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At the moment, a CASP license cannot be obtained in Poland: the country has not designated a national authority to grant it. Polish crypto businesses can still serve clients lawfully by obtaining a CASP authorisation in another EU member state and passporting it into Poland under MiCA. The SBSB team of fintech lawyers helps businesses choose a suitable jurisdiction and obtain a CASP license in countries such as Cyprus, Germany, or Malta, and serve the Polish market through passporting.
What Is a CASP License in Poland?
In 2023, the Markets in Crypto-Assets Regulation (MiCA) was adopted in the European Union to establish a single legal framework for crypto-asset businesses. MiCA has applied to crypto-asset service providers since 30 December 2024, and providing crypto-asset services in the EU is possible only under a CASP authorisation. According to Article 3, paragraph 1 of MiCA, crypto-asset services are as follows:
- providing custody and administration of crypto-assets on behalf of clients;
- operation of a trading platform for crypto-assets;
- exchange of crypto-assets for funds;
- exchange of crypto-assets for other crypto-assets;
- execution of orders for crypto-assets on behalf of clients;
- placing of crypto-assets;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets;
- providing portfolio management on crypto-assets;
- providing transfer services for crypto-assets on behalf of clients.
Under MiCA, an authorisation is granted by the competent authority of an EU member state. In Poland, the Polish Financial Supervision Authority (KNF) is expected to perform this role, but it has not yet been designated.
Can You Get a CASP License in Poland Now?
No. Poland is currently the only EU member state without a working national MiCA framework. The Crypto-Assets Market Act, which would designate the KNF as the competent authority for CASPs, was vetoed by the President three times: in December 2025, February 2026, and June 2026. On 4 September 2026, the Sejm failed to override the latest veto, as it fell 25 votes short of the required majority.
As a result, the KNF has no legal basis to accept or review CASP applications and cannot grant licenses. The KNF remains the competent authority only for issuers of e-money tokens (EMTs). MiCA itself applies directly in Poland, and the EU-wide transitional period ended on 1 July 2026 without extension. Entities that were registered in the Polish VASP register could operate under national rules only until that date. Without a CASP authorisation, they may no longer provide crypto-asset services.
The situation may change if Parliament adopts the implementing law, so it is important to check the current status before making decisions.
How Is Cryptocurrency Regulated in Poland?
Poland is a member of the European Union, so MiCA applies in the country directly. Poland was expected to designate a competent authority and establish procedures for authorisation and supervision through national legislation. Because the Crypto-Assets Market Act has not entered into force, the national framework is incomplete. This does not suspend MiCA: providing crypto-asset services to clients in the EU, including in Poland, still requires a CASP authorisation or another status permitted by MiCA.
What Are the Options for Crypto Businesses Targeting Poland?
Polish and foreign businesses that want to serve Polish clients have the following lawful options:
- obtain a CASP authorisation in another EU member state and passport the services into Poland;
- wait until Poland adopts the implementing law and the KNF starts accepting applications, which has no confirmed timeline;
- stop providing MiCA-regulated services.
The first option is the only one available today. A CASP authorised in another member state can provide its authorised services in Poland through the MiCA notification procedure, and the Polish regulator has confirmed this approach. A physical office in Poland is not required for this.
How Does Passporting into Poland Work?
The process works in the following way:
- The CASP obtains an authorisation in its home EU member state.
- The CASP submits to its home regulator the information about the services it intends to provide in Poland and the intended start date.
- The home regulator informs the Polish authorities, ESMA, and the EBA within 10 working days.
- The CASP may start providing services in Poland on the date it receives the home regulator’s confirmation, or no later than the 15th calendar day after submitting the notification, whichever occurs earlier.
What Are the Requirements for Obtaining a CASP License in the EU?
Because the authorisation is obtained in another member state, the requirements are those of the chosen jurisdiction under MiCA. In general, an applicant must:
- establish a legal entity in the chosen EU member state with a registered office and local presence;
- appoint at least one director who resides in the EU and ensure effective management within the EU;
- prepare a business plan with a detailed description of services and projections;
- develop internal policies, including AML/CFT, risk management, and ICT security;
- provide information about directors and shareholders for fit-and-proper checks;
- hold the required minimum capital.
Some jurisdictions apply additional national requirements, such as the number of resident directors or local staff, so the choice of country affects the budget and timeline.
What Are the Capital and AML/KYC Requirements for CASPs?
Under MiCA, CASPs must meet a minimum capital requirement of €50,000, €125,000, or €150,000, depending on the services provided:
- Class 1. Execution of orders on behalf of clients, placing crypto-assets, providing transfer services for crypto-assets on behalf of clients, receiving and transmitting orders for crypto-assets on behalf of clients, providing advice on crypto-assets, and providing portfolio management for crypto-assets — €50,000.
- Class 2. Providing custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, and Class 1 services — €125,000.
- Class 3. Operation of a trading platform for crypto-assets and Class 2 services — €150,000.
CASPs must also implement AML/KYC procedures: identify and verify clients, monitor transactions, and report suspicious activity. A designated AML compliance officer oversees these procedures and ensures that employees understand the rules.
How Long Does It Take to Obtain a CASP Authorisation?
MiCA sets the following statutory clock for the regulator: 25 working days to check the completeness of the application and 40 working days to decide after the application is complete. In practice, requests for additional information and the preparation of the file extend the process, so timelines differ between jurisdictions and are usually longer than the statutory periods. A realistic estimate should be made for the chosen country.
Can a Company Be Set Up in Poland?
A Polish company can be registered for business activities in Poland. The most common form is a limited liability company (sp. z o.o.) with a minimum share capital of 5,000 PLN, registered in the National Court Register (KRS) through a notary or the S24 online system. However, until the implementing law is adopted, a Polish company cannot be authorised as a CASP, and incorporation in Poland does not replace the authorisation obtained in another EU member state.
What Is the Tax Regime for Crypto Businesses in Poland?
Companies in Poland are subject to the general corporate income tax (CIT) rate of 19%. A reduced rate of 9% applies to small and new taxpayers. To qualify as a small taxpayer, the company’s gross sales revenue in the previous tax year must not exceed the equivalent of €2 million. The tax residence of a company depends on where it is registered and managed, so the choice of the licensing jurisdiction also affects the taxation of the group.
What Should You Know Before Applying?
Before making decisions, you should know that Poland currently has no authority to grant CASP licenses, and the situation depends on future legislation. For most businesses, the practical solution is to choose another EU jurisdiction that matches the business model, budget, and substance requirements, and to serve Poland through passporting. The SBSB team of fintech lawyers is ready to compare jurisdictions, prepare the application, and support the passporting procedure into Poland, including in countries such as Cyprus, Germany, and Austria.
FAQ About CASP License in Poland
Who regulates CASP licenses in Poland?
The Polish Financial Supervision Authority (KNF) is expected to become the main regulator for CASP licenses in Poland once the implementing law enters into force. At present, it has not been designated for CASPs. Depending on the business model, the National Bank of Poland may also be involved for services overlapping with payment or e-money activities.
How long does it take to obtain a CASP license in Poland?
As of now, KNF has not been designated as Poland’s MiCA competent authority and cannot grant CASP licenses, so there is no confirmed timeline. Drawing on the experience of other EU member states, a well-prepared application could be expected to take several months (the statutory periods under MiCA are 25 working days for the completeness check and 40 working days for the decision), although the exact timeline varies depending on the complexity of the business and the quality of the documentation submitted to the regulator.
Which crypto services require a CASP license in Poland?
Under MiCA, services such as operating a crypto-asset trading platform, exchanging crypto-assets for funds or other crypto-assets, providing custody and administration of crypto-assets, and executing orders on behalf of clients typically require CASP authorisation.
Can an existing VASP registration be converted into a CASP license?
No. The transitional period ended on 1 July 2026, and Poland currently has no authority to grant a CASP license. Providers that have not obtained a CASP authorisation can no longer provide crypto-asset services. They may obtain an authorisation in another EU member state and passport it into Poland.
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