Crypto License in Poland
Poland remains one of the most attractive destinations for obtaining a Polish crypto license in the European Union. With the introduction of MiCA regulations, the licensing process has become even more transparent and standardized. Before obtaining a VASP license in Poland, it is important to know what requirements you need to meet and what benefits you can get by starting a crypto business.
Gofaizen & Sherle provide professional support in obtaining a Polish crypto license (VASP in Poland) remotely with a turnkey contract guarantee in less than 8 weeks and offer a ready-made solution.
Before the introduction of the MiCA regulation in Poland, a system of registration of virtual asset service providers (VASP) was in place, rather than licensing. Regulation was based on the Act on Counteracting Money Laundering and Terrorist Financing (2018). Under the national Poland crypto license register, each company had to establish a legal entity as a Sp. z o.o. with a minimum share capital of PLN 5,000 (approximately EUR 1,200), implement AML/KYC procedures, and appoint a responsible employee. Such companies were allowed to provide currency exchange services, crypto asset transactions, and asset storage, while complying with AMLD provisions and reporting to the GIIF.
After completing the registration procedure, the company obtains the legal right to:
- Exchange cryptocurrencies for fiat currencies and vice versa (e.g., EUR to BTC or BTC to USD);
- Exchange between different virtual assets (e.g., BTC to ETH);
- Provide digital asset storage services, including managing private keys on behalf of clients.
Starting in 2025, Poland will begin implementing the MiCA regulation, which introduces mandatory licensing for crypto companies (CASP) and tightens requirements for capital, internal control, and information disclosure. The bill to implement MiCA is already in the final stages of approval and could come into force in the second or third quarter of 2025.
During the transition period (until mid-2026), existing service providers will have to apply for a full Poland crypto license in CASP format. The MiCA regulation aims to harmonize national legislation with pan-European standards and ensure a higher level of transparency, security, and legal protection for all participants in the crypto market in Poland.
Ready-made company with crypto license in Poland
14 000 EUR
Price
7-9 weeks
Duration
Advantages of a Poland crypto license
The trust of clients and investors
Possession of a crypto license in Poland becomes a kind of guarantee of competence, reliability, and high professionalism of the company. Most clients actively prefer to cooperate with licensed firms, as it provides them with peace of mind and confidence that their investments are in safe hands and under the protection of the jurisdiction.
Scaling up
Poland’s crypto license allows companies to explore new markets and establish partnerships. Thanks to Poland’s authoritative cryptocurrency laws, licensed companies often have advantages when dealing with international partners and clients.
Security and legal stability
Poland’s inherent business protection and jurisdictional stability – provide license holders with confidence in the legality of their actions, and protection of their rights and interests as a business. This allows us to work and scale in the legal environment with peace of mind.
Transparent taxation
Cryptocurrency license in Poland provides businesses with a clear understanding of their cryptocurrency tax obligations. This allows companies to strategically plan their finances and avoid unforeseen fines or penalties, which is becoming an important factor in the volatile world of cryptocurrencies.
Access to digital assets
Polish crypto exchanges provide license holders with access to a variety of digital assets, including altcoins and new tokens other than Bitcoin and Ethereum. This promotes portfolio diversification and creates potential for investment.
Security
Crypto exchanges in Poland give top priority to security to protect users’ funds and sensitive data. They actively apply strong security protocols, including two-factor authentication (2FA), ensuring that funds and sensitive user data are well protected.
Request more information about the Poland’s crypto license.
Service packages for registration of crypto license in Poland
Choose the best package of services for obtaining a crypto license in Poland (Polish VASP).
Corporate account for business activity + Board member/AML Officer with local residence + entire maintenance.
- Full Turnkey Company Transfer
- Registering as Polish VASP within the Regulator
- Address of Registration for one year
- Obtaining Polish Trusted Profile (“EPUAP”)
- Individual AML/KYC Policy
- Handling the communication with the General Inspectorate of Financial Information (GIFI)
- Apostilled and Translated corporate documents
- Assistance in opening segregated Bank accounts (C2B/B2B) under guarantee key result
- Search, integratioon, direct employment agreement for Local Board Member / AML officer.
Exhaustive set up of company infrastructure for the start of operational activity.
- Full Turnkey Company Formation
- Registering as Polish VASP within the Regulator
- Address of Registration for one year
- Obtaining Polish Trusted Profile (“EPUAP”)
- Individual AML/KYC Policy
- Handling the communication with General Inspectorate of Financial Information (GIFI)
Registration of the Virtual Asset Service Provider under the minimum regulatory requirements.
- Full Turnkey Company Formation
- Registering as Polish VASP within the Regulator
- Standard AML/KYC Policy
Persons who deal with virtual currencies and representatives of Polish crypto companies must have knowledge or experience related to activities in this field. If requested by the regulatory authority, proof of this requirement should be provided.
Requirements for obtaining a crypto license in Poland in 2025
In 2025, the pan-European MiCA regulation (EU Regulation 2023/1114) will come into force, harmonizing Polish crypto regulation with EU requirements. All crypto companies must transition from simplified VASP registration to CASP licensing.
Company registration in Poland.
The company must be registered in Poland as Spółka z o.o. or Spółka Akcyjna (S.A.), with data entered in the National Court Register (KRS). Articles of association, legal address, and information about the participants are required.
Minimum authorized capital.
The amount of capital depends on the type of crypto services:
- Class 1 CASP (e.g., consulting) from EUR 50,000;
- Class 2 CASP (exchange, issuance, fiat transactions) from EUR 125,000;
- Class 3 CASP (storage of third-party assets) from EUR 150,000.
Until MiCA is implemented, the previous conditions apply. VASP registration is possible with a capital of PLN 5,000 (approximately EUR 1,200), making a cryptocurrency license in Poland one of the most affordable in the EU at the moment.
Physical office and resident director.
The company must have an office in Poland and at least one EU resident director. These conditions ensure transparency and the possibility of supervision by Polish regulators.
Required documents.
To apply, you need to submit the articles of association, a business plan, CVs of the participants, a list of crypto services provided, and a description of the organizational structure.
Reputation and qualifications.
Management and beneficiaries must have relevant experience or education and no criminal record for economic or financial crimes.
AML/KYC policies and internal procedures.
The company must implement AML/KYC procedures, appoint responsible officers (MLRO and CCO), organize transaction monitoring, customer identification, and sanctions control.
Electronic signature and PESEL.
Each company participant must have a PESEL number and an electronic signature or trust profile (Profil Zaufany) to submit documents via government portals.
Financial reporting and notifications.
After obtaining a license, the company is required to maintain accounting records, submit reports to the KNF (Komisja Nadzoru Finansowego), and inform regulators of any changes.
Staff qualifications.
The staff must include specialists with experience in cryptocurrencies, fintech, and compliance. It is also necessary to organize a system of regular training and risk assessment.
Procedure for obtaining a Crypto license in Poland
Given the updated regulations under MiCA and the current Poland crypto regulation, the process of obtaining a VASP license in Poland requires comprehensive preparation. It includes company registration, compliance with regulatory requirements, and the organization of operational infrastructure. The business can only be launched after all legal and compliance procedures have been completed.
Collection of documents from the client.
Result: A package of documents is prepared, the budget and scope of the project are determined, and a power of attorney is ready.
- Analysis of the project concept and planned crypto services;
- Collection of data for KYC: shareholders, structure, and jurisdictions;
- Preparation of a power of attorney for actions in Poland;
- Checking the uniqueness of the company name;
- Initial check of the director and participants for criminal records;
- Receipt and processing of documents in the Polish office.
Company registration in Poland.
Result: The company is registered in the National Court Register (KRS) and ready to apply for a crypto license.
- Translation and legalization of documents;
- Notarization of founding documents;
- Company registration in the commercial register;
- Obtaining a PESEL tax number for participants;
- Assigning a legal address and authorized capital.
Preparation for CASP licensing.
Result: The company completes the preparation of a full package of documents and procedures by MiCA requirements. At this stage, internal policies are formed, responsible persons are appointed, and all documentation is brought into compliance with the requirements of the regulator.
- Development of AML/KYC policies taking into account the type of crypto services;
- Submission of documents to tax authorities;
- Appointment of MLRO and CCO;
- Adaptation of internal procedures to MiCA requirements;
- Translation of all documentation into Polish.
Registration of activities as a crypto provider (CASP).
Result: The company is entered in the register of virtual asset service providers (CASP) and can legally provide services under a crypto license in Poland.
- Submission of an application and a package of documents to the KNF;
- Verification and analysis of the submitted materials by the regulator;
- Responses to possible requests or clarifications from the KNF;
- Obtaining approval and entry into the CASP register.
Opening a corporate account and accounting support.
Result: The account is open, the company is ready to start operations, and internal processes and accounting are integrated.
- Selection of suitable banks or EMIs taking into account the risk profile;
- Preparation of a package of documents (description of activities, sources of funds, website, etc.);
- Parallel submission of applications to 2–3 crypto-friendly institutions;
- Engaging an accountant, consulting on crypto accounting;
- Ensuring tax and financial compliance with KNF requirements.
Find more information about the Poland VASP license
Transition period and deadlines for CASP licensing in Poland
According to the draft European MiCA regulation, virtual asset service providers (VASPs) registered in Poland will be able to take advantage of an extended transition period of up to 9 months to adapt to the new requirements. However, this deferral is only available if the following conditions are met:
- A complete application for a CASP (Crypto-Asset Service Provider) license must be submitted within three months of the law coming into force.
- The regulator must officially confirm that the documents provided are complete and comply with MiCA requirements.
It is important to note that the extension is not automatic. If an incomplete application is submitted or activities that do not comply with MiCA are carried out, the company may be removed from the VASP register before the end of the transition period.
At the time of publication, the Polish bill implementing MiCA is under review. According to the latest analysis published by experts Gofaizen & Sherle on LinkedIn, it is expected to come into force in the summer of 2025, which means that applications for licensing will start in the third quarter of 2025. Thus, existing VASP companies will have until mid-2026 to complete the CASP licensing process.
In addition, the draft law provides for the lifting of the current ban on crypto lending. This means that lending in digital assets, as well as the operation of DeFi platforms, will once again be permitted, but only with a valid CASP license. Such companies are also required to:
- comply with AML/KYC and financial transparency requirements,
- ensure full compliance with MiCA provisions,
- be accountable to both European and national supervisory authorities.
The transition to CASP regulation in Poland will be a key step in the legalization and standardization of cryptocurrency services within the framework of pan-European regulation, providing both new opportunities and additional obligations for industry participants.
Comparison of VASP and CASP in Poland
At first glance, VASP (virtual asset service provider) and CASP (crypto asset service provider) may seem identical. However, there are important differences between them, both in terms of legal status and business requirements.
| VASP (before MiCA) | CASP (after MiCA implementation) | |
|---|---|---|
| Regulator | Tax Administration Chamber (KAS) | Polish Financial Supervision Authority (KNF) |
| Legal basis | AML Act (2018) | EU Regulation 2023/1114 (MiCA) |
| Type of registration | Simplified registration in the register/td> | Full license with confirmation of compliance |
| Minimum capital | From PLN 5,000 (~EUR 1,200) | From EUR 50,000 to EUR 150,000 (depending on the class of services) |
| Compliance and control | Basic set of AML/KYC procedures | Strict internal policies, AML/CCO officers, and reporting |
| Services | Exchange, wallets, storage | Additional: consulting, portfolio management, trading, DeFi |
| License scope | Poland only/td> | Entire EU territory (through the “passporting” mechanism) |
| Supervision level | Limited | Ongoing monitoring, audits, reports, and MiCA compliance |
| Transition period | Valid until mid-2026, subject to conditions | Full MiCA compliance and successful licensing are required |
Types of crypto licenses in Poland
Starting in 2025, Poland, like other European Union countries, won’t be giving out multiple separate licenses for each type of crypto activity. Instead, there’ll be a single CASP registration covering specific services in the crypto sector.
This structure reflects an approach whereby a cryptocurrency license in Poland implies universal authorization covering one or more regulated activities. Types of regulated services under CASP registration:
- Custodial storage. Storage and administration of crypto assets on behalf of clients, including management of cryptographic keys.
- Operation of a trading platform. Provision of a mechanism for trading crypto assets between users (exchanges).
- Exchange of cryptocurrencies for fiat. Conducting exchange transactions between crypto assets and official currencies.
- Exchange of crypto assets between each other. Transactions between different types of cryptocurrencies.
MiCA divides CASPs into classes based on their activity profile:
- Class I covers the least risky activities, such as providing advice on crypto assets and transmitting client orders. A minimum capital of €50,000 is sufficient for this level.
- Class II includes more operationally intensive activities, such as custodial services for crypto assets and the exchange of cryptocurrencies for fiat currencies or other crypto assets. Companies providing such services must have a minimum capital of €125,000.
- Class III is intended for the most complex and regulated activities, such as the operation of trading platforms for crypto assets. For such companies, the minimum capital requirement is EUR 150,000.
Thus, the Polish crypto license is not divided into separate licenses by type of activity, but is a comprehensive authorization that can be configured depending on the services provided and the requirements of the regulator.
Overview of crypto regulation in Poland
Technically, a cryptocurrency license in Poland is not issued by an independent authority, but by entry in the VASP register. In practice, this procedure is carried out by the Tax Administration Chamber in Katowice, a division of the Ministry of Finance authorized to receive, review, and approve applications for registration of companies providing services with virtual assets.
The General Inspector of Financial Information (GIIF), Poland’s financial monitoring authority, plays a separate role in Poland’s crypto regulation. It is not involved in the registration process, but performs a key function:
- conducts scheduled and unscheduled AML compliance checks on VASP companies,
- analyzes reports and identifies suspicious transactions,
- and coordinates the implementation of AMLD directives within Polish jurisdiction.
On December 30, 2024, the MiCA regulation came into force in Poland, establishing uniform requirements for crypto-asset service providers (CASP) throughout the European Union. This means that all companies providing services related to crypto assets are required to obtain CASP authorization.
Key changes:
- Previously, companies could operate simply by registering with the VASP registry. Now, they are required to go through a full CASP licensing process through the Polish financial regulator (KNF), in compliance with European requirements.
- The new regime requires physical presence in Poland or the EU, as well as a resident director and sufficient capital depending on the class of activity.
- Requirements start at €50,000 and go up to €150,000, depending on the type of services provided (e.g., asset storage, exchange, trading platform).
- Companies must demonstrate that they have internal AML/KYC policies, IT security, risk management procedures, and pass a preliminary check by the regulatory authority.
- The VASP register will be closed on October 1, 2025. After this date, only companies with a valid CASP license will be able to legally operate in the market.
- New companies cannot register as VASPs from December 30, 2024; only CASP applications will be accepted.
Companies will no longer be able to start operating on a “trial basis” with minimal costs. They will now have to go through a full authorization process, including preparing documentation, confirming the qualifications of their management, and implementing compliance measures.
MiCA introduces a stricter but more transparent regime that promotes trust among investors, banks, and customers. This means that the industry is moving to a whole new level of regulation, comparable to the traditional financial sector.
Explore more details on the Poland crypto license
Crypto activities in Poland
The following activities are acknowledged as crypto activities in Poland.
Asset Exchange
Services providing possibility of interchanging virtual assets or purchase of virtual assets with fiat currencies from the service provider is categorized under this activity. Usually, the service provider offers a list of assets that is accepted by them, and only allows exchanges to be done between them and their customer. The customers can exchange one type of virtual asset to another or purchase the virtual asset with depositing fiat currency to the account of the service provider. Companies that offer asset exchange services may or may not allow transfers to the third parties, meaning the virtual assets acquired by the customers cannot be used as a tool to transfer value to third parties and the acquired virtual assets can be only used by them for investment purposes.
Asset Transfers
If a service provider allows exchange of virtual assets between third parties, their activity will be categorized as an asset transfer. Asset transfer services allows their customers to use the virtual assets to be used as a means of payment or transfer of value. The company may be a close circuit service provider, where only internally purchased virtual assets can be transferred between third parties, or it can be an open circuit and allow movement of funds acquired from third parties. In both cases, the service provider becomes subject to Financial Market Supervision and Payment Services Act and obtains further obligations at top of existing obligations for being an obliged entity under the Act on Counteracting Money Laundering and Terrorist Financing.
Marketplaces, Intermediary Services for Sale or Trade
Any intermediary service facilitates exchange, trade or transfer of virtual assets are categorized under this activity. In order to be an intermediary, a company must offer a service which allows execution of financial operations by the will of its customers which does not require their involvement. Usually, the assets in circulation are not under the possession of the company that is offering these services. This means that the company provide a marketplace that facilitates the exchange between crypto to crypto, fiat, or any other asset between third-parties.
Custodian Wallet Service
Custodian Wallet Service is the practice of safe keeping and the virtual assets of a customer in a corporate owned electronic storage system. This service is usually given directly by the service provider or through a third-party solution provider which provides infrastructure for the service. As a general practice, usually, the private key of the wallet is held securely by the service provider and only the public key is given to the customer. The customers of the service providers would require their assistance for the execution of transfers to third-parties, which can be done through direct requests, phone applications, or widgets provided.
Other crypto activities
The Polish Legal System does not have a comprehensive structure that is regulating the crypto related affairs. This means that virtual currencies are not observed as a type of money, and from mining to the purchase, and sale of these assets are recognized as activities that is not prohibited by the law. However, considering the overlaps between certain Acts, The Polish Financial Services Authority has published a statement in 2020 which has resulted with classification of virtual currencies under 3 categories, briefly, they are:
- Payment Tokens: These tokens are also known as Currency Tokens or Exchange Tokens. For a token to be classified under this category, it must possess an Issuer and tokens must represent a fixed value in fiat currency, fitting to the electronic currency described in Payment Services Act.
- Utility Tokens: This is the category of token which has been created for a specific functional purpose. The owners of these tokens are granted specific features that cannot be accessed without holding the token in question.
- Security Tokens: Polish law observes security tokens in different perspectives because they are seen as candidates to be governed under both Act on Trading in Financial Instruments and Act on Alternative Investment Fund Management since these tokens has the potential to provide incorporate rights similar to traditional securities or provide participation rights in investment related actions of the company and classified under this category.
As well as the type of service, it is also important to correctly identify the category of token before an application is made for licensing as it also determines all of the obligations that will be imposed on your company. If you are unsure which category your project falls under, our lawyers will assist you with its correct classification.
Since December 2024, Poland has been applying the pan-European MiCA rules, which have significantly changed the approach to the classification and regulation of tokens. Companies working with crypto assets are now required to consider which regulatory acts their tokens fall under, as this determines both licensing requirements and obligations to the regulator.
1. Payment and utility tokens.
Tokens that do not grant rights to equity, income, or voting are generally classified as:
- Payment tokens are used as a means of payment (e.g., cryptocurrencies that are not recognized as financial instruments).
- Utility tokens provide access to a service, platform, or functionality.
Please note that even if such tokens are not financial instruments, they are subject to MiCA. This means that:
- A white paper for the token must be published according to the regulations.
- You must obtain a CASP crypto license if you provide services related to such tokens (e.g., custodial storage or exchange).
2. Investment tokens.
If a token gives the holder rights similar to those of shares, bonds, or investment units, it is not regulated by MiCA. Such assets are subject to:
- MiFID II (if the token is considered a financial instrument),
- And may also be regulated by Polish law, in particular the Act on Trading in Financial Instruments and the Act on Management of Alternative Investment Funds (AIF).
In other words, if you issue a token with investment characteristics, you are required to undergo not only crypto registration but also possible licensing as an investment firm.
New EU regulations applied to Poland
The European Union will actively tighten the rules regarding regulating CASPs (cryptoasset providers). The MiCA law has been adopted by the European Parliament since 2022. MiCA is a regulatory framework developed by the European Commission to regulate crypto-asset markets and crypto-related services that do not currently fall under the scope of EU regulation.
It has been in place since 2018 and aims to provide a single licensing regime for all EU member states to harmonize the regulation of cryptocurrency creation and trading in line with the European Digital Finance Strategy. The law establishes a pan-European framework for conducting cryptoasset business and covers all virtual currencies, including cryptocurrencies. The new regulation is designed to protect investors, mitigate risks, and combat financial fraud. It also obliges service providers to comply with certain security standards and obey the rules set by regulators in the European Union.
Key objectives:
- Providing legal certainty for cryptoassets not regulated under current EU financial services legislation. There is a clear need for this at the moment.
- Establishing uniform rules for cryptoasset-related service providers at the level of European Union legislation. This will help avoid inequality and chaos in this area.
- Replacing the existing national framework applicable to crypto assets that do not fall under the regulation of the current EU financial services legislation. A single regulatory approach will help avoid fragmentation and conflicts between national rules.
- Establishing special rules for “stablecoins” and e-money. This will ensure consumer and investor protection and support the stability of financial markets.
Key requirements for CASPs:
- Regulatory Compliance: Companies must comply with all applicable laws and regulations, including those relating to anti-money laundering and counter-terrorist financing.
- KYC (Know Your Customer): CASPs must conduct customer identification procedures and collect customer information by applicable regulatory requirements.
- AML (Anti-Money Laundering): establish and maintain systems and procedures to detect and prevent transactions related to money laundering and terrorist financing.
- Monitoring systems: companies should have monitoring systems in place to identify and track suspicious transactions and activities.
- Security: ensure a high level of security in the storage and transfer of virtual assets, using modern technology and security methods.
- Regular audits: companies should conduct regular audits of their systems and procedures to ensure their effectiveness and compliance with applicable requirements.
- Cooperation with regulators: CASPs must cooperate with regulators and provide them with necessary information and documentation upon request.
MiCA will apply in all European Union (EU) member states, so if you plan to operate in Poland or elsewhere in the European Union, you should consider the new rules to operate legally.
Poland is preparing to introduce a new regulatory framework for digital assets in 2024, integrating the The Markets in Crypto-Assets Regulation (MiCA). The government has announced that the bill will be presented to Parliament in the second quarter of the year, giving the Polish Financial Supervision Authority (KNF) expanded powers.
The KNF now licenses virtual asset service providers (VASPs) and will continue to do so, but with additional powers similar to those held by BaFin in Germany and the FCA in the UK. The new bill will allow the KNF to supervise cryptocurrencies, take action against non-compliant VASPs, impose fines, and take violators to court.
Polish Virtual Asset Service Providers (VASPs) will need to prioritize user privacy and data protection, opting for smart contracts over traditional paper documentation. These actions are geared towards aligning with MiCA integration, which is set to enhance oversight of the crypto market and bolster investor protection measures.
Thus, the introduction of new rules will create a legal framework for the efficient functioning of crypto-asset markets and strengthen the KNF’s role in investor protection.
Taxation of crypto companies and crypto transactions in Poland
Taxation of cryptocurrencies in Poland is based on general fiscal rules and the specific legal status of digital assets, which will be regulated by MiCA from 2025.Virtual assets are still not recognized as an official means of payment and do not have currency status in the Polish system, which is important to consider when obtaining a cryptocurrency license in Poland or planning to operate through a Polish crypto license.
| Category | Taxation conditions |
|---|---|
| Individuals | Income from cryptocurrencies is capital income (dochód z kapitałów pieniężnych), taxed at a rate of 19%, declared via PIT-38. |
| Legal entities | Profit from cryptocurrency transactions is included in the general CIT base. |
| Income tax (CIT) | Standard rate – 19%. Preferential rate of 9% for companies with annual turnover of up to €2 million. |
| Capital gains tax | Not identified separately. Taxed under PIT (19%) or CIT. |
| VAT | Basic rate – 23%. The exchange of cryptocurrency for fiat currency and vice versa is not subject to VAT (according to EU Court practice). |
| Social security contributions (ZUS) | From 19.48% to 22.14% of salary (paid by the employer). |
It is important to consider the following factors:
- Exchanging cryptocurrency for fiat currency, goods, or services is considered taxable.
- Cryptocurrency-to-cryptocurrency exchanges are not taxed until they are converted into fiat currency.
- Only expenses related to Fiat sales are taken into account.
- Income is reported on the annual tax return (PIT-38).
Among the recent changes in Polish tax legislation concerning virtual assets, several important points are worth noting. The documentation requirements for transactions with offshore companies have been tightened: a threshold of PLN 2.5 million has been set for financial transactions and PLN 500,000 for non-financial transactions. This is due to increased control under Poland’s crypto regulation and the introduction of reporting standards.
Poland is also preparing to implement the OECD’s Crypto-Asset Reporting Framework (CARF) initiative, which imposes higher requirements on CASPs and provides for the automatic exchange of data between countries. This international initiative aims to increase tax transparency in the digital asset sector and strengthen requirements for CASP crypto service providers, including through the automatic exchange of tax information between jurisdictions.
Reporting requirements for VASP in Poland
Poland crypto license holders are required to comply with strict reporting and auditing requirements under MiCA integration and general Polish legislation regarding regulatory annual reporting and auditing requirements.
Reporting requirements:
- VASPs are required to submit itemized quarterly reports with transaction and active customer data, including information on anti-money laundering (AML) and countering the financing of terrorism (CFT) measures.
- Companies must file financial reports that reflect their current financial condition and comply with accounting standards.
- The reports must include information on customer data protection and privacy measures.
- Cryptocurrency companies are required to file VAT reports on a monthly or quarterly basis.
Audit requirements:
- Independent audit of financial statements and operations by an EU-recognized audit firm.
- Companies are required to conduct internal audits to manage risk and review compliance with AML and CFT requirements.
- Regular reports on compliance with MiCA requirements and KNF laws.
- Verification of the security of IT systems and cryptographic keys.
In addition, all registered companies in Poland are required to file annual financial statements and income tax returns with the Electronic Tax Inspectorate, as well as AML reports with the Inspector General for Financial Information.
A certified audit is required if two of the following conditions are met:
- Annual revenue > €5 million;
- Annual turnover > €2.5 million;
- Staff > 50 employees.
Penalties for violating crypto asset legislation in Poland
With the entry into force of the MiCA Regulation and the tightening of crypto asset market regulation, Polish supervisory authorities have been granted expanded powers to monitor the activities of virtual asset service providers.
Conducting cryptocurrency business without proper registration in Poland or without complying with the conditions of the transition period is a violation of the law and entails serious consequences.
Measures taken by the Financial Supervision Authority (KNF)
By applicable regulations, the KNF is entitled to apply the following administrative measures:
- Public disclosure of violations. Information about a company’s non-compliant activities may be published on the regulator’s official website to inform the public and protect investors.
- To cease operations. The KNF may issue an order to suspend specific operations or all activities of a company.
- Exclusion from the CASP register. Revocation of licensed provider status deprives the company of the right to legally provide services related to crypto assets.
- Restrictions on management. Officers may be temporarily prohibited from holding management or supervisory positions in financial institutions for up to one year or longer, depending on the severity of the violation.
Financial sanctions under MiCA
Companies with a valid CASP license that violate the provisions of the MiCA Regulation may be fined:
- up to €5,000,000,
- or up to 10% of annual turnover, whichever is greater.
Grounds for imposing fines include:
- Failure to submit or falsification of a white paper,
- non-compliance with AML/KYC requirements,
- improper storage or transfer of customer crypto assets,
- lack of appropriate cybersecurity measures.
Criminal liability under AML legislation
In the event of intentional provision of false information, concealment of information about suspicious activities, or failure to notify the authorities, criminal liability is provided for:
- imprisonment for a term of 3 months to 5 years,
- as well as additional criminal fines.
Tax sanctions
Under current tax legislation and as part of the implementation of Poland’s crypto regulation, violators may also be held liable for:
- failure to file or late filing of tax returns,
- incomplete disclosure of information on transactions with crypto assets,
- failure to comply with reporting requirements for transactions with counterparties from offshore jurisdictions (with increased documentation thresholds: from PLN 2.5 million for financial transactions and PLN 500,000 for non-financial transactions).
The Polish tax system is aligned with international standards, including the Crypto-Asset Reporting Framework (CARF), implemented by OECD recommendations.
FAQ about crypto licenses in Poland
Is cryptocurrency-related activity legal in Poland?
Yes, cryptocurrency activities are permitted in Poland. Companies are required to comply with anti-money laundering (AML) requirements and register with the Financial Supervision Authority (KNF). Since 2024, new Poland crypto regulations have come into force as part of the implementation of the European MiCA regulation.
Does Poland issue licenses for cryptocurrency activities?
Poland grants licenses for activities related to crypto assets. Since the entry into force of the European MiCA (Markets in Crypto-Assets) regulation, the country has applied uniform regulatory standards for cryptocurrency service providers (CASP), similar to other EU countries.
Do you need a license to trade cryptocurrencies in Poland?
Trading cryptocurrencies or any other crypto assets using your funds (as a natural or legal person) does not require a license in Poland. A license is required to provide services to third parties, including the activities of a trading broker, exchange, etc.
What types of commercial activities can be carried out based on a crypto license obtained in Poland?
Based on a crypto license in Poland, a company can legally carry out: exchange of cryptocurrency for fiat, exchange of one cryptocurrency for another, intermediation in such exchanges, as well as the provision of custodial wallets. All these activities require registration as a CASP under MiCA.
How to obtain a crypto license in Poland?
From 2025, obtaining a Poland crypto license will be regulated under the European MiCA regulation. In Poland, the CASP license is issued by the Financial Supervision Authority (KNF) and requires compliance with strict requirements:
- Registration of a legal entity in Poland (e.g., Sp. z o.o.) with a confirmed office.
- Contribution of share capital ranging from €50,000 to €150,000, depending on the types of crypto services.
- Preparation of a detailed business plan, including a description of activities, financial calculations, and procedures.
- Development of internal policies on AML/CFT, data protection, risk management, and complaint handling.
- Appointment of qualified managers and confirmation of their reputation (fit & proper procedure).
- Availability of reliable IT systems and cybersecurity measures.
- If necessary, professional liability insurance or the creation of a guarantee fund.
- Submission of a complete set of documents to the KNF and passing a regulatory review.
Obtaining a cryptocurrency license in Poland is a multi-stage process that requires serious preparation and compliance with EU standards.
Is it necessary to contact the local tax authority when conducting cryptocurrency activities on behalf of a Polish company?
Yes, every company operating in the cryptocurrency sector in Poland is required to be registered in the National Court Register (KRS) and registered with the tax office (KAS). This is a standard requirement for all commercial entities, including those that have obtained a crypto license in Poland and provide services under CASP by MiCA regulations.
How long does it take to obtain a cryptocurrency license in Poland?
Following the entry into force of MiCA in Poland, the fast-track VASP registration procedure is no longer available. Now, obtaining a crypto license is carried out in the form of a CASP license and requires comprehensive preparation: from company registration and contribution of authorized capital to the development of all internal policies, a business plan, and the submission of a complete set of documents to the KNF. The time it takes to obtain a license depends on the completeness of the dossier and the readiness of the company, but, as a rule, preliminary estimates suggest that it may take between 4 and 6 months to complete all stages in practice.
How much does it cost to obtain a cryptocurrency license in Poland?
Obtaining a crypto license in Poland under the new MiCA rules requires a significant investment. In addition to the registration fee, costs include share capital of €50,000, preparation of documentation, internal policies, and IT solutions. The total cost depends on the scope of services and the structure of the company.
What is the minimum share capital for a virtual currency service provider?
From 2025, under MiCA, the minimum share capital depends on the type of crypto services. For simple services (e.g., consulting or portfolio management), €50,000 is required. If you operate an exchange, €125,000 is required.For custodial services, €150,000 is required. These amounts are mandatory for a CASP license, even though the basic capital for registering a Sp. z o.o. Remains PLN 5,000.
Can the authorized capital be contributed in cryptocurrency?
No, the authorized capital when obtaining a crypto license in Poland must be contributed exclusively in fiat currency (e.g., Polish zlotys or euros). Cryptocurrency is not recognized as an acceptable means of payment for authorized capital under current Polish law and MiCA requirements.
When is it necessary to contribute capital to open a company and obtain a cryptocurrency license in Poland?
To obtain a CASP license in Poland, the authorized capital must be contributed before submitting an application to the Polish Financial Supervision Authority. This means that proof of the necessary own funds (depending on the license class: €50,000, €125,000, or €150,000) must be provided together with the application. Deferral of capital contribution after company registration is not permitted.
What are the penalties for conducting cryptocurrency business without a license in Poland?
Failure to obtain a CASP license and violation of MiCA requirements in Poland will result in severe penalties. Companies operating without the appropriate authorization risk a fine of up to €5 million or up to 10% of their annual turnover, whichever is higher. In addition to financial penalties, administrative measures are also possible: suspension of activities, removal from the register, and criminal liability for non-compliance with AML/CFT legislation. Therefore, obtaining a crypto license in Poland is a mandatory step for legally conducting cryptocurrency business.
Does a Polish crypto company have to appoint an anti-money laundering officer?
Yes, every licensed CASP company in Poland is required to appoint an AML officer (MLRO), a resident of the country with experience and knowledge of the Polish language. They are responsible for compliance with AML/CFT requirements, interaction with GIFI, and reporting through the official system.
Is cryptocurrency regulated in Poland?
Yes, the cryptocurrency market in Poland is officially regulated. Since 2024, the country has been implementing the provisions of the European MiCA regulation, which establishes uniform standards for crypto asset service providers. Supervision of compliance with the requirements is carried out by the Polish Financial Supervision Authority (KNF), which has been granted extended powers.
Can a foreign company obtain a Polish crypto license?
Yes, non-residents can also go through the process of obtaining a crypto license in Poland by registering a company with an office in the country. All capital, structure, and compliance requirements outlined in MiCA and Polish law must be met.
Does a cryptocurrency license in Poland give the right to operate in other EU countries?
After obtaining a CASP license in Poland, you are entitled to provide services in all EU countries under the passporting principle. This makes a crypto license in Poland particularly attractive for companies with an international strategy.
When can my application for a crypto license in Poland be rejected?
An application for a Polish crypto license may be rejected if it is incomplete, contains inaccurate information, or if key persons do not meet the integrity requirements (fit & proper). A refusal is also possible if the applicant is restricted in their right to conduct business in the EU.
How can I appeal a refusal to grant a crypto license in Poland?
In the event of refusal to register in the register of virtual asset service providers (CASP), the applicant has the right to appeal. First, you can submit a request for review of the decision to the Polish Ministry of Finance. If the result remains unchanged, you can appeal to the competent provincial administrative court. This procedure allows you to protect your interests under the legislation on cryptocurrency licenses in Poland.
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