Poland has attracted over 1,500 crypto and fintech entities with a low-cost registration system for Virtual Asset Service Providers (VASPs). This simple framework is now being replaced by a regime that aligns more closely with the EU’s Markets in Crypto-Assets (MiCA) Regulation.
Under the proposed system, all crypto firms will be supervised by the Polish Financial Supervision Authority (KNF). Operating without a license may be punishable by up to $2.5M in fines or two years' imprisonment.
This guide outlines what founders need to know — the key changes, main requirements, deadlines, application steps, and ongoing obligations for operating as a licensed Crypto-Asset Service Provider (CASP) in Poland.
TL;DR
How Does Poland Regulate Crypto?
MiCA established a unified EU market for crypto-asset services. This enables passporting, allowing a CASP licensed in one EU state to operate across all 27 member countries.
Poland aims to implement these rules through the proposed Crypto Asset Market Act (Bill 1424). The Polish lower house of Parliament passed Bill 1424 on September 26, 2025. If approved by the Senate and signed by the President, the new rules will take effect within 14 days of promulgation.
This will trigger strict measures aimed at protecting investors and tightening supervision.
- Administrative oversight will shift from the Register of Virtual Currencies to the KNF, with a full licensing and enforcement system to replace the simple registration process that was introduced in 2021.
- KNF-issued licenses will be mandatory for all CASPs, and unauthorized operations or illegal token issuance will face serious sanctions, including fines and jail terms.
- Dishonest domains may be blacklisted by the KNF, including websites and IP addresses associated with illegal activities.
How Are Tokens Classified?
Under MiCA, a token’s classification defines the applicable laws. It is necessary to understand these categories before issuing tokens or operating a platform that lists them.
- Utility tokens: These are the broadest category, providing access to a product or service. Issuers do not need prior authorization but must publish a detailed whitepaper and are legally responsible for its accuracy and completeness.
- Asset-referenced tokens (ARTs): These are stablecoins that maintain value by referencing a basket of assets such as multiple fiat currencies or commodities. Issuers must be EU-based, obtain authorization from the KNF, and comply with strict rules on reserve management, governance, and transparency.
- E-Money tokens (EMTs): These are stablecoins pegged to a single official fiat currency, such as the Euro. They are subject to the highest level of regulation and can only be issued by licensed banks or authorized electronic money institutions.
- Security tokens: These represent financial instruments, such as shares or debt. They are regulated under the Markets in Financial Instruments Directive (MiFID II) and relevant guidelines issued by the European Securities and Markets Authority (ESMA).
Obtaining a Crypto License in Poland
The proposed Crypto Asset Market Act set an initial deadline for existing companies to apply for a CASP license by June 30, 2025. Since the law has not yet been adopted, the transitional period was amended so that existing operators may continue to do business:
- 4 months from the date the Act enters into force, or
- Up to 9 months after the Act enters into force, if the VASP has already submitted a complete application to the KNF within 3 months of the law’s entry into force.
The KNF, which will formally oversee licensing once the law is enacted, has encouraged operators to begin preparing and filing applications. However, the KNF currently lacks statutory authority until the law takes effect, and the legal mechanism to obtain a license is not in place.
Choosing a Polish CASP License
The new regime proposes tiered minimum capital requirements for CASP licensing according to the services a company offers.
Regulated Business Activities
The scope of regulated activities under MiCA and Polish law is broad and covers most crypto business models, including:
- Cryptocurrency exchanges.
- Crypto-to-crypto trading.
- Fiat-to-crypto and crypto-to-fiat conversion.
- Virtual asset custody services.
- Peer-to-peer crypto trading.
- OTC brokerage services.
- Cross-border crypto payments and money transfers.
- Advisory services related to crypto-assets.
- Portfolio management involving crypto-assets.
- Custodial storage and management of digital assets.
- Placement of crypto assets and token swaps.
- Crypto payment gateway integration.
Licensing Requirements
The KNF conducts a detailed review of each applicant to ensure the business meets strict organizational and compliance standards. Applicants are expected to meet specific requirements to be considered eligible, although these may be updated when the national law comes into force.
- Corporate setup: The company must be a Polish legal entity with a physical premises of effective management in the EU.
- Governance: At least one director must reside in the EU or EEA. All directors, senior managers, and major shareholders must meet “fit and proper” criteria (good reputation, relevant experience, and a clean criminal record).
- Compliance framework: Applicants must have MiCA-compliant internal policies covering anti-money laundering and countering the financing of terrorism (AML/CFT), know-your-customer (KYC), risk management, and DORA-compliant cybersecurity.
- Documentation: The application must include a detailed business plan, three-year financial forecasts, and a clear description of the company’s structure and internal controls.
Application Process
Corporate and Operational Setup
- Register a Polish Entity: Set up a limited liability company (Sp. z o.o.), or a joint-stock company (S.A.), or a simple joint-stock company (P.S.A.) in the National Court Register (KRS).
- Establish local presence: Secure a physical office in the EU.
- Appoint key personnel: Form a management board that meets EU/EEA residency and “fit and proper” standards, and structure the hiring of personnel to meet the European Securities and Markets Authority (ESMA)’s minimum organizational requirements.
- Obtain essential credentials: Each director and shareholder must have a PESEL (Polish ID/tax number) and EPUAP (trusted profile for e-signatures) to access government systems.
Compliance Documentation
- Corporate: Articles of association and an extract from the National Court Register.
- Financial: Proof of minimum capital, business plan, description of the procedure for segregating customer assets and funds, and three-year financial projections.
- Personnel: CVs and clean criminal record certificates for all board members and beneficial owners.
- Compliance: Full suite of internal policies covering AML/KYC, risk management, business continuity, and internal controls.
- Operational security: Documentation of ICT systems and security arrangements.
- Service-specific: Depending on business activities, include documents such as custody policies, platform rules, or order execution procedures.
Submission and Review
The proposed application fee for CASP licensing is €4,500. Applicants are expected to pay this fee and submit the full documentation package to the KNF for a two-stage review.
The KNF has 25 working days to confirm the application is complete. If any documents are missing, the KNF will request them and may set a new deadline for submission. After confirmation of the completeness check, the KNF has 40 working days to review and issue a decision.
Given the backlog of applications from existing VASPs and the expected surge in new applications from prospective market entrants, applicants should plan for a total review period of six months or more.
Post-Licensing Obligations
- Administrative fees: Licensed CASPs may be required to pay the KNF around 0.4% – 0.5% of their annual revenue as a supervisory fee.
- Ongoing reporting: CASPs must report all suspicious transactions and any transaction above €15,000 to the General Inspector of Financial Information (GIFI). They must also provide the KNF with regular updates on their financial status and all cybersecurity incidents.
- AML/CFT & Travel Rule: AML/CFT programs, including continuous monitoring of customer transactions and compliance with the EU Travel Rule, are all mandatory.
- Operational resilience: CASPs must keep client assets fully segregated from company funds to safeguard user holdings.
- KNF supervision: Licensed operators may be subject to both scheduled and surprise audits by the KNF, which may wield broad enforcement powers, including the ability to blacklist domains and freeze assets linked to non-compliant activity.
Benefits of a Polish Crypto License
- EU passporting: A Polish CASP license grants access to the entire 27-member EU market, allowing businesses to operate across borders without separate licenses.
- Cost efficiency: Poland offers lower operating costs than Western European hubs. The corporate tax system is also attractive, with a standard 19% rate and a reduced 9% rate for new or small businesses with revenue under €2M.
- Access to talent: Poland’s tech ecosystem provides a large, skilled, and English-speaking workforce, and its developers often rank among the world’s best.
Conclusion
Poland is heading towards a structured, EU-aligned framework for crypto licensing. For businesses, this means crypto operations in Poland will now require careful planning, transparent governance, and long-term compliance readiness.
The window to apply for a license is crudely defined, and the legal mechanism to facilitate smooth licensing is still a work in progress. However, applicants who prepare early will be best positioned when regulatory certainty yields a competitive advantage across the EU market.
Preparing for a KNF application? A MiCA-readiness audit can help you identify compliance gaps before you apply. Contact Hacken team to learn more.
