CASP License Poland - MiCA Compliance for Crypto Businesses

CASP licensing for crypto businesses in Poland - VASP to CASP transition under MiCA

If you're preparing to launch a crypto business in Poland or the European Union - or already operating as a registered VASP in Poland - you need to obtain a CASP license to stay compliant under the MiCA regulation. Since December 30, 2024, all Virtual Asset Service Providers (VASPs) are being reclassified as Crypto Asset Service Providers (CASPs), requiring formal KNF authorization to continue offering services legally within the EU.

Our team helps you navigate this transition with ease. From assessing your eligibility to preparing documentation and communicating with the Polish Financial Supervision Authority (KNF), we handle the entire process — so you can focus on growing your business across all 27 EU Member States.

What services are covered by a CASP license?

Under the MiCA regulation, companies must obtain a CASP license to legally offer the following crypto-asset services. Once licensed, your business can operate across all EU Member States via passporting:

Effective date of MiCA regulation and grace period provisions in Poland

The MiCA framework officially took effect on December 30, 2024. Businesses that had not started offering crypto services prior to this date must secure CASP authorization before beginning operations. Those entities already registered in the Polish VASP register can continue their operations temporarily — in line with transitional arrangements:

• Up to June 1, 2025, if no application for a CASP license is submitted by May 1, 2025
• Up to September 30, 2025, if a full application is submitted before May 1, 2025

These dates may be subject to change as the legislative process progresses.

Crypto industry landscape in Poland

According to the 2023 Fintech Foundation Report, Poland's crypto and fintech ecosystem has grown rapidly and is expected to continue expanding. As the largest financial services hub in Central and Eastern Europe, Poland is likely to attract significant investment and talent.

As of December 2024, there were 1,841 registered VASPs. Following MiCA's entry into force, new VASP registrations are no longer accepted after December 30, 2024, per a statement by the Chamber of Fiscal Administration in Katowice.

According to a nationwide 2023 survey, over 94% of Poles are aware of cryptocurrencies, but only 6.2% report a high level of understanding. Most people invest in crypto for speculative purposes. Crypto is rarely used for daily transactions, blockchain projects, or remittances.

Young adults under 34 make up 41% of crypto holders. Ownership is more common among men and correlates with higher education levels.

Eligible applicants for a CASP license

Entities that can apply for CASP status under MiCA include:

• EU-based limited liability (sp. z o.o.) or joint-stock (S.A.) companies
• Credit institutions, securities depositories, investment firms, electronic money institutions, and other entities listed in Article 60 of MiCA

Applicants must:

• Be headquartered in the Member State where the license is issued
• Have at least one board member residing in the EU
• Satisfy minimum capital requirements (see next section)
• Submit full internal documentation
• Ensure management has a clean criminal history and demonstrable expertise

Minimum capital requirements

Depending on service class, companies must hold:

CASP application process in Poland

1. 1.
   Submit the application to the KNF.
2. 2.
   Receive acknowledgment of receipt within 5 business days.
3. 3.
   KNF reviews the submission for completeness (up to 25 business days).
4. 4.
   If documents are missing, the applicant must supplement them.
5. 5.
   Once complete, content review begins.
6. 6.
   During the review, KNF may request further information (up to 20 days).
7. 7.
   Final decision is expected within 40 business days from initial validation.

Delays may occur due to correspondence and procedural steps.

Estimated licensing cost

Internal documentation checklist

Management board requirements

Per Article 68 of MiCA and ESMA guidance:

• Board members must be reputable, qualified, and experienced
• At least two board members are recommended
• The CEO should dedicate 100% of work time to CASP management
• One board member must reside in the licensing Member State
• Members must be present and available to KNF during operations
• Criminal records must be clean, or reviewed individually by the regulator
• Dual employment is allowed if it doesn't hinder duties

KNF has indicated that connections to Russia or Belarus may be grounds for concern regarding the integrity of licensed activity.

Shareholder due diligence

Shareholders with qualifying holdings must:

• Provide a clean criminal record
• Declare absence of financial, commercial, or AML-related penalties
• Submit an ownership and voting rights chart

Staff and structural requirements

Employees must possess adequate experience for assigned duties.

The following departments should be in place:

Each department should be headed by a qualified manager available to the regulator.

CASP license Poland - frequently asked questions