Crypto License in Poland how MiCA Changed the Rules of the Game

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The implementation of MiCA regulation in Poland has become not just another stage of tightening control, but a real paradigm shift for the market. Previously, the registration of crypto business in Europe, and in particular in Poland, was based on national standards, where the role of the KNF (Financial Supervision Commission) was key, but the framework was relatively flexible. Now, the EU CASP license has become a universal “pass” for cross-border crypto services, and the AML/KYC and compliance requirements are unified for the entire European market.

Thus, the transition to regulation according to MiCA standards inevitably entails a revision of approaches to licensing crypto business in Poland, which is detailed in the new requirements for market participants.

Licensing of Crypto Business in Poland: Changes

Before the implementation of MiCA, the process of obtaining a crypto license in Poland was relatively quick, with minimal capital requirements, a standard procedure for checking beneficiaries, and basic internal control. Intra-group compliance procedures were often limited to formal policies, and integration with the EU anti-money laundering directive remained at the company’s discretion.

With the implementation of MiCA, the situation changes significantly:

  • The capital requirements for CASP start at €50,000, and only own funds are considered.
  • The implementation of the MiCA transition period Poland implies mandatory integration of new standards into national law, requiring a review of all documentation and business processes.
  • Compliance becomes an integral part of operational activity: internal audit, enhanced KYC, regular reporting on suspicious transactions, and mandatory sanctions list checks.

COREDO’s experience shows: companies that started restructuring their AML/KYC procedures in advance and integrated risk assessment of crypto assets went through Licensing faster and with fewer costs.

EU CASP License for Business

MiCA opens fundamentally new horizons for Polish crypto companies. The EU CASP license provides European passporting: after approval by the KNF, you gain the right to provide services throughout the EU without needing to obtain separate licenses in each country. This radically simplifies scaling strategies for crypto businesses in the EU and significantly increases the investment appeal of crypto companies.
The COREDO team has implemented several projects on cross-border licensing: for example, for a client in the custodial services sector, we built a model in which the Polish license became the foundation for entering the markets of the Czech Republic, Slovakia, and Cyprus with minimal additional costs and without creating separate structures in each jurisdiction.

MiCA Requirements for Crypto Companies in Poland

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MiCA sets standards that affect all key aspects of crypto companies’ activities: from AML/KYC to IT infrastructure and internal control requirements. The KNF Poland financial supervision now operates in close cooperation with European regulators, and bank accounts for crypto businesses in Poland are opened only with full compliance with the new standards.

As a result, crypto companies in Poland require constant procedure updates, making the implementation of new AML/KYC standards a key step towards full compliance with MiCA.

AML/KYC: New Standards and Practice

The impact of MiCA on AML procedures cannot be overestimated: now crypto companies are required to implement not only standard KYC procedures but also advanced transaction control mechanisms, automatic reporting on suspicious operations, and regular compliance checks against sanctions lists.

COREDO’s practice confirms: automating the assessment of crypto asset risks and implementing comprehensive AML/KYC policies can significantly reduce the likelihood of refusal during licensing and minimize the risks of fines.

MiCA Financial and Technical Requirements

One of the key challenges remains opening a bank account for a crypto company in Poland. Banks require transparency, confirmation of funds’ sources, insurance presence, and a clear strategy for financial sustainability. The introduction of DORA and the AI Act strengthens cybersecurity requirements for crypto companies: data protection, digital resilience, regular IT system audits are mandatory.
The solution developed by COREDO for one of its clients included integrating specialized IT solutions for transaction monitoring and automatic reporting generation for KNF, which not only accelerated the account opening process but also increased banks’ trust.

Personnel and Internal Audit: Management Structure

MiCA requires that key managers and beneficiaries undergo fit and proper checks, verifying compliance with professional and reputational standards. Internal auditing in crypto companies becomes a mandatory element: regular process checks, reputation risk management, and implementation of internal control policies.

COREDO’s experience showed: companies that invested in staff training and the development of internal control systems were not only faster at getting licensed but also reduced the likelihood of future regulatory claims.

Crypto License in Poland: New Rules

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Obtaining a crypto license in Poland is now a multi-step process requiring thorough preparation and strategic planning. The KNF Poland financial supervision controls each stage, and the application submission and review timelines are strictly regulated.

Application Submission Stages

The MiCA transition period in Poland provides a “window” for submitting applications: companies already operating in the market must submit a complete package of documents within 18 months of MiCA’s entry into force. New players must go through preliminary notification and get KNF approval before starting operations.

In practice, COREDO recommends preparing documents in advance: preliminary expert assessment, business process audit, and compliance due diligence significantly reduce application review time.

Documents for Application Submission

The standard package of documents includes:

  • Business plan with financial forecasts and AML/KYC strategy.
  • Confirmation of capital sources (only own funds, minimum €50,000 for CASP).
  • Internal control policies, criminal record certificates, confirmation of key employees’ qualifications.
  • Description of IT infrastructure, cybersecurity, and data protection measures.
In one of COREDO’s cases for a client in the NFT marketplace sphere, a unique set of documents was developed taking into account the specifics of working with digital assets, which allowed them to go through licensing on the first try.

Challenges for Crypto Companies in Poland Post-MiCA

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Cryptocurrency regulation in the EU is becoming increasingly complex, and the liability for non-compliance with MiCA is at an all-time high. Key challenges include adapting AML procedures, managing tax and reputational risks, and ensuring transparency and resilience of the business model.

Typical Mistakes and How to Avoid Them

The most frequent mistakes encountered by COREDO’s team:

  • Underestimation of compliance requirements: a formal approach to AML/KYC leads to refusals and fines.
  • Lack of internal audit and regular checks.
  • Incomplete document package or personnel qualification mismatch.

Recommendation: conduct regular internal audits, implement due diligence at all stages, and use automated transaction control systems.

Risks for Management and Their Responsibility

MiCA increases the responsibility of managers: non-compliance with standards threatens not only fines but also license revocation, inclusion on sanction lists, and account blocking. Managing reputational risks and building an internal control system become critically important.
In one of COREDO’s cases for a large custody service, an internal control system with multi-level reporting was implemented, minimizing regulatory risks and increasing partners’ trust.

Licensing and Scaling Crypto Business in the EU

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The legalization of crypto activities and the strategies for scaling crypto business in the EU require a comprehensive approach: from document preparation to building relationships with banks and implementing best practices of MiCA.

Preparation for CASP License in the EU

Effective preparation includes:

  • Development and implementation of compliance documentation in line with EU standards.
  • Training personnel on new requirements and ongoing professional development.
  • Implementing IT solutions to automate transaction monitoring and reporting.
COREDO’s practice showed that integrating specialized compliance platforms not only accelerates the licensing process but also reduces operational costs.

How to Increase Transparency and Customer Trust

Financial transparency and internal auditing of crypto companies are key to gaining trust from clients and partners. Implementation of transaction control mechanisms, regular reporting, and reputation management are mandatory elements of a modern business model.

In one of COREDO’s projects for a DAO, a transparent reporting system was implemented, attracting institutional investors and increasing the company’s investment attractiveness.

AI and Cybersecurity for MiCA

Implementing the AI Act and DORA requires integrating cybersecurity solutions: data protection, digital resilience, regular IT system testing.

For a COREDO client in the gamification field, a project was implemented to integrate AI modules for assessing transactional risks, allowing adherence to new MiCA standards and improving resilience to cyber threats.

Key Advice for Entrepreneurs

Criterion Before MiCA (national law) After MiCA (EU unified standards)
Regulatory Authority KNF (Poland) KNF (considering MiCA, EU passporting)
Capital Requirements Flexible €50,000+ for CASP, only own funds
AML/KYC National standards EU unified standards, enhanced control
Passporting No Yes, throughout the EU
Liability Limited Enhanced, including fines and license revocation
Compliance Minimal Mandatory internal audit, DORA, AI Act, etc.

Checklist for Preparing for Licensing:

  • Conduct an audit of current AML/KYC procedures.
  • Prepare and approve a business plan considering MiCA.
  • Ensure IT infrastructure compliance with DORA and AI Act requirements.
  • Verify the qualification and reputation of key employees.
  • Implement internal audit and regular reporting.
  • Prepare a document package for submission to KNF.

Actionable advice:

  • Choose jurisdiction considering strategic goals and European passporting possibilities.
  • Optimize business processes for new MiCA standards.
  • Invest in staff training and compliance automation.
  • Use COREDO’s experience to minimize risks and speed up the licensing process.

To gain maximum benefits from the implementation of new MiCA rules, familiarize yourself in advance with typical questions and features of obtaining a crypto license in Poland.

MiCA and Crypto License in Poland, FAQ

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How to get a crypto license in Poland after MiCA’s implementation?

A full document package is required, undergo due diligence, implement AML/KYC standards, and submit an application to KNF. MiCA’s transition period allows existing companies to adapt within 18 months.

What requirements does MiCA impose on crypto companies in 2025?

Unified AML/KYC standards, minimum capital of €50,000, internal audits, compliance with DORA and AI Act, and a transparent management structure.

How does MiCA affect AML/KYC processes for crypto business in Poland?

Stricter requirements for customer identification, transaction monitoring, reporting on suspicious transactions, and sanctions list checks.

How to prepare a company for CASP licensing in the EU?

Conduct process audits, implement new AML/KYC policies, automate transaction control, train staff, and prepare a document package for KNF.

How to open a bank account for a crypto company in Poland?

Full compliance with new MiCA standards, capital structure transparency, confirmation of funds’ sources, and cybersecurity measures are required.

MiCA and Entering the European Market for Crypto Business

MiCA regulation transforms not only the legal and compliance environment but also the very strategy of entering the European market for crypto companies. Registering a crypto business in Europe now requires not just adherence to formal procedures, but building a sustainable, transparent, and scalable business model. Legalization of crypto activities becomes the foundation for attracting investments, increasing competitiveness, and long-term development.

COREDO’s practice shows: companies that adapt to new standards in time, invest in compliance and internal control, not only successfully go through licensing but also become market leaders. If your goal is not just to survive in the MiCA era but to use new opportunities for growth, a strategic approach and the support of COREDO experts will help achieve this task most effectively.

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