Buy or Sell a VASP License — Poland, EU & International

The MiCA Transition Is Reshaping Europe’s Crypto Licensing — Acquiring an Existing VASP May Be Your Only Path Forward

The MiCA transition is reshaping Europe’s crypto licensing landscape. In many EU member states, the VASP framework is being retired, and CASP is taking over. The problem: fresh CASP applications are uncertain, slow (3–6 months), and sometimes blocked entirely. In several countries, they’re impossible right now.

For businesses that need to operate NOW — whether you’re launching a crypto exchange, a custody service, or a payment platform — acquiring an existing licensed entity is often the fastest path. And sometimes, it’s the only legal route available.

Zalewski Consulting facilitates both buy-side and sell-side VASP transactions across all EU member states. We don’t just broker deals; we handle full due diligence, regulatory transfers, post-acquisition compliance, and — critically — the CASP migration planning that comes after July 2026. Whether you’re buying your first crypto license or selling a legacy VASP operation, we’ve handled the process in Poland, Lithuania, Estonia, and across the EU.

Why Buy an Existing VASP?

Speed. Acquiring an existing entity takes weeks, not months. No regulatory application queue, no compliance review period for the license itself. You’re buying a legal right that already exists — just transferring ownership.

Grandfathering rights. Pre-existing VASPs registered before 30 December 2024 benefit from MiCA transition provisions. They can continue operating legally throughout the transition period, even in countries that have closed their VASP registers or begun phasing them out. This is not a minor technical detail — it’s a business lifeline for many companies.

EU-wide operations. A Polish VASP, for example, can operate across all 27 EU member states during the grandfathering period. You’re not limited to the jurisdiction where it’s registered. This is how many businesses currently operate across multiple European markets without needing separate licenses in each country.

Business continuity — the critical case. Many companies operated via VASP licenses in other EU member states. Now those jurisdictions have passed their transition deadline. The VASP register is closed. CASP applications are still pending. Their original license is being wound down. Acquiring a working Polish VASP is not a convenience — it’s a matter of business survival. They need operations to continue, and a ready-made VASP is the only route.

No application risk. A fresh CASP application can be refused, delayed, or caught in legislative limbo (which is exactly where Poland is right now). An existing VASP is already registered and operational. You inherit zero licensing risk — only regulatory transition planning.

Buy vs. build comparison: Fresh CASP application = 3–6 months (post-implementation, whenever that happens) + uncertain outcome. Ready-made VASP = weeks + guaranteed license.

Poland — The Last EU Country with Working VASPs

Here’s what makes Poland unique: it’s the only EU member state where VASPs can still freely operate without a pending CASP application. In other countries (Czech Republic, Lithuania), VASPs can only continue if they’ve already filed for CASP and are waiting. In Poland, VASPs simply operate — no CASP dependency, no artificial urgency.

The Polish advantage runs deeper. Polish VASPs are registered, operational, and can serve clients across all 27 EU member states. Because Poland hasn’t yet implemented the Crypto-Asset Market Act (due to a presidential veto), there’s no competing regulatory framework. No mandatory CASP migration path. No accelerated timeline. Polish VASPs have the longest remaining operational window in the entire EU — extending well beyond July 2026 because the domestic Polish crypto law hasn’t even been passed.

What’s available: We have a limited number of ready-made Polish sp. z o.o. companies with VASP registration. Each is a clean entity — no liabilities, no compliance issues, registered before the December 2024 register closure. These are not shell companies; they’re operational licensed entities.

The acquisition process: Identical to our shelf company service. You don’t acquire a “VASP registration” — you acquire the company that holds it. Share purchase agreement, S24 digital registration (can be done remotely in a few days, or in-person in a couple of hours), KRS update, and you’re the new owner. The VASP registration transfers with the company because the legal entity holds the license, not the shareholder.

After the transition: We don’t leave you at the finish line. When CASP applications eventually open (in Poland or elsewhere), we handle the entire licensing process for you. Scenario A: Poland passes the law → we process your CASP application at KNF. Scenario B: Poland remains in limbo → we process your CASP application in another EU member state (we handle CASP licensing across all 27 jurisdictions). Either way, you’re covered.

Learn more about Poland’s unique position and the full crypto licensing picture in our comprehensive hub → Crypto License in Poland & EU

Other EU Jurisdictions

Our reach extends across all EU member states. Each jurisdiction has its own company law, transfer procedures, and regulatory nuances. We handle them all.

Key considerations when acquiring a VASP outside Poland:

Transfer timelines vary by country. Poland’s S24 system is highly streamlined (days). Other jurisdictions have manual company registry processes (weeks). We know the fastest path in each country.

Digital processes differ. Some countries have fully digital company transfers. Others require notarized documents or in-person appearances. We manage these jurisdictional differences.

Regulatory notifications differ. Beneficial ownership filings, regulatory notifications to crypto supervisors, anti-money laundering updates — the requirements vary. We handle all jurisdiction-specific filings.

Non-EU Alternative: Canada (Money Service Business).

For businesses looking beyond the EU, Canada’s Money Service Business (MSB) framework offers a regulated path to crypto operations. FINTRAC-registered, covers virtual currency dealing and administration, recognized across Canada and increasingly for US-facing operations.

Explore Canadian MSB options → Buy Canadian MSB Registered Shelf Company

Our Process

For Buyers:

Step 1: Consultation. We understand your business model, target markets, timeline, and what you’re actually trying to do. Are you launching an exchange? A custody platform? An advisory business? Which EU markets matter to you? Do you have an immediate deadline? This determines the right entity type and jurisdiction. We also discuss which CASP class you’ll eventually need — it shapes the post-acquisition strategy. → See our CASP classes guide

Step 2: Matching. We identify the right entity from our inventory or source one that meets your requirements. This isn’t a generic shelf company — we’re matching you with a licensed operational entity. The fit matters.

Step 3: Due Diligence. Full verification: clean financial records, no liabilities, valid VASP registration, compliance status. We run AML reports and regulatory checks. You inherit no hidden obligations.

Step 4: Acquisition. Share purchase agreement, digital registration, ownership transfer. The technical process is straightforward — the complexity is in getting the entity right in the first place.

Step 5: Post-Acquisition Support. This is where we add real value. We assist with:

• Opening bank accounts (local Polish bank + international accounts + EMI/FIAT gateways)
• Virtual IBAN setup — this is critical. You get payment accounts with individual IBANs for each of your clients. Every crypto business needs this infrastructure; we help you get it.
• Compliance guidance for the transition period
• CASP transition planning (which jurisdiction, which class, preparation timeline)

For Sellers:

We also help VASP holders who want to sell their entities. Whether you’re exiting the crypto space, consolidating operations, or just looking to liquidate an asset, we facilitate the process.

Confidential process. Your VASP sale is not advertised publicly; we handle buyer matching discreetly.

Professional valuation. We assess the entity’s operational status, regulatory standing, and market value.

Fee structure. Depends on deal size and complexity. Contact us for details on our M&A fee arrangements.

Contact us to discuss listing your VASP.

FAQ

How fast can I acquire a VASP?

Depends on jurisdiction. Polish VASPs follow our shelf company timeline: remote procedure (a few days) or in-person visit (couple of hours). Other EU jurisdictions vary (days to weeks).

Can a Polish VASP operate in Germany, France, Italy, etc.?

Yes. All 27 EU member states. During the MiCA grandfathering period (which extends well beyond July 2026 in Poland’s case due to the legislative situation), Polish VASPs have full EU-wide operational rights.

What happens to my VASP after July 2026?

Transition to CASP. We process the application for you — either in Poland (if the law eventually passes) or in any other EU member state where applications are already open. Your business continues uninterrupted.

Do you handle sell-side too?

Yes. We facilitate VASP sales confidentially, handle valuation, match buyers, and manage the entire transaction.

What about bank accounts and payment infrastructure?

We assist with opening bank accounts (local + international + EMI gateways) and virtual IBAN setup — individual IBANs per crypto client. This is essential infrastructure for every crypto operation.

Can I buy a VASP from outside the EU?

Yes. Non-EU individuals and companies can acquire Polish entities. However, some jurisdictions have additional licensing or beneficial ownership requirements. We’ll advise on any specific restrictions based on your home country.

Ready to Buy or Sell?

Polish VASPs are in extremely limited supply. Once these are gone, they’re gone — the register is permanently closed.

Whether you’re looking to buy a working VASP to enter the EU crypto market, or you’re selling a legacy operation, we facilitate the entire process. Due diligence. Regulatory transfer. Bank accounts. Virtual IBANs. CASP transition planning. End-to-end.

Contact us today. Use WhatsApp, Telegram, Signal, email, or phone:

• WhatsApp: Chat on WhatsApp
• Telegram: Message on Telegram
• Signal: Contact via Signal
• Email: info@zalewskiconsulting.pl
• Phone: +48 222 90 10 90