Crypto License in Poland

Check Your Business Fit

Client Services
Holding, exchanging or advising on customers’ crypto-assets can require CASP permission.

Separate Permissions
Issuers of asset-referenced tokens (ARTs) and electronic money tokens (EMTs) follow separate rules. Assess payment services and financial instruments under the Markets in Financial Instruments Directive (MiFID) separately.

Outside or Uncertain Scope
Software, lending, decentralized arrangements and token classification need individual analysis. A label does not establish exemption.

Identify the Applicable Route

Activity	Current Legal Route	Authority	Passporting	Limit
Ordinary CASP	Articles 62/63 authorization	Home competent authority	Article 65 notification	Authorized services only
Eligible financial entity	Article 60 notification	Relevant competent authority	Eligible scope	Services covered by existing permission
EU-authorized provider serving Poland	Home permission and notification	Home authority	Article 65	Other regulated activities need separate permission

Under Article 59, ordinary CASPs need a registered office in an EU Member State where at least part of their services is carried out, effective management in the EU and at least one EU-resident director. An address alone is insufficient.

Map the Services You Provide

Article 3 lists ten services:

• Custody and administration; operating a trading platform
• Exchange for funds; exchange for other crypto-assets
• Executing orders; placing crypto-assets; receiving and transmitting orders
• Advice; portfolio management; transfers on clients’ behalf

Define Your Support Scope

Gofaizen & Sherle’s CASP application support can cover:

• Assessment: review your activities and route; the authority decides authorization.
• Entity and Office: coordinate setup; you run genuine operations.
• Application and Governance: prepare documents; management supplies evidence and implements controls.
• Systems and Staffing: coordinate technology, transfer controls and recruitment; vendors build systems and auditors check them where applicable.
• Filing and Passporting: assist with a confirmed receiver and relevant permission.
• Ongoing Support: advise on policies and operations; management remains responsible.

Compare Quote Based Scopes

Scope	Deliverables	Exclusions	Professional Fee	Official and External Fees
Readiness Assessment	Review activities, gaps and route	Authority decisions; your implementation	Individual quote	Confirm separately
Application Preparation	Prepare application and governance documents	Polish filing conditional; management implements	Individual quote	Confirm filing and vendor costs
Ongoing Support	Advise on policies and operations	Bank decisions; management remains responsible	Individual quote	Confirm recurring costs

Confirm tasks, taxes and charges in your quote. Fund safeguards and operations separately.

Gather Your Starting Information

Prepare for assessment:

• Entity details and Legal Entity Identifier (LEI)
• Services, customer markets and fund flows
• Ownership and management information
• Safeguards and financial forecasts
• Governance and financial-crime controls
• Information and communication technology (ICT) and continuity plans
• Service-specific custody, platform or execution policies

The full application needs further evidence.

Preparation and Review

Documents, systems and staff determine preparation time. Article 63 sets authority clocks in working days:

1. Receipt acknowledged within 5 days from receipt.
2. Completeness checked within 25 days from receipt.
3. Decision made within 40 days from a complete application.
4. Applicant notified within 5 days after the decision.

A permitted first substantive information request can pause assessment for up to 20 working days. These clocks do not guarantee a launch date.

Understand the Applicable Framework

Ordinary CASPs must maintain prudential safeguards equal to the higher of the class minimum or 25% of the previous financial year’s fixed overheads. New businesses forecast fixed overheads for their first 12 months. Qualifying own funds, insurance or comparable guarantees, or a combination may meet Article 67 conditions. Eligible Article 60 entities are exempt from Article 67.

Class 1 is €50,000 for execution, placing, transfers, receiving/transmitting orders, advice and portfolio management. Class 2 is €125,000, adding custody and both exchanges. Class 3 is €150,000, adding a trading platform.

Current CASP Application Status in Poland

A confirmed procedure for submitting CASP applications in Poland has not been identified. Before filing, check which authority can receive your application and whether it has published submission instructions.

The Sejm’s record for Bill 3173 shows a proposed crypto-assets law, with the latest recorded status dated October 6, 2026. A bill does not establish an available application route.

Item	Official Evidence	What It Means	Before You Proceed
Polish CASP application route	October 13 review	Submission procedure remains unconfirmed	Confirm the receiving authority and filing instructions
Proposed national law	Sejm Bill 3173, status dated October 6	The proposal is not evidence of a law taking effect	Check its progress and any published effective date
Legacy VASP registration	KNF notice dated June 23	Registration does not replace MiCA permission after July 1, 2026	Confirm the permission covering your planned services

Before submitting documents, confirm the receiving authority and its filing procedure.

Plan Your Operational Controls

Management and Outsourcing
Management answers for governance and outsourcing under MiCA Articles 68/73. Keep reviewing policies.

Client Assets
Under Article 70, operations segregates client assets and funds and places relevant non-EMT funds with a credit institution or central bank by the next business day.

Preventing Financial Crime
Assigned staff check customers and beneficial owners, monitor activity and provide training under Polish AML rules. Update risk assessments as needed and at least every two years.

Transfer Information
Operations and compliance collect required TFR transfer information and handle missing data.

ICT Resilience
ICT managers report incidents, test systems according to risk and check vendors’ work under DORA.

Handling Records, Complaints and Conflicts
Compliance handles complaints free and reviews conflict policies annually. Keep MiCA records five years, up to seven on authority request. Keep AML customer records five years from relationship end or an occasional transaction, subject to extension conditions.

Avoid an Unauthorized Launch

A legacy virtual asset service provider (VASP) entry does not permit MiCA services after July 1, 2026. Unauthorized operations create enforcement risk.

Prepare for Account Provider Review

Banks, electronic money institutions (EMIs) and payment service providers decide account acceptance. Gofaizen & Sherle helps prepare:

• Authorization status
• Ownership and source of funds
• Fund flows, customers and markets
• Operational controls

Relevant payment services require separate permission.

Assess Tax and Reporting Duties

Corporate income tax (CIT) is usually 19%. Qualifying small or new businesses may pay 9%, with income limits and exclusions. Capital gains stay at 19%. Private investor rules differ.

Value-added tax (VAT) exemption covers qualifying currency-exchange transactions; custody, other services and tokens need separate assessment.

Under enacted DAC8 tax-information rules, applicable reporting providers’ first period is 2026, with reporting due June 30, 2027. Tax reporting does not authorize services.

Compare Other EU Home States

Choose a home for genuine operations under Article 59. Passporting covers authorized services after Article 65 notification.

Jurisdiction	Filing Availability	Regulator	Substance	Passporting	Practical Fit
Lithuania	Published application route	Bank of Lithuania	Genuine activity; shell companies scrutinized	Article 65 scope	Documented management arrangements
Spain	Published manual/forms	Spain’s securities regulator (CNMV)	Article 59	Article 65 scope	Spanish home operations
Czech Republic	Published route/contact	Czech National Bank (CNB)	Article 59	Article 65 scope	Identified receiver
Germany	Published procedure	Germany’s financial regulator (BaFin)	Article 59	Article 65 scope	Formal submission and introductory meeting