Crypto-Asset Service Provider authorization under MiCA (Poland)

At a glance

What it lets you do, and where

What does a Polish CASP licence let you do, and where can you serve clients?

A MiCA CASP authorisation covers the 10 crypto-asset services defined in MiCA Article 3(1)(16). Under Article 65, the home NCA forwards information to host states within 10 working days, and the CASP may start on receipt or by the 15th calendar day at the latest. KNF confirms that granting domestic CASP authorisations requires statutory designation of the competent authority, while cross-border passporting into Poland remains possible.¹⁷¹

Activities it covers

Where it is valid

Do you need it, and is Poland the right choice?

What is a Polish MiCA CASP licence and do you need one?

A Polish MiCA CASP licence is an authorisation to provide crypto-asset services under EU Regulation 2023/1114, and one is needed to provide those services commercially. KNF states it cannot yet start or conduct authorisation proceedings in Poland until the competent authority is designated by statute. Crypto-asset services provided in a fully decentralised manner without any intermediary fall outside MiCA (Recital 22).²¹¹⁷

Is Poland the right jurisdiction for your CASP model, and what are the alternatives?

Not at present. With the MiCA transition ending and Polish licensing unavailable, market operators face a choice between obtaining authorisation abroad or changing their business model. Latvia actively recruits Polish crypto founders through ministry outreach and Warsaw meetings. SIA AlphaRoute received a Latvijas Banka CASP licence on 18 June 2026; Kanga declares it is behind the company, though this is not officially confirmed, and KangaExchange.EU is not yet operating.¹⁸¹⁹²⁰

Yes. MiCA Article 65 enables single-market passporting across EU Member States via notification to host Member States. The home NCA transmits the cross-border notification to host NCAs within 10 working days under Article 65(2). KNF confirms that foreign CASPs passport freely into Poland while domestic licensing is suspended.¹⁶²¹

Not necessarily. Existing investment firms and banks may provide crypto services via simplified notification under MiCA Article 60. EMT issuance is restricted to credit institutions and EMIs under MiCA Article 48 and the Polish Payment Services Act. Tokenised securities and crypto derivatives are financial instruments under MiFID II and the Polish Financial Instruments Trading Act of 2005.²

No. Poland issued 0 licences, with licensing completely frozen as of September 2026. By contrast, ESMA's fast-track peer review of a CASP authorisation and supervision in Malta was published on 10 July 2025; the report does not name OKX, whose four-day authorisation was reported by CoinDesk.¹²¹

Fully decentralised protocols without intermediaries are exempt under MiCA Recital 22. Crypto-asset advice is a crypto-asset service under MiCA Article 3(1)(16)(h), covered by Article 81, which requires providers to inform clients whether the advice is provided on an independent basis. White paper notification procedures for utility tokens are governed by MiCA Articles 6 to 8 and the draft Polish crypto bill.²¹⁶

Not strictly. Under MiCA Article 75(8), custodians are liable for loss of crypto-assets or means of access resulting from an incident attributable to them, capped at market value, so liability is fault-based, not strict. MiCA Article 70 requires safeguarding of client crypto-assets and segregation from proprietary assets. Druk nr 2529 Article 128 amends Code of Civil Procedure art. 829 to exempt CASP clients' funds and crypto-assets from enforcement against the CASP.²

What it really takes

How much capital do you really need for a Polish MiCA CASP licence?

You must hold prudential safeguards of at least the higher of the Annex IV minimum capital for your class or one quarter of the preceding year's fixed overheads. New firms use projected fixed overheads for the first 12 months. Class 1 minimum capital is EUR 50,000, Class 2 is EUR 125,000, and Class 3 is EUR 150,000.¹⁶

Who do you have to hire for a Polish CASP, and where must they be based?

Under MiCA Article 59(2), a CASP must have its place of effective management in the EU with at least one EU-resident executive director. A senior-manager AML compliance officer is mandatory under Article 8 of the Polish AML Act of 1 March 2018. DORA (Regulation (EU) 2022/2554) sets ICT risk management and incident reporting roles.²²²²³

In which language must a Polish CASP application and documents be filed?

Polish. The official language of public administration proceedings is Polish under the Polish Language Act of 7 October 1999, Articles 4 and 5. Foreign-language documents need certified translations by a sworn translator (§13), and foreign official documents must be legalised by a Polish consul (§14). Public administration bodies prepare a concise protocol of each proceeding activity of significant importance under KPA Article 67 § 1.²⁴²⁵

The application must contain 19 items, points (a) to (s), under MiCA Article 62(2). Information requirements are set in Commission Delegated Regulation (EU) 2025/305 under MiCA Article 62(5), and standard templates and procedures in Commission Implementing Regulation (EU) 2025/306 under MiCA Article 62(6). Your dossier must follow those requirements and forms.⁹²⁶²

Requirements

The legal framework

The procedure under the law

How long it takes

KNF has 25 working days to assess application completeness under MiCA Article 63(2). Once the application is complete, a 40-working-day substantive assessment runs under Article 63(9). The clock stops under Article 63(12) if KNF requests further information by the 20th working day, suspending the paragraph 9 period for at most 20 working days.²

Statutory: 25 working days completeness assessment from receipt, followed by 40 working days decision period from receipt of a complete application². Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.

What it costs

What does a Polish CASP licence cost in total (fees, first year, ongoing)?

An annual supervisory levy is proposed at up to 0.4% of crypto revenue with a minimum fee of €500. The Polish draft Crypto-Assets Market Bill caps the application fee at up to €4,500. The KPRP head cited over-regulation (100+ pages beyond MiCA) and large additional fees, but gave no 0.4% figure.²⁷²⁸²⁹

Approval odds and who can own it

What are the real approval odds for a Polish CASP, and why do applications fail?

KNF says proceedings to issue a CASP licence in Poland can only begin once the competent authority is designated by statute, so no application is currently approved. EU-wide, roughly 17% of pre-MiCA VASPs (about 210 of 1,200-plus) converted to full CASP authorisation. Separately, an Estonian court declared BB Trade Estonia OÜ, operator of the Zondacrypto exchange, bankrupt on 27 August 2026.¹³⁰³¹

Who can own and run a Polish crypto company under MiCA?

Both owners and managers can be assessed: KNF's suitability methodology covers the criminal record, reputation and financial standing of assessed persons. If you plan to take a qualifying holding crossing 20%, 30% or 50% of voting rights, you must notify in advance under MiCA Articles 83 and 84, and that assessment takes 60 working days.²³²

How many CASP licences has the Polish KNF actually granted?

None yet. Parkiet reported on 3 August 2026 that 320+ CASPs appear in the ESMA register while 0 MiCA licences have been issued by KNF. KNF confirmed that granting domestic CASP authorisations requires statutory designation of the competent authority. The Virtual Currency Activities Register (RDwW) listed 1,089 non-deleted entries as of 30 June 2026.¹³³¹⁸

After you get the licence

What other licences and regulatory regimes do you need alongside a Polish CASP?

A Polish CASP must comply with DORA (Regulation (EU) 2022/2554) for ICT operational resilience and the Transfer of Funds / Travel Rule (Regulation (EU) 2023/1113) for crypto transfers. MiCA restricts EMT offering to issuers authorised as credit institutions or EMIs. The Act of 29 July 2005 governs trading in financial instruments; crypto derivatives are not mentioned.^22341735

Will a Polish bank open an account for your crypto company?

It is difficult: Poland has no statutory right to a bank account for CASPs, and banks routinely de-risk crypto firms. In a documented case, BitMarket24 sued KNF for 2.48 million PLN after a January 2019 warning-list entry led Credit Agricole to terminate its accounts within days; court hearings took place in 2026.³⁶³⁷

What does it take to keep a Polish CASP licence, and what is changing?

Under MiCA Article 64(1), an authorisation must be withdrawn if the provider has not used it within 12 months (a), has not provided services for nine consecutive months (c), no longer meets authorisation conditions without timely remedial action (e), lacks effective AML/CFT systems (f), or seriously infringes MiCA (g). Under Article 143, the VASP transitional period ends no later than 1 July 2026; a simplified authorisation procedure is available until then.¹⁰³⁸

Can you appeal a KNF refusal of a CASP licence, to whom and by when?

Yes. Under KPA Article 127 § 3, you can request reconsideration by the same organ, with appeal rules applied accordingly. KNF issues administrative decisions under Article 11(1) of the Financial Market Supervision Act. You can also file an administrative court complaint to the WSA in Warsaw within 30 days under the Law on Proceedings before Administrative Courts (p.p.s.a.) Article 53 § 1.³⁹¹⁴⁴⁰

No fixed validity period is stated. MiCA Article 64(1) allows withdrawal if the authorisation is unused for 12 months or if no services are provided for nine consecutive months. Later, acquisitions of qualifying holdings reaching 20%, 30% or 50% need prior notification and an assessment within 60 working days (Articles 83 and 84), while management board changes only require notification to the competent authority (Article 69).²

Is an old Polish virtual currency registration (RDwW) still valid after 1 July 2026?

No. The transitional period under MiCA Article 143(3) expired on 1 July 2026, so an old RDwW registration no longer protects the activity. KNF states that entities in the virtual-currency register kept by the Katowice Revenue Administration Chamber lose the Article 143(3) transitional right after 1 July 2026 until authorised. Operating without registration carries an administrative fine up to 100,000 PLN under Polish AML Act Article 153b.²⁴¹²⁹¹

Buying a company that already holds it

The CASP authorisation is granted strictly to a specific legal entity and cannot be assigned, transferred, or sold to another legal person. Any change of ownership or control must occur through a corporate transaction (share deal) subject to prior qualifying holding notification to KNF under MiCA Articles 83-84. An asset deal or transfer of business requires the acquiring entity to apply for and obtain its own separate CASP licence.²

Prior notification with an objection period. Acquiring or increasing a qualifying holding needs prior notification to the KNF, which can object within 60 working days (extendable by up to 20 working days while it waits for information). Under MiCA Articles 83-84, any natural or legal person proposing to acquire or increase a qualifying holding crossing 20%, 30%, or 50%, or making the CASP a subsidiary, must give prior written notification. KNF evaluates acquirer reputation, financial soundness, and AML risk during the 60-working-day assessment period. Shares acquired in breach carry no voting rights.⁴

Ready-made companies holding this licence: see verified positions.

CASP in other countries

Values come from each licence's page, where every figure has its source.

Laws behind it

• Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114

Getting this licence

Protegra handles this licence end to end: CASP license in Poland: process, timeline and our fee.