COREDO > Crypto Licence in Poland

Crypto Licence in Poland

A crypto licence in Poland represents an authorisation as a Crypto-Asset Service Provider (CASP) in accordance with the EU Markets in Crypto-Assets Regulation (MiCA). Poland is the largest financial market in Central and Eastern Europe, a member of the European Union, and provides licensed companies with access to the single EU market through the passporting mechanism.

COREDO has been providing a full range of services for obtaining a CASP licence in Poland since 2016: from company registration and preparation of comprehensive documentation to filing the application with KNF and support at all stages of interaction with the regulator.

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Cost of the service
from 56 400 EUR

Regulatory Framework: MiCA and DORA

Activities related to crypto-assets in Poland are regulated at the European Union level. The regulatory framework is based on two key regulations.

The MiCA Regulation (Regulation (EU) 2023/1114) establishes uniform requirements across the entire EU for licensing, consumer protection, risk management, and supervision of crypto-asset operations. MiCA came into full force on 30 December 2024 and has direct effect in all EU member states, including Poland. All previously registered virtual asset service providers (VASPs) are required to undergo the authorisation procedure and obtain CASP status.

The DORA Regulation (Regulation (EU) 2022/2554) — the Digital Operational Resilience Act — is aimed at ensuring the cybersecurity of financial institutions, including cryptocurrency companies. DORA has been applicable since 17 January 2025 and obliges CASPs to implement ICT risk management systems, ensure business continuity, conduct regular resilience testing, and report cyber incidents. Penalties for non-compliance with DORA can reach up to 1% of the company’s annual global turnover.

National implementation of MiCA in Poland is currently undergoing the legislative process. The Act on the Crypto-Asset Market (Ustawa o rynku kryptoaktywów) was adopted by the Sejm on 26 September 2025; however, on 1 December 2025 the President of Poland vetoed the bill. A renewed attempt to adopt the act in January 2026 was also rejected by a presidential veto on 12 February 2026. Nevertheless, as an EU regulation, MiCA has direct effect and applies in Poland regardless of the adoption of a national implementing act.

Transitional Period and Current Situation

In accordance with Article 143 of MiCA, a transitional period has been established, allowing providers that offered cryptocurrency services before 30 December 2024 to continue their activities until 1 July 2026. This date is a firm deadline set at the EU level and cannot be extended by a decision of the national regulator.

Due to the absence of an implementing act, KNF is currently unable to accept applications for CASP authorisation from Polish companies. Existing VASPs registered in the virtual currency register before 30 December 2024 are entitled to continue their activities until 30 June 2026; however, new VASP registrations are no longer accepted.

For companies planning to enter the market, COREDO recommends starting the preparation of documentation and internal procedures well in advance, so as to submit an application to KNF immediately after the adoption of the implementing act. An alternative strategy is to obtain a CASP licence in another EU jurisdiction (for example, in the Czech Republic, Estonia, or Lithuania) and use the passporting mechanism to provide services in Poland.

Types of CASP Licences in Poland

Under MiCA, CASP licences are divided into three classes depending on the scope of services provided.

Class 1

covers the following activities: execution of orders for the purchase and sale of crypto-assets on behalf of clients, placing crypto-assets on the market, reception and transmission of client orders, advisory services on crypto-assets, portfolio management of crypto-assets, and transfer services for crypto-assets between addresses or wallets.

Class 2

includes all Class 1 services, as well as custody and administration of crypto-assets on behalf of clients (custodial services) and exchange of crypto-assets for fiat currency or other crypto-assets.

Class 3

combines all Class 2 services, as well as operation of a trading platform for crypto-assets.

In addition to CASP, the MiCA regulation provides for separate licensing regimes for issuers of Asset-Referenced Tokens (ART) and issuers of E-Money Tokens (EMT).

Advantages of Obtaining a CASP Licence in Poland

Poland offers a number of significant advantages for companies planning to obtain a CASP licence.

EU passporting:

a CASP licence obtained in Poland grants the right to provide cryptocurrency services in all 27 European Union countries through a notification procedure (passporting) in accordance with Article 65 of MiCA, without the need to obtain separate licences in each country. This opens access to a market with a population of over 450 million people.

Largest market in CEE:

Poland is the largest financial market in Central and Eastern Europe, with a population of approximately 38 million people. High technological literacy among the population and a growing cryptocurrency audience (more than 2.5 million users) create a favourable environment for developing a cryptocurrency business.

Competitive tax environment:

the standard corporate income tax rate in Poland is 19%. For new and small companies with annual revenue of up to EUR 2 million, a reduced rate of 9% is available, which significantly lowers the tax burden during the initial stages of operations.

Developed fintech ecosystem:

Poland has an extensive pool of qualified IT specialists and developers. Polish programmers consistently rank among the strongest in global rankings. A significant number of legal, consulting, and technology companies specialising in crypto-assets are present in the market.

Low operating costs:

the cost of office rent, specialist salaries, and administrative expenses in Poland are significantly lower than in Western European countries, allowing for the optimisation of costs associated with establishing and operating a cryptocurrency business.

No additional national requirements:

the Polish regulator does not impose requirements exceeding MiCA standards (no gold-plating), which simplifies the licensing process and subsequent passporting to other EU countries.

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Cost of COREDO Services

COREDO offers a full package of services for obtaining a CASP licence in Poland starting from EUR 56,400 + VAT. The package includes four stages of work.

Stage 1. Company Registration and Comprehensive Due Diligence

EUR 6,000 + VAT

Consulting on the choice of legal form and company structure.
Preparation of incorporation documents, registration with the National Court Register (Krajowy Rejestr Sądowy, KRS).
Obtaining NIP, REGON and VAT numbers (if required).
Opening a bank account.
Conducting comprehensive due diligence on the company, board members, and beneficial owners.

Stage 2. Preparation of the Company for MiCA Licensing

EUR 24,000 + VAT

Analysis of MiCA requirements as applied to the company’s activities.
Development of internal policies (AML/KYC, risk management, cybersecurity).
Internal audit and compliance procedure review.
Consulting on the implementation of procedures and recruitment.
Preparation of the documentation package for submission to KNF.

Stage 3. Application Submission and Support

EUR 18,000 + VAT

Filing the application with the Polish Financial Supervision Authority (KNF).
Representing the client’s interests and communicating with the regulator.
Support in meeting additional KNF requirements.

Stage 4. Final Stage

EUR 8,400 + VAT

Payable within five business days of receiving the KNF decision.

The final cost may vary depending on the results of the initial project assessment, the number of CASP service classes, and the degree of involvement of COREDO specialists in document preparation.

Payment Terms

Payment for COREDO services for obtaining a CASP licence in Poland is distributed across four instalments linked to the completion of each stage of work.

The first instalment — EUR 6,000 — is payable within five business days from the date of contract signing and covers the services of the first stage (company registration and comprehensive due diligence).

The second instalment — EUR 24,000 — is payable within five business days after the completion of the first stage and covers the services of the second stage (preparation for licensing).

The third instalment — EUR 18,000 — is payable within five business days after the completion of the second stage and covers the services of the third stage (application submission and support).

The fourth instalment — EUR 8,400 — is payable within five business days from the date of receiving the KNF decision.

Requirements for Obtaining a CASP Licence in Poland

To obtain CASP authorisation in accordance with MiCA, a company must meet a number of organisational, financial, and technical requirements.

Minimum capital:

the amount of own funds depends on the CASP class. For Class 1, the minimum share capital is EUR 50,000; for Class 2 — EUR 125,000; for Class 3 — EUR 150,000. Additionally, own funds must be no less than one quarter of the fixed overhead costs for the previous year, subject to annual review.

Organisational structure:

the company must have a registered office and place of effective management in Poland. Board members must possess sufficient qualifications, experience, and an impeccable reputation. A clearly defined organisational structure with delineation of responsibilities is required.

AML/KYC compliance:

the appointment of an anti-money laundering officer (AML Officer) is mandatory. KNF practice indicates that the AML Officer must be employed in Poland and be fluent in Polish. The company is required to implement client identification procedures (KYC), transaction monitoring, and suspicious activity reporting.

Technical security:

implementation of robust cybersecurity measures to protect client data and crypto-assets, including backup, access control, and protection against cyber threats in accordance with DORA requirements.

Consumer protection:

ensuring full transparency — disclosure of risks associated with services, fee structures, and terms of service.

List of Documents for the Application

The following set of documents is required to submit an application for CASP authorisation in Poland.

Incorporation documents: articles of association, registration details, ownership structure, criminal record certificates for management and owners.

Business plan: description of activities, list of services, target markets, operational processes, partners, and resources for a three-year period.

Financial documentation: confirmation of available capital and liquidity, readiness to fulfil prudential requirements and maintain financial statements.

Policies and procedures: AML/KYC documentation, internal control procedures, risk management processes, and complaint handling procedures.

IT security and data protection: description of technical infrastructure, cybersecurity measures and client data protection, business continuity plan (in accordance with DORA).

Personnel information: CVs of key employees with confirmation of professional experience, qualifications, and role within the company.

Client documentation: contract templates, terms of service, risk disclosures, and fee schedules.

Training programme: employee training plan in the field of AML/CFT and company internal procedures.

Procedure for Obtaining a CASP Licence in Poland

The procedure for obtaining a CASP licence in Poland comprises four main stages.

Company Registration and Comprehensive Due Diligence.

COREDO assists with the choice of legal form, preparation of incorporation documents, company registration with KRS, obtaining necessary identification numbers (NIP, REGON, VAT), opening a corporate bank account, and conducting comprehensive due diligence on management and beneficial owners. Estimated timeline: 2–4 weeks.

01

Preparation of the Company for Licensing.

Analysis of applicable MiCA requirements, development of a full package of internal policies and procedures (AML/KYC, risk management, cybersecurity, consumer protection), conducting an internal audit, preparing a business plan and all necessary documentation for submission to KNF. Estimated timeline: 1–2 months.

02

Application Submission and Support.

Compilation and submission of the complete set of documents to KNF. Within 5 business days, KNF confirms receipt of the application; within 25 business days, a formal completeness review of the documents is conducted; then within 40 business days, a qualitative assessment is carried out. COREDO represents the client’s interests, ensures communication with the regulator, and provides support in meeting additional requests. Estimated timeline: 4–6 months.

03

Obtaining the Licence.

Following a positive decision by KNF, the company is entered into the register of authorised CASPs and receives the right to conduct cryptocurrency activities in Poland and, through passporting, in all EU countries.

04

The overall estimated timeline for obtaining a CASP licence in Poland is 6 to 10 months from the commencement of work.

Our Experts

COREDO specialists possess deep expertise in the field of cryptocurrency licensing in the European Union. Our team supports projects from the initial consultation through to obtaining the licence and subsequent regulatory compliance.

Pavel Kos

Head of Legal at COREDO. Has been with the company since 2017 and oversees all projects in the field of licensing financial and cryptocurrency companies. Specialises in strategic planning, team management, and interaction with regulators across various EU jurisdictions.

Basang Ungunov

Lawyer at COREDO. A specialist in civil and financial law, provides legal expertise for CASP licensing projects, preparation of legal opinions, and client support at all stages of interaction with the regulator.

Frequently Asked Questions

Which regulator issues the CASP licence in Poland?

CASP authorisation in Poland is carried out by the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF). KNF is the competent authority responsible for supervising the activities of cryptocurrency service providers in accordance with the MiCA regulation.

What is the minimum capital required for a CASP licence?

The minimum capital depends on the CASP class: EUR 50,000 for Class 1 (advisory, order reception, transfers), EUR 125,000 for Class 2 (custodial services, exchange), EUR 150,000 for Class 3 (trading platform operation). These requirements are established by Article 67 of MiCA and Annex IV to the regulation.

Can a Polish CASP licence be used to operate in other EU countries?

Yes. A CASP licence obtained in Poland grants the right to provide cryptocurrency services in all 27 EU member states through the passporting mechanism (Article 65 of MiCA). To do so, it is sufficient to notify KNF, which then forwards the information to the regulator of the host country.

How long does it take to obtain a CASP licence in Poland?

The estimated timeline is 6 to 10 months: 2–4 weeks for company registration, 1–2 months for documentation preparation, and 4–6 months for KNF review. Timelines depend on the completeness of the submitted documents and the complexity of the project.

Is it mandatory to appoint an AML Officer in Poland?

Yes. All CASPs are required to appoint a person responsible for anti-money laundering (AML Officer). KNF practice indicates that the AML Officer must be employed in Poland and be fluent in Polish to ensure effective communication with the regulator.

How does the current MiCA implementation situation affect licensing?

The Act on the Crypto-Asset Market in Poland was twice rejected by a presidential veto (December 2025 and February 2026). Nevertheless, MiCA has direct effect as an EU regulation. COREDO recommends starting the preparation of documentation well in advance so as to submit the application immediately after the adoption of the implementing act, or to consider obtaining a licence in another EU jurisdiction with subsequent passporting to Poland.

What is the cost of obtaining a CASP licence in Poland through COREDO?

The cost of the full COREDO service package starts from EUR 56,400 + VAT. The package includes company registration (EUR 6,000), preparation for licensing (EUR 24,000), application submission and support (EUR 18,000), and the final stage (EUR 8,400). The final cost may vary depending on the specifics of the project.

What are the technical requirements?

In accordance with MiCA and DORA, the company is required to implement robust cybersecurity measures: protection of client data and crypto-assets, backup, access control, incident response system, and a business continuity plan. DORA requires quarterly vulnerability assessments and annual penetration testing.

Get a Consultation on CASP Licensing in Poland

COREDO has been supporting cryptocurrency licensing projects in Poland and other EU jurisdictions since 2016. Our specialists will conduct a preliminary assessment of your project, prepare a complete set of documents, and ensure interaction with KNF at all stages of the procedure.