Europe

Crypto License in Poland

Poland is the EU jurisdiction where the headline and the reality diverge most. MiCA applies, but the Polish implementing Act on the Crypto-Assets Market has been vetoed twice — so as of mid-2026 the regulator (KNF) has no domestic legal basis to accept CASP applications. Anyone selling you a clean Polish CASP timeline today is not reading the legislature.

  • Regulator — Komisja Nadzoru Finansowego (KNF)
  • Timeline — Gated by national legislation — see status below
  • Capital — €50,000 / €125,000 / €150,000 (by CASP class)
  • Lead expert — Tomáš Novák

Quick Facts

ParameterValue
RegulatorKomisja Nadzoru Finansowego (KNF)
License typesMiCA CASP — Class 1 · MiCA CASP — Class 2 · MiCA CASP — Class 3
Minimum capital€50,000 / €125,000 / €150,000 (by CASP class)
Typical timelineGated by national legislation — see status below
Corporate tax19% (reduced 9% for small taxpayers)
RegionEurope

Current status (mid-2026): can you actually apply yet?

Short answer: not cleanly. Poland's national Act on the Crypto-Assets Market — the law that gives the KNF the power to authorise CASPs — was vetoed by the President twice (reported on 1 December 2025 and again on 12 February 2026, on the grounds it over-burdened small business). Until a version is enacted, the KNF has no domestic legal basis to receive and decide CASP applications, even though MiCA itself is in force EU-wide. Treat any "Polish CASP in X weeks" promise as a red flag.

What happens after the 1 July 2026 transition cliff

MiCA's transitional window for legacy operators runs to 1 July 2026. If Poland still has no national act in force by then, firms mid-transition face a genuine legal vacuum: no enacted basis to be authorised domestically, and the transitional cover gone. The practical exposure is that you cannot lawfully serve Polish clients as a CASP, with a wind-down obligation rather than a grace period. This is the scenario the templated "open for business" guides simply do not mention.

Wait for Poland or file elsewhere? A decision view

If you…Then
Need to be live in the EU within 6 monthsFile in Lithuania or another member state with an open CASP process and passport into Poland
Are Poland-anchored (team, market, banking)Prepare the file now (substance, AML pack) so you can submit the day the act is enacted — but do not assume a date
Hold a legacy Polish registrationPlan a wind-down or passport-in path before 1 July 2026 rather than relying on a law that may not pass in time

A CASP passport is jurisdiction-agnostic for the holder — authorising elsewhere and notifying into Poland is, for most operators, faster and lower-risk than waiting on Warsaw.

Why Poland?

Poland is a wait-or-pivot decision in 2026, not a file-now jurisdiction. We track the legislative status and tell clients plainly when the window actually opens — and where to file in the meantime.

Requirements for a Poland crypto license

Every Poland crypto application turns on six pillars. Get them right and the regulator interaction becomes routine; get them wrong and you spend the next six months in RFI cycles.

Step-by-step process for a Poland crypto license

  1. Strategy and gap analysis. We map your business model to the available licence categories at Komisja Nadzoru Finansowego (KNF) and identify the gaps before any regulator interaction.
  2. Incorporation and substance setup. Local entity formation, resident-director arrangement, registered office and AML officer appointment are completed in parallel to save weeks on the timeline.
  3. AML / KYC programme drafting. Transaction monitoring rules, sanctions screening, KYB onboarding flow, MLRO reporting matrix and Travel Rule provider selection are documented to regulator-grade standard.
  4. Application file and submission. The application file is built to the actual reading list of Komisja Nadzoru Finansowego (KNF) examiners — not a generic template — and submitted with a covering memo addressing the most common RFI triggers.
  5. Regulator engagement and RFI cycles. We respond to Requests for Information within published service-level windows and brief you weekly on engagement progress.
  6. Approval and onboarding. On approval, the post-licence onboarding sprint covers banking, payment rails, audit firm appointment, and the first annual return calendar.
  7. Ongoing supervision. Annual reporting, AML programme refresh, MLRO appointments and material change notifications are calendared and monitored.

Costs breakdown

Total first-year all-in cost combines four lines: regulator fee, statutory capital tied up unproductively, legal fees, and substance (resident director, office, AML officer, technology audit). Ongoing supervision sits on top from year two onwards. We model three-year total cost upfront so the budget is realistic.

Cost lineIndicative range
Regulator feeConfirmed in writing at engagement
Statutory capital€50,000 / €125,000 / €150,000 (by CASP class)
Legal feesFixed-scope quote at kickoff
Substance (year 1)Resident director, office, AML officer
Ongoing supervision (year 1+)Annual audit, returns, AML refresh

Taxation

The corporate tax position in Poland is 19% (reduced 9% for small taxpayers). Tax is structuring-dependent — the headline rate is rarely the rate a properly-structured group ends up paying. Tax advice is provided in cooperation with locally-admitted tax counsel and is scoped separately from the licensing engagement.

Documents required

Our experts for Poland

Tomáš Novák

Senior Counsel — EU & Eastern Europe

Six years at the European Banking Authority working on MiCA technical standards and the Transfer of Funds Regulation.

Jurisdictions: Georgia · EU MiCA (cross-cutting)

Languages: English, Czech, Polish, Russian

  • LL.M. KU Leuven
  • Czech Bar
  • Former EBA Senior Policy Officer

Daniel R. Whitmore

Founder & Managing Partner

Founder. Eight years at a Magic Circle firm leading the financial-regulation emerging-tech desk before founding the firm in 2018.

Jurisdictions: United Kingdom · United States · Jersey · Gibraltar · Switzerland

Languages: English, French

  • LL.M. Financial Regulation, LSE
  • Solicitor (England & Wales)
  • New York Bar
  • CLLS Financial Law Committee

Frequently asked questions

Can I get a crypto (CASP) licence in Poland right now?

Not cleanly. As of mid-2026 the Polish Act on the Crypto-Assets Market has been vetoed twice and is not in force, so the KNF has no domestic legal basis to accept and decide CASP applications. MiCA applies EU-wide, but the national implementing law is the missing piece.

Why was Poland’s crypto law vetoed?

The President vetoed the Act on the Crypto-Assets Market (reported on 1 December 2025 and again on 12 February 2026), citing concerns that it placed an excessive compliance burden on small and medium businesses. Until a revised version is enacted, KNF authorisation of CASPs cannot proceed.

What happens to my Polish crypto business after 1 July 2026?

MiCA’s transitional window runs to 1 July 2026. If Poland still has no national act in force by then, firms relying on the transitional regime face a legal vacuum — no domestic basis to be authorised and the transitional cover expired — which in practice means a wind-down rather than a grace period. Plan a passport-in or exit path ahead of the date.

Is Lithuania faster than Poland for a CASP licence right now?

For most operators, yes. Lithuania has an operating CASP process while Poland’s is legislatively blocked. Authorising in an open member state and passporting into Poland is currently the lower-risk route to serve Polish clients legally.

Who is the crypto regulator in Poland?

The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) is designated as the competent authority for CASPs under MiCA — but it can only exercise that power once the national implementing act is enacted.

How much does a Polish CASP licence cost?

Once the regime opens, MiCA capital tiers apply (€50,000 / €125,000 / €150,000 by class) plus a KNF application fee and legal/substance costs. We confirm the live fee schedule in writing at engagement, because the figures move with the enacting legislation.

Related jurisdictions

Speak with our Poland licensing team.

A free 30-minute call with Tomáš Novák — the partner who would lead your Poland engagement.