Financial
Real & Physical
Case study
Levionis SP ZOO
Services Provided: End-to-end VASP formation in Poland, including company incorporation, registration, AML/KYC policy development, and ongoing regulatory and reporting support.
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Crypto License
CASP License Poland
Plan a MiCA route while Poland's crypto-asset law is pending
Fact Checked by: Mark Gofaizen
Overview
Regulatory & Service Snapshot
As of October 2026, Poland has not adopted its national act on the crypto-asset market: the President vetoed three successive versions of the act, and the Sejm failed to override the latest veto on 4 September 2026. As a result, no Polish authority has yet been designated to supervise crypto-asset service providers under MiCA, and CASP authorisation cannot currently be obtained in Poland. Crypto-asset services may be provided in Poland by CASPs authorised in another EU Member State.
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. Since 1 July 2026, crypto-asset services in Poland may only be provided with a MiCA (CASP) authorisation. 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.
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, a CASP license is required in Poland, but it cannot currently be obtained there because Poland has not yet adopted its national MiCA implementing act.
What is a Poland CASP license?
The MiCA Regulation has applied in full since December 30, 2024, which means changes for crypto service operators across Europe. Now, companies registered as VASPs in Poland must obtain a Crypto Asset Service Provider (CASP) authorisation; until Poland adopts its national MiCA implementing act, this is only possible in another EU Member State. The transition period for Polish VASPs ended on 1 July 2026; since then, an entry in the Polish register of virtual currency activities no longer permits providing crypto-asset services.
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 had to obtain a CASP authorisation before the end of the transition period (each jurisdiction set its own deadline, 1 July 2026 at the latest) to continue operating in the EU.
- 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
35 000 EUR
- 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
Legal and Consulting Services
from 1 550 EUR/month
- 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.
HR & Training Services
from 900 EUR/month
- 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.
Compliance & IT Audit Services
from 4 000 EUR/quarter
- 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 competent authority checks the application for completeness within 25 working days; if the application is incomplete, it sets a deadline for providing the missing information. The second stage involves a comprehensive assessment of the application, leading to a final decision within another 40 working days. At this stage, the competent authority may request additional information no later than the 20th working day of the assessment; such a request suspends the assessment once, for up to 20 working days.
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.
However, CASP applications cannot currently be filed in Poland and no application fee has been set, as the national act on the crypto-asset market has not been adopted.
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.
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.
- Because Poland did not adopt a national act shortening it, the MiCA transitional period for providers entered in the Polish virtual-currency register ran until 1 July 2026. It has now ended: a VASP register entry no longer permits the provision of crypto-asset services in Poland or abroad.
- CASP applications cannot currently be filed in Poland because the national act on the crypto-asset market has not been adopted.
- Since 1 July 2026, crypto-asset services in Poland may only be provided by CASPs authorised under MiCA in another EU Member State and passported into Poland; former VASP registrations no longer permit these services.
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 meant they could continue operating with an existing registration until that date, but the transition period has now ended. 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:
Procedures required to apply for a CASP license 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, but since 1 July 2026 a register entry no longer permits providing crypto-asset services, and a MiCA (CASP) authorisation can currently only be obtained in another EU Member State. 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.
Client Testimonials
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Excellent service! The communication is fast and friendly, we are very satisfied with received comprehensive package of services such as legal consulting, full turnkey crypto company formation in Lithuania, assistance in bank account opening for "high risk" business, human resources acquisition etc. Highly recommended!
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Founder & CEO. TRASTRA
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