Obtaining crypto licenses, white label consulting,
ICO/STO, supporting NFT marketplaces, drafting policies
for crypto projects, DAOs, and gamify projects
Poland has emerged as one of the EU’s most crypto-friendly jurisdictions. By late 2024 it had over 1,800 registered virtual asset service providers (VASPs), making it arguably the #1 global hub for crypto businesses by 2025. Historically, Poland offered a simple registration regime for crypto ventures, which made market entry very fast and cost-effective.
Now, with the EU’s Markets in Crypto-Assets (MiCA) regulation in force, Poland is aligning its laws to require a formal Crypto-Asset Service Provider (CASP) license for any crypto service provider. Under MiCA, any Poland-based crypto-asset service provider must obtain authorization from the Polish Financial Supervision Authority (KNF). The KNF, together with the Finance Ministry’s Financial Intelligence Unit (GIIF), oversees crypto licensing and anti-money laundering compliance. In practice, this license – granted to a local company (typically a Polish sp. z o.o. LLC) – allows the company to legally provide crypto services (exchanges, wallets, brokerage, etc.) to customers across the EU. MiCA’s CASP rules became applicable on 30 December 2024, so Polish VASPs are transitioning from the old registration regime to the new CASP license. Existing operators benefit from a transitional period: they may continue under the old rules until 1 July 2026.
What is a Poland crypto license?
A Poland crypto license is a government authorization (specifically, the CASP license under MiCA) that permits a company to conduct crypto-asset business under Polish and EU law. It is issued by the KNF (the Polish regulator) and certifies that the company meets strict regulatory standards for operating in the crypto sector. The license covers all MiCA-defined crypto-asset services – for example, providing custody of crypto-assets, operating a trading platform, executing exchange or transfer orders, offering crypto investment advice or portfolio management, and related services. In essence, it is a single comprehensive permit to engage in virtually any cryptocurrency-related financial service, so long as those services involve crypto-assets (tokens that are not classified as e-money or certain asset-referenced tokens). Once obtained, a Polish CASP license is passportable EU-wide under MiCA, meaning the company can serve clients in any EU/EEA country without needing separate local licenses. (Activities outside the scope of financial crypto services – for example, purely technical blockchain development or non-financial use of tokens – generally do not require this license.)
Who needs it?
Under MiCA, any entity offering crypto-asset services in Poland (or to customers in the EU) must hold a CASP license. This requirement applies to centralized cryptocurrency exchanges (crypto-to-crypto or crypto-to-fiat trading platforms), custodial wallet providers, crypto brokers and dealers, investment advisors and portfolio managers dealing in crypto, and other businesses that “provide custody and administration of crypto-assets,” “operate a trading platform,” “execute orders,” “exchange crypto for fiat or other crypto,” or “provide advice or transfer services” for crypto-assets. In short, if a company is handling clients’ crypto assets or facilitating crypto transactions as a service, it is required to be licensed. Conversely, businesses not dealing with customers’ crypto funds – for example, purely software developers or blockchain consulting firms that do not intermediate or hold crypto on behalf of clients – generally do not need this license. (For those businesses, however, it is important to avoid actually providing any regulated crypto-asset service without a license, since Poland can penalize unlicensed crypto activity by, for instance, blocking access to offending websites.)
Scope of permitted activities
A Polish CASP license is very broad in scope. It covers all crypto-asset services defined under MiCA, as long as they involve crypto-assets that are not otherwise regulated (e.g. not e-money tokens, which would require a separate e-money institution license). Permitted activities under the license include: crypto-to-fiat exchange services and crypto-to-crypto exchanges; custody and secure storage of crypto-assets (custodial wallets); operating crypto trading platforms or exchanges; executing clients’ orders for buying or selling crypto; facilitating transfers or payments in crypto; providing crypto investment advice or portfolio management; arranging or brokering crypto transactions; and other related services. In other words, one CASP license in Poland allows an operator to offer virtually any cryptocurrency-related financial service (the full spectrum from trading and custody to advisory and payment services). If an activity lies completely outside this financial scope – for example, a video game using blockchain tokens purely as in-game items, or a non-financial NFT art platform – it would typically fall outside the CASP licensing requirements (though other laws might still apply). But whenever an activity does fall under the regulated crypto services category, the CASP authorization is needed to conduct it legally.
| Parameter | Value |
|---|---|
| License processing time | 3–6 months (estimate, depending on KNF workload and completeness of documentation) |
| Application fee | ~€4,500 (one-time KNF licensing fee under MiCA) |
| Annual supervisory fee | ~0.4% of revenue (recurring regulatory levy; e.g. ~€750 for €187k revenue, scaling up to 0.4% of turnover) |
| Minimum capital requirement | €50k–€150k (depending on services: e.g. ~€125k for exchange/custody providers, €50k for advisory-only, €150k for operating a trading platform) |
| Corporate tax on profits | 19% (standard Polish corporate income tax; new small companies may qualify for 9% in initial years) |
| Resident director | Yes – at least one director must be resident in Poland |
| Local office | Yes – must have a registered office address in Poland (an EU presence is required) |
| Local staff | Yes – must appoint key local personnel, including a dedicated AML/KYC compliance officer (and other responsible managers as needed) |
| Bank account | Yes – a corporate bank account in Poland or the EU is needed (to hold paid-in capital and handle fiat operations) |
| Target markets | EU-wide – the license is passportable across all EU/EEA countries under MiCA |
| Restricted countries | Must block business with sanctioned or high-risk jurisdictions per FATF/EU lists (strict sanctions compliance required for any EU financial license) |
| AML/KYC requirements | Strict – full EU-standard AML/CFT compliance is mandatory (customer identity verification, transaction monitoring, record-keeping, reporting, etc.) |
Benefits of the Poland crypto license
Poland’s crypto licensing regime offers several advantages for crypto companies:
- Fast and efficient process. Poland is known for quick licensing turnaround – a well-prepared CASP application can be approved in a matter of a few months. The country’s historical registration system was extremely fast (about 14 days to register a VASP) with minimal bureaucracy. Even under MiCA, the application fee (~€4.5k) is modest and the process is streamlined relative to some larger EU states. There are no exorbitant government charges, and while a new annual levy of 0.4% on revenue will apply, initial costs remain competitive for startups.
- One license covers all services. Unlike some jurisdictions that used to have separate permissions for exchange vs. custody, etc., Poland (in line with MiCA) issues a single CASP license covering all authorized crypto-asset services. This “all-in-one” approach means an operator can start with one business line (say, a crypto exchange) and later expand into others (custodial wallet, crypto payments, investment products) under the same license, without needing new approvals. The Polish license effectively future-proofs a startup’s ability to add new crypto offerings as the market evolves.
- EU market access and credibility. A Polish crypto license is recognized across the entire EU single market, granting access to 450+ million consumers under the passporting regime. Being regulated in an EU jurisdiction signals compliance with high standards (AML, consumer protection, transparency), which enhances trust among European banks, payment providers, and customers. Operating with an EU-authorized license often makes it easier to establish partnerships and banking relationships. Poland’s reputation as a stable, EU-compliant jurisdiction adds credibility to licensed businesses.
- Large domestic market and talent pool. Unlike smaller jurisdictions, Poland itself offers a sizable home market and workforce. With ~38 million people and a tech-savvy demographic, there are over 2.5 million crypto users in Poland (~6.3% of the population). The country has a growing fintech and blockchain community, and a highly educated talent pool (dozens of universities offer blockchain-related courses). Setting up in Poland gives crypto startups access to this robust local ecosystem, which can be valuable for hiring, partnerships, and early user adoption – in addition to EU-wide expansion.
- Favorable tax and business climate. Poland’s corporate tax rate is a flat 19%, which is moderate by EU standards (and new/small companies can benefit from a 9% reduced rate). There are no special turnover taxes on crypto services, and crypto trading revenues are generally exempt from VAT across the EU (crypto exchanges are treated as financial services and thus VAT-exempt per EU court rulings). The regulatory framework is clear and transparent – while compliance is strict, rules are well-defined, reducing uncertainty. Poland’s economy is strong and the government has shown support for fintech innovation, providing a stable environment for crypto ventures.
- Robust, evolving regulation. Poland has been proactive in adopting the latest EU crypto rules, aiming to keep its regime up-to-date and comprehensive. The proposed Crypto-Assets Market Act (drafted in 2025 to implement MiCA in Poland) is one of the most detailed frameworks in the EU, giving businesses clarity on licensing procedures and regulatory expectations. This robust oversight (to be under KNF) provides a stable operating environment with clear guidance – often preferable to the uncertainty of under-regulated jurisdictions. Being in a jurisdiction that closely follows EU guidelines (e.g. on cybersecurity and operational resilience under DORA) means fewer regulatory surprises in the long run.
Disadvantages of the Poland crypto license
There are also some drawbacks to consider in Poland’s regime:
- Regulatory burden and costs. The MiCA-based framework – and Poland’s implementation of it – imposes strict compliance requirements that can be onerous for smaller operators. Applicants must commit significant capital (€50k–€150k of own funds) and establish full AML/KYC programs, internal controls, and local governance. Ongoing compliance entails regular reporting, audits, and maintaining qualified staff, which add to operational costs. Additionally, Poland’s law introduces a 0.4% of revenue annual supervisory fee, a relatively high levy that could erode profit margins for firms with large volumes. These obligations mean running a licensed crypto business in Poland comes with substantial overhead (though similar burdens would apply in any rigorous jurisdiction).
- Banking and financial support challenges. Despite Poland’s crypto-friendly regulations, many traditional Polish banks have been hesitant to service crypto businesses. Firms may encounter difficulties opening bank accounts or face strict limits and enhanced due diligence. While workarounds exist (such as using EU-based fintech banks or electronic money institutions that are crypto-friendly), this banking friction adds complexity. By contrast, some smaller EU jurisdictions have niche banks more openly welcoming to crypto clients. This means a Polish crypto startup might need extra effort to establish reliable fiat banking relationships – a vital aspect of operations.
- Limited recognition outside the EU. A Poland CASP license, like any EU crypto license, is not a free pass globally. Major non-EU markets (e.g. the USA, UK, China, etc.) do not accept an EU crypto license for local operations – they require their own licensing or registration. Thus, a Polish-licensed crypto company must geofence and avoid offering services in those jurisdictions, or pursue additional local licenses if expansion is desired. In effect, the Polish license grants excellent access across Europe and other friendly markets, but it does not eliminate the need to comply with separate regulations in non-EU countries. This limitation is not unique to Poland, but it does cap the global reach unless further licenses are obtained.
- Transitional and regulatory change period. Poland is still in the midst of transitioning from its old registration regime to the new MiCA regime (2024–2026). This change, while ultimately positive, can create short-term complexity. Existing companies that were on the simple register will need to undergo a full license application by 2026, meaning extra paperwork and possible business adjustments. New entrants in early 2025–2026 have faced uncertainty while Polish legislation is being finalized. Although Poland’s parliament passed a new crypto-assets law, a presidential veto in late 2025 stalled its implementation, prolonging the regulatory limbo. This extended transition could pose timing challenges and temporary confusion. Startups must stay abreast of the latest rules and ensure they migrate to the CASP license by the deadline (mid-2026), or risk business interruption.
- Higher competition (and scrutiny). Since Poland became a popular base for crypto firms (over 1,800 registered VASPs by late 2024), the market has many operators. This means competition for local talent, banking, and customers can be high. The KNF and other authorities will also be supervising a large number of entities, which could mean closer scrutiny and stricter enforcement to manage risks. Companies might find that while Poland is welcoming, it’s also very diligent in inspections and enforcement of rules – e.g. regulators can impose hefty fines for AML violations (up to 5–10% of turnover or €1 million). This level of oversight, while good for the ecosystem’s integrity, means there is little leniency for startups learning the ropes.
Types of Poland crypto licenses
Under the current framework, Poland does not issue multiple “levels” of crypto licenses beyond what is defined in MiCA – there is essentially a unified CASP authorization for service providers. Historically, Poland did not have distinct license categories like some countries did; instead, it maintained a single register of virtual currency activities under the AML law. Any company engaging in virtual currency exchange or custody simply had to register as a virtual asset service provider with the GIIF, and that one registration covered both exchange and wallet/custody services. There were no separate licenses for “exchange operator” versus “wallet provider” – one registration entry sufficed for all permitted virtual currency services.
From 2025 onward, with MiCA in effect, Poland is moving to a full Crypto-Asset Service Provider license system. In practice, every crypto operator will apply for a CASP license from the KNF, regardless of whether their business is an exchange, custodian, broker, or other service – it’s a single license encompassing all those activities. (MiCA does delineate classes of service for prudential purposes: e.g. Class 1 covers advice/portfolio management, Class 2 adds exchange and custody services, Class 3 adds operating a trading platform, each with different capital requirements. However, these are not separate licenses per se, just different scopes under one CASP authorization with corresponding capital tiers.)
Importantly, Poland does not allow any third-party or “master license” arrangements in the crypto sector. All licenses are granted directly by the state authority (the KNF). Under the old regime, companies dealt directly with the Ministry of Finance/GIIF for VASP registration, and under the new regime they will deal directly with the KNF for licensing. There is no white-label, franchise, or umbrella licensing in Poland’s crypto framework – each provider must obtain its own approval from the regulator.
Requirements for obtaining a Poland crypto license
Prospective crypto service providers in Poland must meet a range of strict requirements to obtain the CASP license. Key conditions include (but are not limited to):
- Corporate structure & capital. The applicant must establish a Polish legal entity (usually a spółka z o.o. – a limited liability company) to be the license holder. The company must have a certain minimum share capital fully paid in: under MiCA this ranges from €50,000 to €150,000 depending on the services offered. For example, a crypto exchange or custodial wallet provider needs ~€125k in equity capital, while an operator of a trading platform needs €150k. This capital must be the firm’s own funds (not borrowed) and is typically demonstrated via bank statements or audited financials. (Notably, Poland’s general company-law minimum capital is only 5,000 PLN (~€1,200), but to obtain the CASP license you must inject the higher amount required by MiCA.) The funds usually need to be deposited in a Polish/EU bank account and kept as a reserve to ensure solvency.
- Local presence and personnel. Poland (and MiCA) mandate real substance in the EU. The company must have a registered office in Poland and at least one director who is resident in the EU. Key management roles must be filled with qualified individuals. In particular, a Chief Compliance Officer/AML Officer is required – someone responsible for day-to-day anti-money laundering and KYC compliance. The company should also appoint a qualified executive director (CEO or equivalent) to run the business, ideally based in Poland or at least frequently present. These roles can be combined in smaller startups (e.g. one person might be both director and AML officer if properly qualified), but regulators will scrutinize whether the persons have the necessary time and expertise. The physical office in Poland must be more than just a P.O. box – regulators expect an actual operational presence or at least a real contact point for the business. Additionally, a functional EU bank account is needed not just for holding capital but to facilitate customer fiat flows (demonstrating that the business can integrate with the traditional financial system).
- Fit-and-proper vetting. All owners (beneficial shareholders), directors, and senior managers will undergo thorough background checks. Polish law requires no criminal record for individuals in charge – the applicant must produce police clearance certificates showing that directors and beneficial owners have not been convicted of fraud, financial crimes, money laundering, terrorist financing, or other serious offenses. This extends to corporate owners as well: if the applying company is owned by another legal entity, that entity’s controlling persons must also have clean records. Furthermore, there is a professional qualification requirement: persons directing the crypto business must have relevant knowledge or experience in crypto or finance. This can be demonstrated by completing specialized training or courses on cryptocurrency law/operations, or by having at least one year of prior work experience in the crypto or financial field. Documentation (certificates, reference letters, etc.) must be provided to prove these credentials. The KNF will also evaluate the overall reputation and financial soundness of major shareholders – typically anyone owning 10% or more of the company is subject to review for fitness and propriety.
- Business plan and documentation. A detailed business plan and a suite of internal policies must be prepared as part of the application. The business plan should describe the planned services, target markets, revenue model, organizational structure, and financial projections for at least two years. Required documents include the company’s constitutional papers (articles of association, KRS company registration extract), proof of capital (e.g. a bank statement showing the paid-in capital), and comprehensive internal procedures. These procedures must cover areas such as AML/CFT policies, customer onboarding and KYC processes, risk management policies, IT security policies, custody of assets procedures (if applicable), complaint handling procedures, and more. Essentially, the applicant must show in writing how it will operate safely and in compliance – including how it will safeguard client assets, manage private keys if handling wallets, address cybersecurity risks, and ensure business continuity. Any partnerships or key third-party service providers should be identified (for instance, if you will use an external custodian or compliance software, that should be noted). All documentation needs to be presented in Polish (with translations as needed) and formatted according to any guidelines provided by the KNF.
- Technical infrastructure and IT compliance. Applicants must demonstrate a secure and robust technical setup for their crypto platform. This means showing that the IT systems (trading engine, wallet infrastructure, databases, etc.) meet modern security standards – for example, encryption of sensitive data, secure key management, DDoS protection, disaster recovery, and so on. Poland will also be subject to the EU’s new Digital Operational Resilience Act (DORA) rules starting in January 2025, which means higher expectations for risk management in ICT systems. Companies should be prepared to conduct risk assessments and have incident response plans for cyber threats. Additionally, compliance with the EU’s NIS2 Directive on network security is expected (e.g. use of firewalls, strict access controls, regular security audits). The IT infrastructure is generally expected to be located in a stable jurisdiction (preferably in Poland or elsewhere in the EU for data protection reasons). Regulators may not explicitly require local servers, but data residency and security will be closely scrutinized. Demonstrating strong IT governance (for example, by hiring experienced IT security personnel or outsourcing to reputable providers) will strengthen the application.
- AML/KYC and risk controls. A Poland crypto license application must heavily emphasize anti-money laundering (AML) controls. The applicant needs to have a written AML/CFT program that meets EU standards (as set out in Poland’s AML Act and EU 5AMLD/6AMLD directives). This includes procedures for customer due diligence (KYC – Know Your Customer), ongoing monitoring of transactions, identifying politically exposed persons (PEPs), screening customers against sanctions lists, and reporting suspicious activities. Polish law requires that crypto businesses identify and assess money-laundering risks in their operations and have internal controls to mitigate them. The company must designate an AML Compliance Officer (as mentioned above) who will be responsible for filing reports to the GIIF (Poland’s financial intelligence unit) whenever there are red-flag transactions. Ongoing staff training in AML, proper record-keeping systems (to retain transaction and customer data for at least 10 years), and an internal audit function or independent audit arrangements for AML compliance are also expected. In short, the firm must be “regulation-ready” – showing that from day one of operations it will comply with all AML/CFT obligations. Any weaknesses in this area are a common cause of license denial or significant delays.
- Application submission to authorities. Once all documents are in order, the company submits the license application to the KNF (Polish Financial Supervision Authority), which is the competent authority for CASP licensing. The application is usually filed electronically through the KNF’s portal (or by hard copy), and the ~€4,500 application fee is paid at this stage. The KNF will review the submission for completeness and may consult other bodies like the National Bank of Poland or the GIIF for their input on specific areas (e.g. AML matters). If the application is incomplete or documents are missing, the KNF will request additional information (which can pause the approval clock). Once the application is formally accepted as complete, the KNF aims to make a decision within a few months. During this time, expect questions or requests for clarification from the regulator – for example, they might ask for more details on your IT security measures, or request changes to an internal policy. It’s important to respond promptly to any regulator queries to keep the process on track. After a successful review, the KNF will issue a decision granting the CASP license, at which point the company can commence the approved crypto activities. (If the decision is negative, the authorities will provide reasons, and the applicant has the right to appeal or to reapply after addressing the issues.)
Costs & taxes
When planning to obtain a crypto license in Poland, one should budget for several cost components:
- State and regulatory fees. Poland historically did not charge heavy state fees for basic crypto registration (the old VASP registration cost was only 616 PLN, about €130). Under the new MiCA regime, there is an application fee of €4,500 payable to the KNF upon applying for the CASP license. Additionally, Poland’s law has introduced an annual supervisory fee for licensed CASPs – set at 0.4% of annual revenue of the crypto business. This fee (effectively a regulatory levy) is paid yearly to fund oversight activities. For small startups, 0.4% may amount to a few hundred or thousand euros (there may be a minimum threshold around €750), but for larger exchanges, it can become a significant expense. Notably, this percentage-based fee is higher than in some other EU countries (it was a point of contention in Poland’s legislation). Aside from these, there is no separate “license issuance” tax – once you pay the application and annual supervisory fees, you won’t face other government charges specific to the crypto license.
- Share capital. A major “cost” is the minimum capital requirement, which ranges from €50k to €150k depending on the scope of services. This money isn’t a fee paid to anyone; it remains the company’s own capital, but it must be available (usually held in a Polish or EU bank account) and cannot be just an IOU or crypto asset – it should be in cash or other high-quality liquid assets. In practice, this means founders must allocate that amount of money to the company’s account and keep it as a buffer. It’s essentially “tied-up” funds for the duration of the license (regulators expect the firm’s equity capital not to drop below the required minimum). While these funds can be used for operating expenses if needed, falling below the threshold could jeopardize the license – so in reality the money is effectively locked as a safety reserve.
- Corporate and other taxes. Poland’s corporate income tax rate is 19% on net profits (with a possible reduced rate of 9% for small new firms in their initial years). This is a straightforward tax on profits similar to many jurisdictions. There is no special crypto transaction tax or turnover tax – crypto trading revenues are taxed as normal corporate income. Importantly, within the EU, cryptocurrency exchange and related services are treated as VAT-exempt (following a 2015 European Court of Justice ruling), which means Polish crypto companies do not charge VAT on trading fees or similar services (just as stock brokerage fees are VAT-exempt). This is beneficial as it avoids an extra 23% tax on such services that would otherwise apply. If the company later distributes profits as dividends, standard Polish dividend withholding tax (generally 19%) may apply unless reduced by an EU directive or a tax treaty. Overall, Poland’s tax regime is considered moderate – not a zero-tax haven by any means, but relatively predictable and not overly burdensome for a regulated business.
- Compliance and professional services. Aside from official fees, a substantial cost comes from professional services and building the compliance infrastructure. Most foreign entrepreneurs hire local legal consultants to assist with the license application, given the complexity of MiCA and Polish regulations. Legal and advisory fees can range widely – from a few thousand euros for basic document preparation support, up to €20k or more for full turn-key licensing support. Budget should also include accounting and auditing services: a crypto company will need accountants to maintain its books and potentially an independent auditor for annual financial statements (audits become mandatory once certain size thresholds are exceeded). Many startups also invest in compliance tools (for example, identity verification/KYC software, transaction monitoring systems) and cybersecurity measures (secure hosting, DDoS protection, etc.), which can be significant ongoing costs. Don’t forget personnel costs: employing a local compliance officer or resident director may require a salary or stipend. These expenses can add up to tens of thousands of euros per year, depending on the scale of operations. For instance, independent audits, if required, might cost €5k–€10k annually; a compliance officer’s salary in Poland could be €20k–€40k per year; and IT/security solutions could be another few thousand annually.
- Total first-year budget. Combining the above, a rough first-year budget for obtaining and launching under a Poland crypto license might look like: €50k–€150k in share capital (not spent but set aside), ~€4.5k in application fees, possibly €750+ in first-year supervisory fee, legal/consulting fees on the order of €10k–€30k (depending on how much external help is used), and initial setup costs for IT and compliance (maybe €10k or more for systems, policies, and security). In addition, there will be ongoing operating costs (staff, office, etc.). It wouldn’t be unusual for a startup to invest on the order of €50,000 or more in actual expenses in the first year (excluding the capital lock-up) to get fully licensed and operational. Naturally these figures can vary widely with the project’s scale – a small advisory-focused startup might spend much less, whereas a full-fledged exchange aiming for a large launch may invest significantly more. The key takeaway is that Poland – while cheaper than some places like the UK or France – still requires a substantial initial investment to meet all regulatory and setup requirements.
Ongoing maintenance of your crypto license
After obtaining a crypto license in Poland, a company must maintain strict compliance and fulfill ongoing obligations to keep the license in good standing:
- Regulatory reporting. Licensed CASPs in Poland are subject to periodic reporting requirements to both the KNF and the FIU (GIIF). Under current rules, quarterly reports must be submitted to the GIIF with statistical data about the VASP’s activities (e.g. number of customers, transaction volumes, etc.), generally due within ~15 days after each quarter ends. Additionally, annual financial statements must be filed, and there may be regulatory reports to the KNF on the firm’s financial condition and compliance (the exact reporting forms will be defined by KNF under MiCA). It’s wise to maintain a compliance calendar to track all submission deadlines (quarterly AML reports, annual audit reports, any ad-hoc notifications, etc.).
- AML/KYC obligations. The obligation to enforce robust AML/CFT measures doesn’t stop at licensing – it’s an ongoing responsibility. The company must continuously verify customer identities, monitor transactions for suspicious patterns, and keep customer and transaction records for at least 10 years. Any suspicious transaction that might indicate money laundering or terrorist financing must be immediately reported to the GIIF (typically via an online STR/SAR filing system, within 2 business days or sooner). CASPs also need to implement the EU’s “travel rule” for crypto transfers (Regulation (EU) 2023/1113), meaning they have to include originator/beneficiary information with crypto transfers and possibly report certain transfers above defined thresholds. Regular sanctions screening is required to ensure no dealings with prohibited persons or countries. Polish authorities may conduct inspections or request information to ensure compliance – for example, the GIIF can inspect a crypto company’s AML procedures and records. Failing to meet AML duties can result in heavy penalties or even license suspension, so this is a critical area of ongoing effort.
- Audits and security assessments. Licensed crypto companies in Poland are expected to undergo periodic audits and evaluations. Financially, if the company reaches a certain size, an annual financial audit by an independent auditor might be mandatory (Polish law requires audits for companies over certain size thresholds or those considered public-interest entities). Even if not mandatory, having audited financials can bolster credibility. On the compliance side, many firms commission independent AML audits or IT security audits each year to ensure they are meeting all obligations – this can identify issues before the regulators do. The regulator (KNF) has the authority to request external reviews or additional reports; for instance, KNF could ask for a report on the effectiveness of the firm’s cybersecurity, or require a penetration test of systems under DORA’s resilience framework. Additionally, CASPs will need to conduct business continuity and disaster recovery tests as part of operational resilience plans. While Poland’s law might not explicitly list all these requirements, EU-level guidelines (from ESMA/EBA) influence the expectations. Staying proactive by regularly auditing your own compliance program is highly recommended to avoid unpleasant surprises.
- Change management and notifications. Any significant changes in the licensed business must be communicated to the authorities, and in some cases pre-approved. This includes changes in ownership structure (for example, if a new investor will acquire 10% or more of the company, KNF approval is likely required), changes in directors or key personnel (the appointment of a new board member or a new compliance officer usually must be vetted for fit-and-proper criteria), and changes in the scope of services offered. If, for example, a company licensed for exchange services wants to add a new service like operating a trading platform, it may need a variation of permission from the KNF. Even changes like rebranding the platform or launching a new website might require notification. The license ties the company to the conditions under which it was granted, so any material deviation from that (new product lines, major shifts in the business model) should be discussed with the regulator. Failing to notify authorities of changes can be grounds for enforcement action. In practice, maintaining an open line of communication with the KNF and seeking guidance when in doubt is part of good governance for a licensed entity.
- Consumer protection and conduct. Although crypto-assets aren’t traditional financial instruments, MiCA introduces certain conduct requirements to protect users. A licensed CASP in Poland must ensure transparent disclosure to customers – clear terms and conditions, fee information, and appropriate risk warnings for crypto trading. They must also have a complaints handling procedure so that retail customers can raise issues and have them addressed in a timely manner. Client funds and assets should be safeguarded: for instance, if holding crypto on behalf of clients, those assets should be segregated and protected (not used for company purposes), and proper custody measures (like multi-signature wallets, keeping the bulk of funds in cold storage, obtaining insurance if available, etc.) should be in place. While Poland might not have a formal investor compensation scheme for crypto, the spirit of consumer protection is that licensed firms should minimize the risk of loss or misuse of client assets. Advertising rules also apply – marketing communications must not be misleading (and MiCA has specific rules about promotions, including requiring certain disclaimers on crypto offerings). Overall, a Polish CASP must conduct its business honestly, fairly, and professionally in the best interests of its clients, aligning with general EU financial consumer protection principles.
Failure to adhere to ongoing obligations can lead to sanctions. Polish regulators have the power to impose administrative fines, issue public warnings, or even revoke the license if a company is found in serious or persistent breach of its duties. Thus, maintaining a strong compliance culture after licensing is just as important as obtaining the license in the first place.
Suspension or revocation of a Poland crypto license
The KNF can suspend or revoke a crypto license in Poland for significant violations or risks. Typical grounds for such action include: major AML/CFT compliance failures (for example, if the company is found to be willfully violating AML laws or has facilitated money laundering), providing false or misleading information to regulators during the application or supervision process, loss of the required capital (e.g. if the firm’s own funds drop below the minimum threshold and are not promptly replenished), insolvency or bankruptcy of the company, or operating beyond the permitted scope of the license. If a CASP is found to be engaging in fraudulent activities or egregiously mismanaging customer assets, authorities will act decisively to protect consumers and the integrity of the market. (A license may also be revoked for breach of ESMA’s technical standards or failure to maintain ICT operational resilience as required by DORA.)
In practice, the KNF would likely first issue warnings or orders for corrective action for less severe issues. For example, if an inspection finds deficiencies in KYC procedures, the company might be ordered to fix them by a deadline. However, in cases of acute risk – say a crypto operator is suspected of actively facilitating criminal transactions – regulators can immediately suspend the license, effectively freezing the business, while an investigation is underway. Suspension means the company must cease providing services for a period (possibly until issues are remedied or a case is resolved). If the problems are not resolved or are too severe, a full revocation (license withdrawal) can follow, which terminates the firm’s authority to operate and results in its removal from the public register of licensed entities.
Poland’s law provides for various penalties in such scenarios. For instance, regulators can publish the entity’s name and violations on the KNF website (a reputational penalty). Administrative fines can be quite steep (up to twice the benefit gained from the violation, or up to €1,000,000 if the illicit benefit cannot be determined, for certain infringements). Individuals responsible can also be penalized – in serious cases, people can be banned from serving in managerial roles in the financial sector for up to 5 years. In extreme cases involving criminal misconduct (for instance, knowingly facilitating money laundering or failing to report suspicious activity), individuals can face criminal charges – Polish law stipulates that failure to report certain financial crimes by a responsible person can lead to imprisonment from 3 months up to 5 years.
Updates to Poland crypto licensing (2024–2026)
Poland’s crypto regulatory landscape has been rapidly evolving from 2023 through 2026 to keep pace with European developments:
- MiCA adoption. At the EU level, the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) was adopted in 2023 and became largely applicable as of 30 Dec 2024. MiCA provides a unified regulatory framework for crypto-assets across Europe. Poland, like all member states, must implement certain national measures to make MiCA work (such as designating the competent authority, setting penalties, etc.). In late 2025, Poland’s parliament passed the Act on the Crypto-Assets Market – a comprehensive 100+ page bill to implement MiCA nationally – but on 1 December 2025 the President vetoed the act, preventing it from becoming law. The President objected to several provisions (including broad website-blocking powers, excessive complexity, and high supervisory fees). As a result of this veto, the new regulatory regime did not enter into force in 2025, and the Polish CASP licensing process remains on hold until new legislation is adopted. In January 2026, the lower house (Sejm) resubmitted the same bill to the President without changes (after rejecting a Senate amendment to tweak fees), leaving the outcome uncertain as of early 2026. Because MiCA is directly applicable, technically from Jan 2025 any new crypto service provider in Poland must be licensed under MiCA – but due to the lack of a national law and licensing procedure, Poland has been in a regulatory gap where new licenses can’t yet be processed. It is expected that a CASP licensing framework will be established in 2026 once the legislation is resolved.
- Transitional regime for existing companies. Recognizing that many companies were operating under the old registration system, Poland’s draft law provides a generous transition period. Originally, early proposals would have required VASPs to apply for a CASP license within 3 months of the law to keep operating, but the final bill (as passed by the Sejm) removed that short deadline. Instead, it stated that any company already entered in the Polish virtual currency register may continue its business under the old rules until 1 July 2026 (or until they receive a CASP license or are refused one, if earlier). In other words, there is a blanket permission (grandfathering) for those registered VASPs to keep operating through mid-2026, giving them time to transition. By that date, however, all crypto firms in Poland will need to have obtained the full CASP authorization or cease activities. Notably, the Register of Virtual Currencies (the old AML-based VASP register) will eventually be phased out – it was initially expected to be dissolved around late 2025 as the new regime ramped up, but with the delay it will likely remain in use until the MiCA licensing system officially takes over in 2026. For new market entrants (not previously registered), there is no transitional exemption – since MiCA’s applicability date (Dec 2024), any new crypto business in Poland is supposed to obtain a license before starting operations. In practice, this means new startups have to wait until the KNF can accept CASP applications, or consider other jurisdictions in the interim.
- Stricter substance and AML standards. Through 2024–2025, Poland has been increasing the bar for crypto operators in terms of local substance and compliance. The new rules reinforce the requirement of having an AML Officer in Poland – a person at management level responsible for overseeing the AML/CFT program locally. There is also emphasis on “fit and proper” standards for directors: guidance (including ESMA’s recommendations) makes clear that CASP directors in Poland must have demonstrable experience in finance or crypto and be actively involved in the business (residing in the EU and not just figureheads). Poland continues to follow updates in EU AML laws: for instance, the EU is establishing a new AML Authority (AMLA) and working on a unified AML Regulation, which will further tighten controls in coming years – Polish crypto firms will have to comply with those as they roll out. Additionally, Poland has implemented the EU’s Travel Rule for crypto transfers (Regulation (EU) 2023/1113, effective from 2024), which requires CASPs to collect and transmit sender/recipient information for crypto transactions over certain thresholds (similar to requirements for bank wire transfers). All these measures mean that the compliance workload for crypto businesses in Poland is growing – it’s reaching a level of oversight closer to that seen in traditional financial institutions. CASPs must demonstrate real economic presence (i.e. substance) in Poland: having an office, staff, local management, and genuine operational capacity in the country (not just a shell).
- Supervisory fees and investor protection measures. As noted, Poland’s new law proposed a 0.4% of revenue supervisory fee for CASPs, which would be one of the highest such fees in the EU and raised concerns that it could drive some businesses to other jurisdictions. (The President explicitly warned that the fee was set so high that smaller startups would effectively be excluded from the market.) Whether this fee might be adjusted in the final law remains to be seen, but as of early 2026 it’s a unique aspect of Poland’s planned crypto regime. On the investor protection front, the draft law empowers the KNF with new tools, such as maintaining a blacklist of banned domains – i.e. websites of entities offering crypto services without the required license can be blocked in Poland. This measure is intended to protect consumers from unlicensed offshore exchanges or scams, though it stirred debate about potential overreach (indeed, the broad domain-blocking power was one reason cited in the presidential veto). The KNF has also launched public warnings and educational communications to consumers (for example, clarifying that mere registration under the old rules was not the same as having a regulated license). Going forward, we can expect Poland to continue updating its regulations in line with EU developments – for instance, any changes coming from ESMA’s technical standards under MiCA, or new EU laws addressing areas like decentralized finance or NFTs, would be incorporated into the Polish framework.
- Transparency and public registers. Under MiCA, ESMA will maintain a central register of all licensed CASPs in Europe, and national authorities like KNF will contribute to this database. Poland has already moved toward greater transparency by making the list of registered VASPs public (the Ministry of Finance maintains an online public register of virtual currency firms). Once CASP licenses are being issued, the KNF will likely publish the list of authorized companies on its website (similar to how it lists banks or payment institutions). This public register allows anyone – investors, banks, partners – to verify if a crypto company is duly licensed in Poland. The push for transparency also means CASPs may be required to disclose certain information publicly (for example, possibly the name of their compliance officer or certain policies) to increase customer trust. Overall, Poland’s approach is to bring crypto into the mainstream financial oversight framework, which includes public accountability and visibility of licensed providers.
Who issues Poland crypto licenses?
In Poland, crypto licenses are issued by government regulatory authorities, not by any private or self-regulatory body. Historically (pre-MiCA), crypto businesses in Poland did not require a financial license per se; instead they registered with the Ministry of Finance (specifically with the General Inspector of Financial Information, GIIF) as virtual currency service providers. This registration was essentially an AML compliance formality and was maintained by the director of a Tax Administration Chamber under the Ministry’s authority. Importantly, being on that register was not equivalent to a full license – it wasn’t a permit granted after detailed review, but rather a notification-based inclusion (GIIF explicitly noted that the register was of a “record-keeping nature” that did not imply any warranty or prudential supervision). GIIF could inspect firms for AML compliance, but it did not otherwise “regulate” the business activity as a financial supervisor.
Under the new MiCA-based system, the Polish Financial Supervision Authority (KNF) becomes the main licensing authority for crypto services. The KNF is Poland’s financial regulator (which already supervises banks, insurers, payment institutions, etc.), and it has been empowered to authorize and oversee CASPs as well. All applications for a crypto license in Poland must be submitted to the KNF, and the KNF will grant the license after evaluating the application. Each legal entity that wants to operate a crypto service must go through its own authorization process with the KNF – a license is tied to the specific company and cannot be transferred or “rented” from another firm. In practical terms, if you’re launching a crypto exchange in Poland, you first establish a Polish company and then apply to the KNF for the CASP license. If approved, the KNF will list your company as an authorized CASP in Poland (and this info will also be shared with ESMA for the EU-wide register). The license is tied to your company – it isn’t something you can piggyback on via another licensee.
For entrepreneurs, this means dealing with a single regulator for licensing, which can be advantageous for clarity and guidance. However, as of early 2026, the KNF cannot yet commence processing CASP license applications until the national law comes into effect – so existing registered VASPs remain under the Ministry of Finance/GIIF’s AML-based oversight in the interim. Once the new law is implemented, the KNF will fully take over supervision of the crypto-asset market in Poland.
Why the Poland crypto license is attractive for startups
For entrepreneurs and crypto startups, Poland offers a compelling combination of factors that make it an attractive entry point into the regulated EU crypto market:
- Moderate costs and transparent setup. Compared to many Western European countries, Poland’s barriers to entry are lower. The official fees are reasonable (on the order of a few thousand euros, not tens of thousands). Moreover, company incorporation in Poland is fast – one can establish a new LLC (sp. z o.o.) within days using electronic filing. Under the old regime, VASP registration took only about 2 weeks, and under the new regime, licensing is expected to be relatively efficient (authorities aim for ~3–6 months for decisions, which is brisk in the licensing world). This means a well-prepared startup can go from idea to a fully licensed, EU-operating company in a matter of a few months, which is a huge advantage in the fast-moving crypto industry.
- Single-scope license, flexibility to expand. Poland’s CASP license (like the MiCA framework generally) is broad, allowing startups to pivot or expand their service offerings without needing multiple different licenses. For example, a team might start with a simple crypto–fiat exchange service. As they grow, they might want to add a custodial wallet service, an NFT marketplace, or a crypto lending feature. In Poland, all these activities fall under the same CASP umbrella as long as the company’s internal controls and capital are scaled appropriately to the new activity. You don’t have to apply for a brand-new license to introduce a new line of crypto services – often it’s just a matter of notifying the KNF of the expanded business (or at most requesting a license variation), rather than starting from scratch. This flexibility is ideal for startups, which often iterate on their product offerings. It allows innovation to happen under one regulatory roof, rather than dealing with fragmented licenses for each new idea.
- EU passporting and large market access. By getting licensed in Poland, a startup gains immediate access to the entire EU market of 27 countries. This is crucial – it means you can onboard customers from France, Germany, Italy, and so on without obtaining additional licenses in each country. For a startup, that kind of scale is key to achieving growth and network effects. Additionally, Poland itself is the largest economy in Central & Eastern Europe, adjacent to major markets like Germany. Setting up in Poland situates a startup in a region with millions of potential users and a growing crypto user base. The strategic location bridging Western and Eastern Europe can be beneficial for outreach and partnerships. Essentially, Poland can serve as a launchpad: you establish operations there, prove your model domestically, and you’re automatically able to expand services across the EU (subject only to simple notifications to the KNF/ESMA). This beats having to navigate 27 different national regulatory regimes separately.
- Credibility for investors and partners. Being regulated under an EU license in Poland provides legitimacy that can reassure both investors and business partners. Institutional investors or venture capitalists are more likely to invest in a crypto startup that is operating legally and transparently under EU rules than in an unlicensed entity. Likewise, other businesses (such as payment processors, liquidity providers, or potential corporate clients) will conduct due diligence – seeing that the startup is licensed in Poland (and listed on the official register) can significantly increase their trust. It signals that the team is serious about compliance and long-term operation. Since Poland’s regulator KNF is known and respected, having their approval is almost like a quality stamp. In contrast, being based in an unregulated environment could raise red flags. Thus, a Polish license can open doors to banking services, partnerships, and customer acquisition that might be closed to unregulated players.
- Supportive ecosystem and resources. Poland has a growing fintech and blockchain startup scene. There are numerous service providers (law firms, consulting companies, tech developers) with specific crypto expertise in Poland, given the large number of registered entities already. The government and regulator have shown engagement with the industry – for instance, the KNF has run an “Innovation Hub” program to assist fintech and crypto firms with regulatory queries. The presence of so many crypto companies (Poland had over 1,800 registered VASPs as of 2024) means there is a community and knowledge base to tap into. There are ample networking opportunities, industry events, and talent with crypto experience available in Poland compared to many other places. Additionally, Poland’s general business environment offers high-quality infrastructure (fast internet, modern office spaces in cities like Warsaw and Kraków) at relatively low cost. Operating costs (salaries, rent, etc.) in Poland are considerably lower than in hubs like London or Berlin, which is advantageous for startups burning through initial funding.
Official Sources & Primary Legislation (KNF / GIIF / MiCA)
Primary Acts
- Regulation (EU) 2023/1114 (Markets in Crypto-Assets, MiCA) — full text
- Regulation (EU) 2023/1114 (MiCA) — PDF version
- Regulation (EU) 2023/1113 — Transfer of Funds and Certain Crypto-Assets (EU Travel Rule) — full text
- Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (consolidated text, PDF, Polish)
- Act on the Crypto-Assets Market (Poland, 2025) — implementing MiCA at national level
KNF — Polish Financial Supervision Authority (Licensing Authority)
- Official KNF website
- FinTech & Innovation Hub — KNF support for CASPs and fintechs
- Crypto-Assets (MiCA) section — KNF supervisory information
- Public registers of supervised entities (to include CASPs under MiCA)
- Public warnings — unlicensed entities list
GIIF — General Inspector of Financial Information (AML/FIU Authority)
- GIIF main page — Financial Intelligence Unit of Poland
- Communication No. 77 (2023) — Status of Virtual Currency Operators
- Money Laundering Prevention — guidance and forms
- Register of Virtual Currency Activities (legacy VASP register)
EU Supervisory Registers & Guidelines (ESMA / EBA)
Jurisdictions for Obtaining a Crypto License in Europe
Get in touch with us
Daria Lysenko
Senior lawyer
Valeriia Kozel
Customer manager
Customer reviews
