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The CASP authorisation in Poland is based on the EU-wide MiCA framework and, once granted, provides the same EU passporting rights as a MiCA authorisation obtained in other EU Member States, including the Netherlands and Germany.
However, Poland has faced significant legal and regulatory uncertainty because its national legislation implementing MiCA and establishing the domestic supervisory framework has repeatedly been vetoed by President Karol Nawrocki. Therefore, while Poland offers the potential advantages of an EU MiCA authorisation and access to the EU market, its regulatory environment in 2026 remains less predictable than in other EU jurisdictions. The SBSB team of fintech lawyers can help cope with local licensing nuances.
What Is a CASP License?
In 2023, the Markets in Crypto-Assets Regulation (MiCAR) was adopted in the European Union to establish a single legal framework for crypto-asset businesses. Providing crypto-asset services across the EU is possible only under a license. According to Article 3, paragraph 1 of MiCAR, 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.
Entities already holding an old VASP license had a transitional period to obtain a license under MiCA.
How Is Cryptocurrency Regulated in Poland?
Being in the European Union, Poland automatically follows the Markets in Crypto-Assets Regulation (MiCA). Like any other EU member state, it must designate its competent authority and establish administrative procedures for authorisation and supervision. Also, national legislation must be adopted to support MiCA’s operation.
In practice, the Polish Parliament adopted the Crypto-Assets Market Act in late 2025 to establish Poland’s national framework. According to this document, the Polish Financial Supervision Authority (KNF) is expected to be a MiCA competent authority. But President Karol Nawrocki has repeatedly blocked the government’s legislation aimed at regulating the cryptocurrency market and implementing the European Union’s Markets in Crypto-Assets (MiCA) regulation. The three vetoes occurred on the following dates:
- December 1, 2025: The first version of the bill was rejected.
- February 2026: A slightly revised version was vetoed.
- June 11, 2026: The third, and most recent iteration, was vetoed.
The President has argued that the government’s proposed laws represent excessive regulatory intervention. This has created a significant gap between the directly applicable MiCA framework at EU level and the unsettled Polish national implementing framework. Following the expiry of the MiCA transitional period on 1 July 2026, entities providing crypto-asset services in Poland must hold a valid MiCA authorisation; registration under the former Polish virtual-currency regime is no longer sufficient.
In Poland, a CASP licence must be granted by the Polish Financial Supervision Authority (KNF). But because of the president’s veto, it is impossible to submit a CASP application to the regulator as of today. To provide CASP services in Poland, a business may obtain a relevant licence in any other EU member state (Lithuania, Estonia, Czechia) with normal passporting of services to Poland. As of today, it is the only legal solution.
What Are the Benefits of Getting a Crypto License in Poland?
Obtaining a CASP license in Poland could be advantageous due to low-cost market entry.
What Are the Advantages of a CASP License in Poland?
When the legal conflict is resolved, Poland, like any other EU member state, may provide crypto-asset service providers with EU passporting rights and lower operating costs. Here, the business environment, including tax codes and consumer protections, is predictable. Companies can grow safely. And even the current presidential vetoes can be considered a protective mechanism, defending the business sector from burdensome administrative regulations.
What Are the Requirements for Obtaining a CASP License?
Obtaining a CASP license in EU member states may differ slightly. Typically, a company must establish a local entity with at least one director residing in the EU and ensure domestic physical substance. Share capital must be deposited, according to the range defined by classes. Developing proper AML/ICT policies is another crucial requirement.
Before applying for authorisation, an entity must prepare filings. The package must include foundational documents, a business plan with a detailed description of services and perspectives, data about directors, and internal policies.
What Are the Capital and AML/KYC Requirements for CASPs?
Under MiCA, CASPs must meet a minimum share capital requirement of €50,000, €125,000, or €150,000. Each amount, respectively, corresponds to the following types of services:
- 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.
- 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.
- Class 3. Operation of a trading platform for crypto-assets and Class 2 services.
A local AML officer must be appointed to oversee the implementation of AML/KYC policies, monitor daily compliance, and report suspicious transactions. He also must ensure employees understand regulatory rules.
How Does the CASP Licensing Process Work?
Generally, a CASP licensing process is smooth and well-structured. The filings are submitted online or by post. The receipt is officially confirmed in writing.
What Are the Steps to Apply for a CASP License in the EU?
To apply for a CASP license in the EU, a service provider is typically expected to register a legal entity in the chosen jurisdiction, open a physical office, and hire personnel. Then, an applicant must take the following steps:
- Develop a detailed business plan with a strategy.
- Develop internal policies.
- Appoint a director and an AML officer with essential credentials.
- Deposit the required share capital.
- Prepare and submit a documentation set.
- Wait for the approval and get started with the operation.
When the filings are reviewed, the regulator can request any other information that will help an accurate assessment of the company’s stability.
How Is a Company Incorporated in Poland?
The veto issue concerns the crypto-assets/MiCA implementing legislation solely, not the general Polish company-registration system. In Poland, corporate entities are registered with the National Court Register (KRS), while sole proprietorships are registered with the Central Register and Information on Economic Activity (CEIDG). Companies can generally be established either through the traditional procedure, involving a Polish notary where required, or electronically using the S24 system for eligible company forms.
To start with, the original name, the right legal form, and a PKD code that best corresponds to the business activity should be selected. Then the required documents, such as the company’s agreement or articles of association, are prepared and submitted. Once registered, the company is entered in the Register of Entrepreneurs.
How Does the Application Submission to the Regulator Work in Poland?
As of today (September 2026), in Poland, CASP license applications cannot be submitted. However, a company seeking access to the Polish market may obtain a MiCA authorisation in another EU Member State and subsequently use the MiCA passporting regime to provide its authorised services in Poland, subject to the applicable notification requirements.
How Does the CASP Application Review Process Work?
Under MiCA, the competent authority must acknowledge receipt of a CASP application within five working days. Within 25 working days of receiving the application, it checks whether the application is complete. The regulator may require an applicant to submit additional documents. Then, within 40 working days, it will review the business model and security policies. The 40 working days are counted from receipt of a complete application. Again, during the assessment, the authority may request additional information, which can suspend the assessment period. Therefore, although the formal statutory assessment periods are relatively short, the overall authorisation process may take 6 months or more depending on the complexity of the application and any requests for additional information.
What Happens After CASP License Approval?
After a CASP license is approved, the company receives notification and can operate across the EU member states.
What Is the Tax Regime for Crypto Businesses in the EU?
In most EU member states, crypto-asset companies are governed by the general tax codes and pay a corporate income tax. There may be a reduced rate for small and new taxpayers. Sometimes, a special tax regime is involved.
Crypto businesses operating in Poland may be subject to different tax regimes depending on where the CASP is established and tax-resident. A CASP authorised and tax-resident in another EU member state generally remains subject to that local corporate tax regime. Obtaining a MiCA authorisation in one EU Member State and passporting the authorisation into Poland does not, by itself, make the CASP a Polish tax resident.
What Should You Know Before Providing Crypto Services in Poland?
Before providing crypto-asset services in Poland, businesses should be aware of the current legal and regulatory uncertainty surrounding the implementation of MiCA. As a result, CASP authorisation applications cannot currently be submitted in Poland.
If you prefer a different EU state to register a crypto business, such as Austria, the SBSB team of fintech lawyers is always ready to provide end-to-end support, ensuring full compliance with MiCA regulations.
FAQ About CASP License in Poland
Who regulates CASP licenses in Poland?
The main regulator for CASP licenses in Poland is the Polish Financial Supervision Authority (KNF). However, the national legislation that establishes the Polish competent authority for CASPs has not entered into force following the President’s veto.
How long does it take to obtain a CASP license in Poland?
Now, it is impossible to obtain a CASP license in Poland. But you can submit an application in any EU member state you like. The timeline differs. Typically, the process takes 6 to 8 months.
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?
Yes, it can. Under Article 143(3) of MiCA, the EU-wide transitional period for existing crypto-asset service providers that were lawfully operating under national law before 30 December 2024 ended on 1 July 2026 at the latest.
Jurisdictions for Obtaining a Crypto License in Europe
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