Poland has the talent, customers, and crypto infrastructure to support a serious digital-asset business. But its domestic MiCA licensing route is still unavailable.
Protegra helps Warsaw-based businesses keep their Polish team and operations while placing regulated CASP services inside an authorised EU entity.
We map your services, select the right EU route, structure the relationship between the Polish and authorised entities, and prepare the business for passporting into Poland.
Keep Warsaw for operations. Build the licence where it can work.
Poland remains subject to MiCA, but a domestic CASP authorisation route is not currently operational. An EU-authorised CASP may provide permitted services in Poland after the relevant MiCA notification process.
A Poland MiCA project is not a normal licence application. The challenge is connecting the Polish business, the former VASP registration, the crypto product, and an alternative EU authorisation into one structure that can actually operate.
We turn Poland’s regulatory gap into a workable Warsaw-to-EU operating model.
Start your Poland assessment ⟶Schedule a regulatory strategy call ⟶We assess your crypto services and customer flows, your existing Polish registration, your Polish and EU customer targeting, your custody, exchange, transfer, brokerage, and advisory activity, the EU CASP authorisation route, and the passporting, payments, AML/CFT, and tax structure. You receive a practical answer: what can continue, what must change, and what requires authorisation — not conflicting advice from separate providers.
Your Polish company and team may continue handling technology, operations, product, support, or commercial functions while the authorised EU entity provides the regulated CASP services. We define which entity contracts with customers, which entity holds the authorisation, which functions are outsourced, who owns compliance and MLRO responsibility, and how customer, wallet, data, and reporting flows are controlled. The result is a real group structure, not a foreign licence attached to an unchanged Polish operation.
For an existing business, we help move from the former Polish registration to a compliant operating model. That may involve reviewing current services and customers, restricting activities that cannot continue, selecting an EU licensing jurisdiction, preparing the CASP application, migrating customers and contracts, reviewing Polish marketing and onboarding, setting up passporting, banking, and payment arrangements, and supporting an orderly wind-down where required.
Your Warsaw team can remain in place. The regulated activity needs to sit within an EU structure that can actually be authorised, supervised, and operated.
Poland entered the post-transition period with approximately 1,229 entities still recorded in its former Virtual Currency Activities Register. These businesses represented Poland’s established crypto market — but the register itself was not a MiCA authorisation.
By the end of the transition period, Poland had issued no domestic MiCA CASP authorisations. The market therefore had a large existing crypto base but no functioning Polish route for a new operator to obtain the authorisation locally.
A CASP authorised in another EU Member State can potentially provide its permitted services in Poland after the MiCA cross-border notification process — and use the same authorisation to access the other EU and EEA markets within its approved scope.
The EU route is not about abandoning Poland. It is about separating the location of your team from the location of the entity that must hold the regulated authorisation.
The exact allocation depends on the business model, outsourcing arrangements, employment structure, tax position, data flows, and the requirements of the chosen EU regulator.
Keep Warsaw for the operating team. Build the regulated entity around the supervisor that can authorise it.
Assess your group structure ⟶Poland’s regulatory gap creates different starting points for different businesses. The right next step depends on whether you are already operating, preparing to launch, or building an EU structure around a Warsaw team.
If you already provide crypto services from Poland, the first task is not choosing a new country. It is understanding what your business can continue doing now.
You receive: a written action plan showing what can continue, what must be restricted, and what should move to an authorised EU entity.
If you are still building the product, do not incorporate the operating model around the assumption that a Polish CASP licence will soon become available.
You receive: a Poland-to-EU structure designed before the product, contracts, and customer journey become difficult to change.
Your Warsaw company may remain responsible for technology, product development, operations, support, administration, or commercial functions that sit outside the regulated service.
You receive: a group structure that preserves Warsaw as an operating base while placing the licence and regulated responsibility where they can be supervised.
The former Polish register may explain where the business started. It does not provide the MiCA authorisation required for the next stage.
You receive: a controlled transition plan instead of an improvised response to the end of the legacy regime.
Poland currently does not offer a functioning domestic CASP authorisation route. If your business needs regulated EU authorisation, the practical route is to apply in an EU Member State with an operational MiCA supervisor and then assess passporting into Poland.
MiCA defines three CASP licence classes by service scope and minimum own-funds requirement. Identify yours below—then use the calculator to map the full cost of your Poland-to-EU structure. Getting the class wrong at the start can mean costly reclassification later.
Advice, portfolio management, reception and transmission of orders, execution of orders, placing, and transfer services. The right starting point for firms not planning to hold client crypto-assets, offer exchange services, or operate a trading venue.
Everything in Class 1, plus custody and administration of crypto-assets on behalf of clients and the exchange of crypto-assets for funds or for other crypto-assets. This is the class a Warsaw operator normally needs once it holds client assets or runs an exchange book.
Everything in Class 2, plus operation of a trading platform for crypto-assets. The widest MiCA scope, and the only class that covers running a venue where third parties trade.
Own-funds figures and service scope: MiCA, Annex IV of Regulation (EU) 2023/1114. Checked 22 September 2026. Own funds are the applicable minimum or one quarter of the preceding year’s fixed overheads, whichever is higher.
Poland charges nothing for a CASP authorisation because it does not currently issue one. The cost of this route is the EU authorisation you take instead, plus the group structure that connects it to the Warsaw team.
One licence, three levels — the regulator asks for exactly the same file in all three, and what changes is how much of it sits with you. The middle level is the default here: every price on this page is quoted at it, and the selector above the total switches between them. Moving up or down changes our fee and nothing else — not the capital, not the state fees, not the statutory clock. Carrying a file to the decision is not a promise of approval: no adviser can give one, and an adviser who does is selling you something other than advice.
Poland cannot authorise the entity today, so the choice is which EU supervisor does. These are the four routes Protegra files, with the Year 1 estimate each page publishes. All four passport into Poland through the same MiCA notification.
| EU host state | Year 1, estimated | What it gives a Warsaw team |
|---|---|---|
| Slovakia | €120,000 | The cheapest EU route we publish. Suits a lean Warsaw team that needs authorisation without a large local footprint. |
| Cyprus | €163,500 | An established CySEC process and a deep local services market; a statutory audit applies to every Cyprus company. |
| Malta | €169,500 | The longest-running crypto supervisor in the EU, and the most demanding on substance and documentation. |
| The Netherlands | €199,500 | The heaviest governance expectations of the four, and the strongest banking access once authorised. |
Year 1 figures are the estimates published on each jurisdiction page and cover professional fees, formation, substance, DORA and accounting; they exclude own funds, which are held as capital rather than spent. The Warsaw-to-EU estimate in the calculator is €154,000: higher than a single-country route because it carries two lines those routes do not, the group and outsourcing structure and the transition of existing customers and contracts.
A Poland project starts with what the business does today, not with a choice of country. The jurisdiction is selected once the regulatory perimeter is known.
We document the Polish business as it operates today: ownership and entities, current registration, products and services, customers and markets, contracts and terms, wallets and custody, payment flows, marketing, outsourcing, and AML and compliance controls.
We determine which activities fall within MiCA, which may require payment authorisation, which functions can remain in Poland, and which services need to be provided by the authorised EU CASP — and whether existing customers and operations can continue, or migration or wind-down is required.
We compare possible licensing jurisdictions by regulator and pre-application access, service scope, own funds, application fees, local management, substance requirements, banking and payments, tax and accounting, passporting, and compatibility with the Warsaw team.
We design the relationship between the Polish and EU entities: customer contracts, regulated-service responsibility, support services, outsourcing, compliance reporting, technology access, data flows, cost allocation, and management and escalation.
We prepare the selected jurisdiction’s CASP application: business plan, financial projections, governance, own-funds analysis, AML/CFT, ICT and DORA, custody, outsourcing, client protection, complaints, disclosure, and regulatory reporting.
We coordinate customer migration, contract updates, website and marketing changes, wallet and custody migration, banking and payment activation, staff and service-provider arrangements, Polish operational restrictions, and communications with customers and counterparties.
After authorisation, we support the notification process for Poland and other target EU and EEA markets. The business then moves into supervised operations with AML monitoring, DORA and ICT controls, client-asset protection, regulatory reporting, outsourcing oversight, material-change notifications, and ongoing passporting management.
Authorisation is the point at which the Warsaw-to-EU structure has to work in production. We stay with it.
Notification management for Poland and the other EU and EEA markets within the authorised scope, and new-service assessments as the product grows.
Ongoing financial-crime controls, operational-resilience governance, and the ICT evidence the home-state regulator expects to see maintained.
Client-asset safeguards, regulatory reporting, and the banking and payment relationships the structure depends on.
Oversight of the Warsaw company as an outsourced provider, cost allocation, material changes, and the documentation that keeps the two entities properly separated.
Your Warsaw team can remain in place. The authorised EU entity becomes responsible for the regulated activity.
Poland’s gap is not a technicality. Each of these is a question a Warsaw business has to answer before it can operate anywhere in the EU.
See how we work ⟶Not as a substitute for MiCA authorisation after the transition period ended.
Waiting may be commercially reasonable for some businesses, but it should be an informed decision.
The team may remain in Warsaw. The regulated service cannot simply remain with the Polish company if that company does not hold the required authorisation.
Not automatically. The authorised entity, customer contracts, website, marketing, onboarding, disclosures, and service flows must all reflect the authorised structure and the passporting position.
No. Passporting supports cross-border provision of authorised CASP services. It does not replace Polish tax, payment, employment, consumer, AML, data, or corporate analysis.
A new wallet feature, staking product, payment flow, token, custody model, or trading function may change the regulatory scope.
Select a challenge to see how a Poland project moves from a stalled registration to a structure that can be authorised and supervised.
“We assumed our former Polish registration allowed us to continue until a new Polish law arrived.”
“We understood which services were affected and created a plan to restrict, migrate, wind down, or move the regulated activity into an authorised EU entity.”
“We thought obtaining an EU licence meant moving the entire company and team out of Poland.”
“We retained Warsaw for technology and operations while designing a separate EU entity to hold the regulated responsibility.”
“We assumed a foreign licence automatically covered our existing Polish website, contracts, customers, and marketing.”
“The authorised entity, passporting notification, customer documents, website, and Polish operations were aligned before launch.”
Reference: Crypto-asset service provider (MiCA CASP) licences compared in the Licensing Atlas.
Leave your details and we will assess your current position, identify whether your activities require CASP authorisation, and determine whether Poland or another EU Member State should sit at the centre of your regulated structure. You will receive a personalised Poland crypto-regulatory plan within 24 hours.
Poland used to be one of Europe’s most active crypto markets. Its virtual-currency register contained 1,841 businesses, ranging from small peer-to-peer operators…
The AFM published its MiCA expectations before applications opened. What Dutch CASP licensing really takes: two regulators, real substance, class choice.
Brussels reopened MiCA on 20 May 2026, months after its transition ended, while Brazil writes its first crypto rulebook. What both mean for 2026 plans.