Crypto License in Poland & EU — VASP, CASP and MiCA
Poland is the only EU member state where Virtual Asset Service Providers can still freely operate. Not “with restrictions.” Not “subject to a pending CASP application.” Freely. In every other EU country, VASP operations have either been terminated or — in a handful of cases like the Czech Republic and Lithuania — are allowed only if the operator has already filed for CASP authorization.
What does that mean for you? If you need to run a crypto business in the European Union right now, a Polish VASP gives you something no other jurisdiction can: immediate, legal, EU-wide market access with no regulatory queue to sit in.
There’s a catch. The Polish VASP register has been closed since 30 December 2024. No new registrations are accepted. The only way to get a Polish VASP today is to acquire an existing one on the secondary market — and the supply is extremely limited. Once the remaining entities are sold, there will be no more.
Zalewski Consulting has ready-made Polish VASPs available for immediate acquisition. We have been in the company formation and fintech advisory business for almost 30 years and have sold over 2,000 ready-made companies in Poland. Below, we explain the full regulatory picture — what a VASP is, what a CASP is, what the MiCA veto means, and what your options are right now.
What Is a Crypto License in Poland? VASP vs CASP
Two terms dominate crypto licensing discussions in Poland and the EU: VASP and CASP. They refer to two different regulatory frameworks, but both are relevant to anyone looking for a crypto license today.
VASP — Virtual Asset Service Provider (Legacy Framework)
The VASP regime was Poland’s original crypto licensing framework. Introduced in late 2021, it required businesses to register with the Polish Tax Authority (not the financial regulator). Registration covered four types of activity:
- Exchange between cryptocurrencies and fiat currencies
- Exchange between cryptocurrencies themselves
- Brokerage in the above exchange activities
- Maintenance of crypto wallets and payment accounts necessary to perform those activities
The barrier to entry was low. There was no minimum capital requirement. The main conditions were that company directors needed to declare at least one year of experience in the crypto industry and have no criminal record. The registration fee was nominal.
The register is now closed. Since 30 December 2024 — the date MiCA entered into force across the EU — no new VASP registrations have been accepted in Poland. But existing VASPs registered before that date remain fully operational. We still have ready-made ones available for sale.
CASP — Crypto-Asset Service Provider (MiCA Framework)
CASP is the new EU-wide licensing framework under the Markets in Crypto-Assets Regulation (MiCA). It replaces the patchwork of national VASP regimes with a single, harmonized authorization system.
Under MiCA, CASPs are divided into three classes based on the services they provide, each with different minimum capital requirements: €50,000, €125,000, or €150,000. Authorization is granted by the national competent authority in each EU member state. In Poland, this will most likely be the KNF (Komisja Nadzoru Finansowego — the Polish Financial Supervision Authority), although the National Bank of Poland is also a possibility. The bill that would decide this has not been passed.
And that is the problem. CASP applications cannot currently be filed in Poland. The legislation needed to implement MiCA has been vetoed — twice. We explain the situation in the next section.
For a detailed breakdown of the three CASP classes, their capital requirements, and which class fits your business model, see our MiCA CASP Classes — Information Guide.
Why Both Terms Still Matter
Existing VASPs are grandfathered under MiCA’s transition provisions. They can continue operating legally — in Poland and across all 27 EU member states — while the CASP framework takes effect. This makes pre-December 2024 Polish VASPs the only active crypto licenses available in Poland today.
The Current Reality: Poland’s MiCA Veto
Poland’s Crypto-Asset Market Act — the legislation that would implement MiCA and establish the CASP authorization framework — has been vetoed by the President of Poland twice. The first veto came in December 2025. The second followed on 12 February 2026, when parliament failed to override it.
Poland is now the only EU member state without MiCA implementation.
What This Means in Practice
No competent authority has been designated for CASP applications. No new crypto licenses of any kind can be obtained from scratch. The VASP register is closed to new entrants. From a regulatory standpoint, Poland is in a kind of limbo.
But here is what many people miss: this situation is actually convenient for those who acquire existing Polish VASPs. Because Poland has not implemented MiCA, existing VASPs operate under the old framework — which has fewer regulatory requirements — while still benefiting from EU-wide recognition during the grandfathering period. 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 for even longer. No law, no CASP requirement.
The Outlook
The political standoff between Poland’s government and its president is unpredictable. It is driven by politics, not regulatory logic. Nobody — and we mean nobody — knows when or in what shape the crypto law will eventually pass. The government may try a third time. They may draft an entirely new bill. The president may accept it or veto again.
For businesses that need to operate now, waiting for this to resolve is not a strategy.
For the full technical picture of CASP application requirements and the legislative timeline, see our dedicated page: MiCA CASP License in Poland.
Your Options Right Now
Given the current regulatory situation, you have three practical paths forward. Each suits a different timeline and risk tolerance.
Option A: Buy a Ready-Made Polish VASP
This is the fastest route to market and, for many businesses, the only one that makes sense right now.
A ready-made Polish VASP gives you immediate market access across all 27 EU member states. That includes countries that no longer allow their own VASPs to operate — your Polish VASP is recognized EU-wide during the MiCA transition period under Article 143(3).
The acquisition process is identical to buying a shelf company in Poland. It is a proven, fast procedure handled through the S24 digital registration system (the Polish Company Registry). If you visit Warsaw in person, the transfer can be completed in a couple of hours. If you prefer to handle everything remotely, it takes a few days depending on courier services — the same process we use for our regular ready-made shelf companies.
After acquisition, we cover every scenario. If Poland passes the MiCA implementation law, we process your CASP application at the KNF (or whichever authority is designated under the final bill). If Poland does not pass the law, we process your CASP application in another EU member state. Either way, you are covered.
This option is particularly critical if your business operated via a VASP in another EU country that has already been wound down. In several member states, the MiCA transition period has already expired, and businesses that have not yet received their CASP authorization are left without a license. Acquiring a working Polish VASP — which has the longest remaining transition window in the EU — is not a matter of convenience for these companies. It is a matter of business survival.
Option B: Wait for Poland’s CASP Framework
If you have no immediate operational needs, you can wait for the legislation to pass and then apply for CASP authorization in Poland. The timeline is unpredictable, but the application process itself, once available, is expected to take one to two months.
The risk here is straightforward: the July 2026 grandfathering deadline continues to approach regardless of political delays. And there is a counterargument worth considering — many Polish legal experts specializing in crypto law argue that as long as Poland has not passed the implementing legislation, there is no CASP requirement in Poland. Crypto business can continue under the existing VASP framework (for those who have one) or without specific authorization entirely.
This is not just our opinion. It is a position shared by multiple crypto-specialized lawyers in Poland who have debated this question extensively.
Option C: Apply for CASP in Another EU Jurisdiction
If you want a CASP license and cannot wait for Poland, we handle CASP licensing across all EU member states. We know which jurisdictions are currently accepting applications and processing them efficiently — including Lithuania, the Netherlands, Slovakia, Malta, France, and Cyprus.
Once you hold a CASP authorization in any EU member state, you can passport your services into Poland and all other EU countries. This is one of MiCA’s core advantages: one license covers the entire European Union.
For multi-jurisdiction options and our VASP M&A services, see our Buy or Sell VASP License page.
Buying a Ready-Made Polish VASP: How It Works
What You Acquire
A Polish sp. z o.o. (limited liability company — the Polish equivalent of a UK Ltd) that was registered in the VASP register before 30 December 2024. The company has clean financial records, no liabilities, and all AML reports — the only regulatory requirement under Poland’s VASP regime — are fully up to date. The VASP registration belongs to the legal entity itself, not to its shareholders or directors. When you buy the company, the license transfers with it automatically. That is simply how separate legal personality works.
The Acquisition Process
The process is identical to acquiring any of our ready-made Polish companies:
- Share Purchase Agreement — We draft and execute the agreement for the transfer of shares.
- S24 Digital Registration — The transfer is processed through S24 (Polish Company Registry online system). New director and shareholder details are registered.
- KRS Update — The National Court Register publishes the updated ownership details, typically within 24–48 hours.
- You Are the New Owner — The transfer is legally effective from the moment of signing. The KRS update is declaratory — it confirms what has already happened.
If you visit Warsaw in person, the entire transfer — from signing to registration — takes a couple of hours. If you handle it remotely, we use the same courier-based Power of Attorney procedure as for our standard shelf companies. You do not need to visit Poland at all.
What We Handle After the Transfer
We do not just sell you a company and disappear. Our service covers everything you need to start operating:
- Bank account opening — at Polish banks (in person, as many banks as you want) or remotely via banks where we have introducer relationships, plus international payment institutions and EMI/FIAT gateways
- Virtual IBANs — we help you set up payment accounts with individual IBANs for each of your clients, which is essential infrastructure for any crypto business that processes client funds
- Post-acquisition compliance guidance — ensuring your VASP operations meet Polish regulatory requirements
- CASP transition planning — when CASP applications become available (in Poland or another EU jurisdiction), we handle the entire process
Your CASP Transition: We Stay With You
This is the part that sets us apart. Buying a VASP is not the end of your regulatory journey — it is the beginning. When the time comes to transition from VASP to CASP, we manage the entire licensing process. In Poland if the law passes. In another EU member state if it does not. You are not left to figure this out alone.
For those who want to get ahead of the process: we advise retaining us to begin preparing your CASP application documentation now, so that when the law is passed, we already have more or less what is needed for filing.
MiCA Grandfathering: The July 2026 Deadline
Article 143(3) of MiCA provides a grandfathering clause for existing crypto service providers. VASPs registered before 30 December 2024 may continue operating until 1 July 2026, or until their CASP application is decided — whichever comes first.
Poland’s Unique Position
Because Poland has not implemented MiCA, the situation here is different from other EU countries. The grandfathering period in Poland effectively extends for as long as the implementing legislation remains unresolved. Poland currently has the longest operational window for VASPs of any EU member state.
In most other EU countries, VASPs have already been required to either cease operations or file for CASP authorization. In Poland, existing VASPs continue to operate freely — no CASP application required, no wind-down pressure.
What Grandfathered Polish VASPs Can Do
Polish VASPs are recognized across the entire European Union during the transition period. That means a Polish VASP can serve clients not just in Poland, but in Germany, France, the Netherlands, Spain — all 27 member states. This includes countries that have already ended their own VASP regimes and no longer allow their domestic providers to operate.
The Strategy
Acquire a Polish VASP now. Operate across the EU during the transition period. When CASP applications open — in Poland or elsewhere — file for authorization with our support. Seamless continuity, no interruption to your business.
Frequently Asked Questions
Can I still register a new VASP in Poland?
No. The VASP register has been closed since 30 December 2024. No new registrations are accepted. However, we have ready-made Polish companies with existing VASP registrations available for sale. This is the only way to obtain a Polish VASP today.
Can I apply for a CASP license in Poland right now?
Not yet. The implementing legislation has been vetoed twice by the President of Poland, and no competent authority has been designated for CASP applications. However, it is advisable to begin preparing your application now — gathering documentation, setting up compliance frameworks, organizing governance structures — so you are ready to file as soon as the law is passed. We can also process CASP applications in other EU member states if you prefer not to wait.
How fast can I buy a ready-made VASP?
The acquisition process is identical to buying a shelf company in Poland. In person in Warsaw: a couple of hours. Remotely: a few days, depending on courier transit times. The bottleneck is never on our side.
Can a Polish VASP operate in other EU countries?
Yes. During the MiCA grandfathering period, Polish VASPs are recognized across all 27 EU member states. This includes countries that no longer allow their own VASPs to operate.
What happens after the July 2026 deadline?
You transition to a CASP license. We handle the entire application process for you — either in Poland (if the law has been passed by then) or in another EU member state (if it has not). Our service is end-to-end: we do not leave you after the VASP sale.
What if Poland never passes the MiCA implementation law?
Then we process your CASP application in another EU member state of your choice. Once authorized, you can passport your services back into Poland and across all of the EU. We know which jurisdictions are efficient and currently processing applications.
Do I need to be physically present in Poland to buy a VASP?
No. The entire process can be handled remotely using a Power of Attorney and courier service. We use the same remote procedure that we offer for all of our ready-made company sales. An in-person visit is faster but not required.
What crypto activities does a Polish VASP cover?
Four activity types: exchange between cryptocurrencies and fiat currencies, exchange between cryptocurrencies, brokerage in those exchanges, and maintenance of crypto wallets and payment accounts.
Can businesses from outside the EU buy a Polish VASP?
Yes. Non-EU individuals and companies can acquire Polish sp. z o.o. entities. However, some jurisdictions have additional licensing requirements that may affect your ability to operate crypto services in your home market. The United States, for example, has particularly strict rules. We advise clients on how the Polish VASP fits within their broader regulatory picture.
Do you help with bank accounts and payment infrastructure?
Absolutely. Bank account opening at Polish and international banks is part of our service, including EMI and FIAT gateway integrations. We also help you set up virtual IBANs — individual payment accounts for each of your crypto clients — which is essential infrastructure for any business that processes client funds.
Get in Touch
We currently have a limited number of ready-made Polish VASPs available for acquisition. The VASP register is permanently closed — once our remaining inventory is sold, these entities cannot be replaced. This is genuinely the last opportunity to acquire a working crypto license in the only EU country where VASPs still operate freely.
Contact us to discuss your requirements, timeline, and the best path forward for your business.
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- Email: info@zalewskiconsulting.pl
- Phone: +48 222 90 10 90
