting and amending legal documents (e.g., if the auditor asked to amend policies, contracts, etc.);
- Communication with third parties (e.g., banks, KYC/KYT providers, etc.);
- Communication with regulators (guiding through the application process, answers to their requests, asking clarifications regarding implementation of regulations, etc.);
- Answering to client’s claims and ensuring proper communication;
- Search of third parties necessary for business (auditor, office, KYC/KYT provider, etc.).
- Setting up accounting software and framework for processing financial statements;
- Helping your internal (or external) accountant to understand the specifics of crypto transactions;
- Ensuring communication with auditor and tax authorities;
- Financial reporting & other reports (e.g., BoL, Statistics, counterparties);
- Bookkeeping and other accounting-related task.
- Seeking for the appropriate personnel and ensuring their integration (incl. finding a replacement in any case);
- Employment and unemployment of personnel;
- Preparing employees for the interview with Bank of Lithuania for the licensing process;
- Integration of employees into the company’s ecosystem;
- Payroll and declarations related thereof;
- Communication with BoL in case of key person change.
- Employee training, including new employees, following regulatory requirements (at least annually) and the supervisory authority’s expectations;
- Prepare organization-tailored training and implementation.
- Assisting with the risk assessment (to the extent permitted by audit standards);
- Assisting in-house employees regarding the implementation of an internal control framework;
- Performing regular internal reviews and assessing the effectiveness of the Company’s processes;
- Performing DORA-related tasks: ICT risk reviews;
- Analysis of ICT incidents, analysis of 3rd party ICT service providers, building staff awareness and providing cyber security trainings, assisting in table-top exercises, assisting in regulatory reporting.


Peculiarities of obtaining a CASP license in Poland
The process of obtaining a CASP license in Poland consists of two key stages. First, the KNF reviews the application for completeness and provides feedback within 40 working days. During this period, the KNF can ask for additional information, which may extend the review by 20 working days for each request without a limit on extensions. The second stage involves a comprehensive assessment of the application, leading to a final decision within another 40 working days. Similar to the first stage, the KNF may request further clarifications at this point, allowing for a single 20-day extension if necessary.
One of the advantages of establishing a CASP in Poland is the country’s competitive labor market. Poland boasts some of the lowest labor costs in the European Union, significantly reducing operational expenses for companies that hire local staff.
Furthermore, the application fee for a CASP license is set at €4,500, making it a relatively accessible option for businesses looking to enter the crypto-assets market.

Services requiring a CASP license in Poland
The CASP license will allow the following types of services (MICA Art.3):
- Providing custody and management services for crypto assets on behalf of clients;
- Operation of a trading platform for crypto assets;
- Exchanging crypto assets for cash;
- Exchanging crypto assets for other crypto-assets;
- Executing orders for crypto assets on behalf of clients;
- Placement of crypto assets;
- Accepting and transmitting orders for crypto-assets on behalf of clients;
- Providing crypto asset advice;
- Providing crypto asset portfolio management;
- Providing crypto asset transfer services on behalf of clients.
Gofaizen & Sherle assists in obtaining a pan-European CASP license in Poland.
MiCA regulation for cryptocurrency business in Poland
MiCA regulation with its rules and regulations in the European Union began to apply from December 30, 2024. This means that all operators of crypto asset services must now obtain a CASP license.
Timeline for obtaining a CASP:
- As of December 30, 2024, the Chamber of Tax Administration in Katowice can no longer accept applications for VASP registration.
- Companies with a VASP permit can officially operate until June 30, 2025 (the last day of the transition period).
- Until May 1, applications for new licenses are accepted by CASP.
- As of July 1, 2025, VASP licenses will be revoked and companies will not be able to provide crypto services until they receive a CASP license. In order not to interrupt operations, a CASP license must be obtained by June 30, 2025.
- As of October 1, 2025, the VASP registry will be abolished.
Poland is one of the countries that has not had time to adopt legislation to regulate the domestic crypto market. Although the whole sphere is regulated by MICA, local laws are also needed to define the regulator, its functions, and responsibilities. Currently, there is some chaos in the concept of how crypto operators can operate in Poland. KNF cannot consider CASP applications because there is no regulatory framework.
According to MICA, EU member states can extend the “transition period” to 18 months, i.e. until July 1, 2026. For registered VASPs, this means unhindered operation with an existing license. Poland could have shortened this period if it had adopted the relevant legislation by December 30, 2024, which did not happen. But on 02.01.2025 KNF published an official position on its website, which states that in case of adoption of a new law (even after 30.12.2024) Poland has the right to shorten the “transitional period”. Potentially, the temporary misunderstanding between market participants should end in February this year, when the Polish Act ensuring full functionality of MICA regulations will be approved.
The regulations that CASP operators in Poland will be required to comply with are:
Request more information about a CASP licence in Poland
Procedures required to apply for a CASP licence in Poland
Successfully obtaining a CASP license is contingent upon applicants meeting basic requirements before the regulator, namely:
- Providing operational and management documentation describing the services offered, internal management systems and the role of staff, marketing strategies, and financial projections.
- Compliance with risk management procedures and precautions with proof of compliance with all paragraphs of Article 67 of the MICA, controls, and application of AML/KYC, ensuring the segregation of client assets, and describing procedures for maintaining business continuity during crises.
- Providing information on the members of management and evidence of their excellent reputation and experience in the field. Shareholders (with qualified shareholdings) should submit a package of documents for identification procedures and proof of reputation.
- Implementation of technical and customer service mechanisms, namely steps to address and resolve customer complaints, technical description of security measures, and ICT systems.
In addition, depending on the type, of services provided, applicants must submit:
- Principles of platform operation and methods for detecting fraudulent activities in the market.
- In the case of currency exchange, a description of the pricing concept.
- When providing consulting services – proof of experience, and qualifications in this area.
- When making transactions in cryptocurrencies – guidance on the implementation of transfers.
- Description of the implementation of data protection and storage procedures by GDPR.
- Procedures for risk assessment and implementation of necessary measures.
Documentation required for CASP board members
The comprehensive requirements for each board member when obtaining a CASP license, according to Art68. MICA includes confirmation of good reputation with proof of absence of convictions for financial crimes. In addition, the demonstration of knowledge and experience in the field of cryptocurrency management is a mandatory step.
Accordingly, a list of documents is submitted to the regulator:
- CV with a detailed description of activities over the past 10 years;
- a certificate of absence of any criminal record, especially important in the financial sphere;
- declarations with the absence of penalties, bankruptcy;
- personal documents for identification, confirmation of place of residence;
- full information on powers, and responsibilities;
- detailed description of the ownership structure and schemes, financial and non-financial interests with management bodies, shareholders (all liabilities, loan amounts, number of shares).
Conclusion
Poland is one of the prosperous countries of the EU, which maximally welcomes and approves the introduction of innovative technologies, the emergence of new blockchain companies, and the development of the cryptosphere. The introduction of the MICA Regulation has completely changed the requirements for all market participants. There are over 1,800 cryptocurrency companies registered in Poland, which will soon have to go through the authorization procedure all over again. CASP opens up huge prospects for local companies and the possibility to operate legally in the EU region. For Poland as a whole, it is also an opportunity to become a fintech center in the whole of Europe with the prospect of gaining leadership positions on a global scale.