Poland Crypto License: Your Path to Business Compliance

Planning to launch a crypto-related business in the EU? Poland offers a robust and structured path to become fully licensed and compliant under the EU’s Markets in Crypto-Assets Regulation (MiCA). While Poland previously operated a VASP (Virtual Asset Service Provider) registration regime until late 2024, the focus has now entirely shifted to MiCA compliance.

Here’s what you need to know-and do-to secure your poland crypto license.

Who Needs a Poland Crypto License?

Under MiCA, and consequently under Polish law, any business involved in the following activities for third parties must obtain a CASP authorization:

• Custody and administration of crypto-assets on behalf of third parties
• Operation of a trading platform for crypto-assets
• Exchange of crypto-assets for fiat currency that is legal tender
• Exchange of crypto-assets for other crypto-assets
• Execution of orders for crypto-assets on behalf of third parties
• Placing of crypto-assets
• Reception and transmission of orders for crypto-assets
• Providing advice on crypto-assets
• Providing portfolio management on crypto-assets

If you plan to offer any of the above within the EU-even remotely-obtaining a CASP authorization in Poland will allow you to operate legally across the bloc under the MiCA framework.

Step-by-Step: How to Register as a VASP in Poland

Step 1: Establish a Polish Company

You’ll need a local LLC (Sp. z o.o.) or other appropriate legal entity.

• Minimum Share Capital: This is crucial. MiCA mandates specific minimum initial capital requirements for CASPs, depending on the services offered:
• €50,000 for services like reception and transmission of orders, execution of orders, providing advice on crypto-assets, and portfolio management.
• €125,000 for services including custody and administration of crypto-assets, in addition to the €50,000 services.
• €150,000 for operating a trading platform for crypto-assets, in addition to the €125,000 services.

At least one director (can be a foreign national). Registered address in Poland

Step 2: Appoint an AML/Compliance Officer

You must appoint a person responsible for anti-money laundering (AML) and counter-terrorist financing (CFT) procedures, as well as other key management and compliance roles as required by MiCA. They must be properly qualified, trained, and have relevant experience. This person doesn’t have to be a Polish citizen but should have strong professional experience and ideally, access to Polish-speaking legal and compliance support for interactions with the Polish Financial Supervision Authority (KNF).

Step 3: File for VASP Registration

This is a significantly more detailed step than the previous VASP registration. You will need to prepare extensive documentation demonstrating compliance with all MiCA requirements, including:

• Full company data and organizational structure
• Detailed business plan outlining all crypto-asset services
• Proof of sufficient initial capital
• Information on the identity and good repute of management board members and significant shareholders
• Details of the AML/CFT officer and other key personnel
• Robust governance arrangements, internal control mechanisms, and risk management procedures
• IT and cybersecurity framework
• Proof of professional indemnity insurance (or sufficient own funds) for certain services.

Step 4: Develop AML Policy & Internal Procedures

You are expected to develop and maintain detailed, MiCA-compliant AML/CFT procedures, including:

• Enhanced KYC/CDD (Know Your Customer/Customer Due Diligence) checks
• Comprehensive risk assessment policy
• Advanced transaction monitoring systems
• Reporting obligations to the General Inspector of Financial Information (GIIF)
• Procedures for handling complaints and conflicts of interest. This documentation must be kept up-to-date and available for inspection by Polish regulators (KNF and GIIF).

Step 5: Start Operating-But Stay Compliant

The application is submitted to the KNF, which is the primary competent authority for CASP authorizations in Poland. The KNF will rigorously assess the application against all MiCA requirements.

Costs & Timeline

• Company registration: approx. €1,000–€1,500 (one-time, for a basic LLC structure)
• Minimum Share Capital: €50,000 – €150,000 (depending on services – required to be paid up)
• Regulatory application fees: To be confirmed by KNF, but expect them to be higher than previous VASP fees.
• Legal + compliance support: Varies significantly, but expect substantial costs (€15,000 – €50,000+ for setup, plus ongoing retainer) due to the complexity of MiCA.
• Timeline: Obtaining a CASP authorization under MiCA is a complex process. Expect a timeline of several months (e.g., 3-6+ months) from comprehensive application preparation to final approval, provided all documentation is complete and accurate.

Banking & Payments

Unlike many “light-touch” crypto jurisdictions, Poland gives you access to real EU banking, including SEPA, IBAN accounts, and payment gateways-assuming your business is clean and well-documented. Having a Polish crypto license also makes it easier to integrate with licensed European exchanges and fintech APIs.

To sum up, Poland now offers a robust and structured path for legitimizing crypto businesses within the European Union by obtaining a MiCA-compliant CASP authorization. Since the full implementation of MiCA, the country provides a clear regulatory framework and ensures access to reliable European banking services, which is a significant advantage. The process involves comprehensive steps, including establishing a Polish company with appropriate capital, appointing qualified key personnel, and developing detailed internal procedures. Throughout all stages, the support of qualified local experts is critical to successfully navigate the linguistic, legal, and regulatory complexities of MiCA.

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