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Licensing · Crypto · Poland

Serving the Polish crypto market under MiCA

Poland is the one large EU market without a working domestic route to MiCA authorisation. The national crypto-assets act was vetoed for the third time on 11 June 2026, leaving no competent authority with licensing powers, while the MiCA transition has fully expired. Polish clients can currently be served only by CASPs authorised in other Member States.

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Key facts
Intended regulator
Komisja Nadzoru Finansowego (Polish Financial Supervision Authority, KNF), under the draft act
Legal basis
Regulation (EU) 2023/1114 (MiCA), directly applicable; national implementing act not in force at our October 2026 review
Transitional period
6 months notified to ESMA; all MiCA transitional rights ended by 1 July 2026 at the latest
Domestic CASP authorisations
None available while no competent authority is designated
Current access route
Passported services by a CASP authorised in another EU/EEA state
Former regime
Register of virtual currency activity kept by the Director of the Tax Administration Chamber in Katowice
Minimum own funds (MiCA)
EUR 50,000 / 125,000 / 150,000 by CASP class, in the home state
01

Overview

Poland once had one of Europe's largest national registers of virtual asset service providers, maintained under its AML legislation. MiCA has applied directly since 30 December 2024, but a regulation of this kind still needs a national act to designate a competent authority, give it supervisory and sanctioning powers and organise the authorisation procedure. Poland's draft crypto-assets market act, which would have entrusted those roles to the KNF, was passed by parliament and vetoed by the President three times, most recently on 11 June 2026, and the Sejm did not override the veto.

Poland had notified ESMA of a six-month transitional period, and in February 2026 the KNF stated that unauthorised providers could operate only until 1 July 2026 in any event. As a result, a Polish-incorporated firm currently has no domestic body to which it can submit an Article 62 MiCA application, yet providing crypto-asset services without authorisation is a breach of EU law. The President's stated objections concerned the length of the bill, the level of sanctions and KNF powers to block accounts and websites rather than MiCA itself.

In practice the Polish market has not closed: it is being served by CASPs authorised in other Member States and passported into Poland. Polish founders have relocated their regulated entity to another jurisdiction, operated as agents or distributors of an authorised CASP, or restricted their activity to services outside MiCA's scope. Each route has legal, tax and substance consequences that need to be planned carefully.

A further legislative attempt is expected, and commentators anticipate that any new act could take effect no earlier than 2027. Firms that intend to hold a KNF authorisation eventually can use the interval to build a MiCA-grade governance and compliance framework, often first through an authorisation in another state. We review the position continuously and will update this page when a Polish competent authority is designated.

02

Key benefits

  • Access to one of the EU's largest retail crypto markets through passporting
  • A single authorisation elsewhere in the EU covers Polish clients without a second licence
  • Time to prepare a robust framework before a Polish licensing route opens
  • Flexibility to keep development, marketing or customer support teams in Poland
  • Clear compliance position for banks and partners while domestic law is unsettled
  • A future option to redomicile or add a Polish authorisation once the KNF regime exists
03

Requirements

  • Authorisation as a CASP in another EU or EEA Member State, with registered office and effective management there
  • Passporting notification to the home regulator listing Poland and the services to be offered
  • Compliance with MiCA conduct rules, including marketing communications and client information in Poland
  • Own funds of EUR 50,000, 125,000 or 150,000 by class in the home state
  • AML/CFT controls covering Polish clients and the EU travel rule
  • Careful structuring of any Polish entity so it does not itself provide MiCA services without authorisation
  • Clear allocation of responsibility where Polish agents or distributors act for an authorised CASP
  • Wind-down or migration plan for clients of any former Polish VASP
04

Licence options & capital

Authorise in another EU state and passport

MiCA capital from EUR 50,000

The most common route today. The CASP is authorised in, for example, Lithuania, Cyprus, the Czech Republic or Slovakia and notifies its regulator that it will serve Polish clients.

Polish operations of an EU CASP

Within the home-state licence

Technology, marketing or support functions may sit in Poland while regulated activity is carried out by the authorised entity, subject to outsourcing rules and the home regulator's view on substance.

Agent or distributor model

No separate CASP capital

A Polish business introduces clients to an authorised CASP that retains regulatory responsibility. The contract, branding and client journey must make the provider clear.

Prepare for a KNF authorisation

Timing depends on new legislation

For groups that want a Polish home state, we build governance, policies and capital planning now so an application can be filed quickly once a new act designates the KNF.

05

Step-by-step process

  1. 1

    Regulatory status review

    We analyse current Polish activities, client base and any former VASP registration to identify what is in MiCA scope and what must stop or move.

  2. 2

    Choice of home state

    Comparison of EU jurisdictions on supervisory approach, substance, language and timeline, aligned with founders' tax and residence position.

  3. 3

    Authorisation abroad

    Incorporation, substance and a full MiCA application in the chosen state, with a 25 plus 40 working day statutory review window.

  4. 4

    Passport into Poland

    Notification of cross-border services covering Poland, followed by Polish-language client documentation and marketing review.

  5. 5

    Restructure Polish entities

    Re-papering of Polish service companies as outsourcing providers, agents or development hubs, with intra-group agreements.

  6. 6

    Monitor and adapt

    Ongoing monitoring of Polish legislation, with a plan to add or move an authorisation once the KNF can license CASPs.

06

Typical documents

  • Corporate documents of the home-state CASP and the Polish entities
  • Programme of operations covering the Polish market
  • Passporting notification and list of services for Poland
  • Outsourcing, agency or distribution agreements with Polish entities
  • Polish-language client terms, crypto-asset white paper references and marketing materials
  • AML/CFT risk assessment covering Polish clients
  • Client migration and communication plan for former VASP customers
  • Fit-and-proper files for directors and qualifying shareholders
07

How Legal Wealth helps

Legal Wealth helps Polish founders and international groups navigate the gap between directly applicable EU law and a missing national regime. We assess current exposure, select a home state that fits the business and the founders' personal plans, coordinate the authorisation and passporting process, and restructure Polish entities so their role is clear and defensible. Client and shareholder information is handled discreetly throughout, and we keep a watch on Polish legislation so that clients can move quickly when a KNF route becomes available.

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08

Frequently asked questions

Can I obtain a MiCA licence from the KNF today?

Not as at our October 2026 review. Without a national implementing act, the KNF has not been designated with licensing powers, so there is no domestic authorisation procedure for CASPs.

Is my registration in the Polish virtual currency register still valid?

It does not authorise crypto-asset services under MiCA. All transitional rights ended by 1 July 2026, so continued activity requires authorisation in another Member State or a model outside MiCA's scope.

Can foreign CASPs serve Polish clients?

Yes. A CASP authorised in another EU or EEA state can provide services in Poland after notifying its home regulator under MiCA's passporting rules.

Why was the Polish crypto act vetoed?

The President's objections focused on the length of the bill, the level of sanctions and KNF powers to block accounts and websites. The third veto came on 11 June 2026 and was not overridden.

What did the vetoed act propose on fees?

The version adopted by parliament in May 2026 provided for a percentage-based KNF supervisory fee, capped at 0.4% for CASPs. Any future act may differ, so this should be treated as indicative only.

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