MiCA CASP License in Poland - European Union passporting (Crypto Asset Service Provider)

MiCA CASP License in Poland — Application, Requirements and Current Status

As of February 2026, CASP applications cannot be filed in Poland. The Crypto-Asset Market Act — the legislation that would implement MiCA and designate a competent authority for CASP licensing — has been vetoed by the President of Poland. Twice.

This page explains what a CASP license is, what the general application requirements look like under MiCA, where things currently stand in Poland, and what your realistic options are right now. We keep this page updated as the situation develops.

If you need to operate a crypto business in the EU immediately, the fastest route is to acquire a ready-made Polish VASP — an existing licensed entity that gives you EU-wide operational rights today, with no regulatory queue.

What Is a CASP License?

CASP stands for Crypto-Asset Service Provider. It is the new licensing category under the Markets in Crypto-Assets Regulation (MiCA) — the EU-wide framework that replaces the patchwork of national VASP regimes that existed before 30 December 2024.

Under MiCA, any business that wants to provide crypto-asset services in the European Union must be authorized as a CASP by the national competent authority (NCA) in its home member state. Once authorized, the CASP can passport its services into all other EU countries — no additional license needed, just a notification to the host state regulator.

MiCA divides CASP authorization into three classes based on the services you provide, each with a different minimum capital requirement: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3). The class you need depends on whether you are running an advisory business, an exchange, or a full custody platform. For a detailed breakdown of each class and which one fits your business model, see our MiCA CASP Classes — Information Guide.

In Poland, the competent authority for CASP licensing was expected to be the KNF (Komisja Nadzoru Finansowego — the Polish Financial Supervision Authority). However, this was a point of political disagreement. The president has argued that the KNF is not sufficiently crypto-friendly and has suggested the National Bank of Poland as an alternative. Until the implementing legislation is passed, this remains unresolved.

CASP Application Requirements Under MiCA

The specific requirements for CASP authorization in Poland will depend on the final text of the implementing law — which has not yet been passed. However, MiCA itself sets out the general framework that all EU member states must follow. Below is an overview of what to expect.

Capital Requirements

The minimum initial capital depends on your CASP class. Class 1 (advisory and order services) requires €50,000. Class 2 (exchange and trading) requires €125,000. Class 3 (custody and full service) requires €150,000. These are regulatory minimums — they do not include the costs of preparing your application or the professional fees involved in the licensing process.

Governance and Management

MiCA requires that CASP applicants demonstrate fit and proper management. Directors and key personnel must have relevant professional experience, clean regulatory and criminal records, and the capacity to dedicate sufficient time to the role. You will need a designated compliance officer and an AML officer. We facilitate the full governance setup — from identifying suitable candidates to preparing the fit-and-proper documentation.

Operational Requirements

A CASP must maintain a physical office in the EU member state where it is authorized. At least one member of management must be domiciled in the EU. These are standard requirements across all EU jurisdictions and are straightforward to arrange — particularly in Poland, where we provide virtual office and registered address services as part of our broader company formation practice.

Compliance Framework

Every CASP applicant must present a robust AML/KYC framework — including policies for client onboarding, ongoing transaction monitoring, and suspicious activity reporting. MiCA also requires cybersecurity standards, IT resilience measures, and data protection protocols. The compliance framework needs to be proportionate to the scope and complexity of the services you intend to offer.

Poland-Specific Considerations

The vetoed bill proposed that CASP licensing fees would be approximately €4,500. It also included a provision requiring Polish banks to open accounts for locally licensed CASPs — a meaningful advantage for regulated crypto firms that often struggle with banking access. Whether these provisions will survive in a future version of the law is unknown.

All of the above requirements are things we help our clients prepare. The fact that the law has not been passed does not mean you cannot start getting ready. In fact, preparing now is the smartest move — so you can file immediately when the window opens.

The Application Process (When Available)

Once the implementing legislation is passed, the CASP application process in Poland is expected to follow the standard MiCA timeline.

How It Will Work

You submit your complete application to the designated competent authority — most likely the KNF, though the National Bank of Poland remains a possibility. The authority reviews the application against MiCA requirements: capital adequacy, governance, compliance framework, operational readiness. Based on the experiences of other EU member states that have already begun processing CASP applications, the review and authorization process typically takes one to two months for well-prepared applications.

The Practical Implication

One to two months is fast by regulatory standards. But that timeline assumes a clean, complete submission. Firms that submit half-prepared applications face delays, additional information requests, and the risk of rejection. The KNF (if designated) already has experience with complex financial licensing — they handle Electronic Money Institutions (EMIs), Payment Institutions (PIs), and Small Payment Institutions (SPIs). We have worked with the KNF on these types of applications and understand how the regulator operates.

What You Should Do Now

We strongly advise clients who intend to apply for CASP in Poland to retain us now — before the law is passed — and begin preparing the application documentation. Governance structures, compliance frameworks, AML policies, capital planning, IT security assessments — all of this can be assembled in advance. When the law is finally passed, we already have more or less what is needed for filing. You will not be starting from scratch while your competitors scramble.

Current Status: The Presidential Veto

Here is the timeline of what has happened.

The Sequence of Events

In late 2024, MiCA entered into force across the entire European Union. Each member state was required to adopt national implementing legislation — designating a competent authority, setting local fees, and integrating MiCA into their national regulatory framework.

Poland’s government drafted the Crypto-Asset Market Act during 2025. The bill proposed the KNF as the competent authority for CASP authorization and included provisions to facilitate banking access for licensed CASPs.

In December 2025, the President of Poland vetoed the bill. His stated reasons included concerns about the KNF’s approach to crypto regulation — he argued the authority was not sufficiently crypto-friendly — and suggested the National Bank of Poland as an alternative supervisor.

The government attempted to override the veto in parliament. On 12 February 2026, the override failed. The bill was dead.

Poland became — and remains — the only EU member state without MiCA implementation.

Why It Happened

This is a political conflict, not a regulatory one. The disagreement between Poland’s government and its president is rooted in institutional politics, not in any substantive objection to crypto regulation itself. Both sides support MiCA in principle. They disagree on who should supervise it.

For businesses trying to plan around this, the important takeaway is simple: nobody knows when or in what form the law will eventually pass. The government may draft a new bill. It may try to negotiate with the president. It may attempt another override with a different coalition. The president may accept a revised version, or veto again.

What This Means for You

No CASP applications can be filed in Poland. No new VASP registrations have been possible since December 2024. The only working crypto licenses in Poland today are existing VASPs that were registered before the cutoff. These remain fully operational — and there is a strong argument, shared by multiple Polish crypto law experts, that if Poland continues to delay MiCA adoption, crypto activity in Poland simply will not require CASP authorization. No law, no CASP requirement. This is not just our position — it is a view debated extensively by specialized crypto lawyers in Poland.

For businesses that need to operate now, the practical solution is to acquire a ready-made Polish VASP. For those who prefer to wait for CASP, we help you prepare in advance so you can file the day applications open.

What To Do Right Now

Given the current situation, you have three realistic paths forward. Each depends on your timeline, risk tolerance, and business needs.

Acquire a Ready-Made Polish VASP

This is the fastest path to market. A Polish VASP gives you immediate operational rights across all 27 EU member states under MiCA’s grandfathering provisions (Article 143(3)). The acquisition process is identical to buying a shelf company — fast, proven, handled through Poland’s S24 digital registration system. We have ready-made VASPs available now, but the supply is extremely limited. The register is permanently closed and these entities cannot be replaced.

For the full details on acquiring a Polish VASP, including the process, what you receive, and post-acquisition support: Crypto License in Poland & EU — VASP, CASP and MiCA.

Apply for CASP When the Law Passes — or in Another EU Jurisdiction

If your timeline allows it, you can wait for Poland’s implementing legislation and then apply for CASP authorization. We help you prepare all documentation in advance so you are ready to file immediately. The application process itself is expected to take one to two months.

Alternatively, if you cannot wait for Poland, we handle CASP licensing across all EU member states. Lithuania, the Netherlands, Slovakia, Malta, France, and Cyprus are among the jurisdictions currently processing CASP applications. Once authorized in any EU member state, you can passport into Poland and all other EU countries. For jurisdiction options and our multi-country services, see our Buy or Sell VASP License page.

Prepare and Wait

Even if you do not plan to apply immediately, you can use this period to build your compliance infrastructure. Set up governance structures, appoint key personnel, develop your AML framework, arrange your capital, and establish banking relationships. When the regulatory path clears — whether in Poland or elsewhere — you will be positioned to move fast. We offer a preparation-stage engagement specifically for this purpose.

EU Passporting Under MiCA

One of MiCA’s most significant advantages is the single-license principle. A CASP authorized in any EU member state can provide services across all 27 member states through a passporting notification. No separate application. No additional license. Just a notification to the host country regulator.

This applies regardless of where you are authorized. A CASP license obtained in Lithuania works in Germany. A license from Malta covers France. A Polish CASP — when available — would cover the entire EU.

It is worth noting that this passporting principle already applies to existing Polish VASPs during the grandfathering period. A Polish VASP registered before 30 December 2024 can serve clients across the entire European Union right now — including in countries that have already wound down their own VASP regimes.

For the full breakdown of CASP classes and what services each class covers, see our MiCA CASP Classes — Information Guide.

Frequently Asked Questions

When will CASP applications open in Poland?

Unknown. The implementing legislation has been vetoed twice, and there is no confirmed timeline for a new bill. It could be months. It could be longer. We monitor the situation continuously and will update this page as developments occur.

Can I prepare for my CASP application now?

Yes — and you should. We offer a preparation-stage engagement where we assemble your governance documentation, compliance framework, AML policies, and capital planning in advance. When the law passes, you file immediately instead of starting from scratch.

What if I cannot wait for Poland?

Two options. First, you can acquire a ready-made Polish VASP for immediate EU-wide operations. Second, we can process your CASP application in another EU member state (Lithuania, Netherlands, Slovakia, Malta, France, Cyprus, among others) and passport into Poland once authorized.

Will my CASP license work across the entire EU?

Yes. MiCA provides EU-wide passporting. Once authorized as a CASP in any member state, you can operate in all 27 EU countries through a notification process. No separate license required in each country.

Is Poland still a good jurisdiction for crypto business?

Yes. Despite the current legislative delay, Poland has a mature fintech ecosystem, competitive operating costs, and — uniquely — the only working VASPs left in the European Union. Once the implementing legislation passes, Poland’s CASP framework will benefit from the KNF’s existing experience with financial services licensing. The delay is political, not structural.

Get in Touch

Whether you want to prepare for a CASP application in Poland, apply for CASP in another EU jurisdiction, or acquire a ready-made Polish VASP for immediate operations — we handle the entire process.

Contact us to discuss your situation, timeline, and the best regulatory path for your business.

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• Email: info@zalewskiconsulting.pl
• Phone: +48 222 90 10 90