Crypto license in
Poland 2024
Poland has become a strategic jurisdiction for crypto businesses adapting to the new regulatory landscape under MiCA. With the implementation of the Crypto-Asset Service Provider (CASP) license, Poland offers a structured yet efficient pathway for compliance with EU-wide regulatory standards. While the registration process now requires stricter adherence to financial and operational requirements, Poland remains an attractive destination due to its clear regulatory framework and competitive tax environment.
Legalaes provides end-to-end support for obtaining a CASP license in Poland, ensuring full compliance with MiCA regulations. Our services cover company incorporation, document preparation, policies development, AML compliance, and representation before the Polish Financial Supervision Authority (KNF). Whether you require a tailored licensing solution or a ready-made entity with an active CASP license, we facilitate a seamless process, guiding you through each regulatory step efficiently.
Regulations for Crypto license in Poland
To obtain a Crypto-Asset Service Provider (CASP) license in Poland under the Markets in Crypto-Assets Regulation (MiCA), a local company must be established to provide cryptocurrency services. The minimum share capital required for company registration is 5,000 PLN. Prior to submitting a CASP license application to the National Bank of Poland (NBP), the company must ensure compliance with capital requirements, which vary depending on the specific services offered under the license.
The company must secure a PESEL number and digital signature to complete regulatory and administrative processes. Additionally, the appointment of key personnel is required — including a company director and an Anti-Money Laundering (AML) officer. These individuals must be residents of the European Economic Area (EEA). While final confirmation from the Polish regulator is pending, current expectations align with MiCA standards, requiring EU/EEA residency for managerial roles.
If the company is acquired as a ready-made VASP (Virtual Asset Service Provider), it remains possible under the current framework to appoint non-resident individuals as director and AML officer, although this is likely to change with the MiCA transition.
All crypto companies operating in Poland are subject to enhanced regulatory compliance, particularly with Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations. These measures ensure alignment with both national law and EU-wide MiCA regulations, strengthening corporate transparency and customer protection. Polish authorities reserve the right to access and monitor business and financial data in line with supervisory responsibilities.
The National Bank of Poland (NBP) will serve as the competent authority overseeing CASP license issuance and regulatory compliance. Companies must satisfy governance, capital, and operational criteria to obtain and retain their CASP license.
Entities already holding a VASP license in Poland benefit from a transitional period to migrate to the MiCA framework. Entities already holding a VASP license in Poland are expected to transition to the new MiCA framework; however, no official deadline has been established. According to the current legislative process, once the new Polish crypto regulation enters into force, existing VASPs will have a four-month window to apply for a CASP license in compliance with MiCA. As of now, the legislative draft has not yet been submitted to the Polish Parliament — it remains at the governmental (executive) level and is expected to reach Parliament in June or July 2025, in line with constitutional procedures.
Taxation of cryptocurrency companies in Poland
- Corporate tax: 9% for revenue up to 2 million EUR.
- Tax on dividends: 19%.
- Foreigner company register in Poland is suggested to register with 2 shareholder, this way You will be excluded from insurance tax, otherwise 1 shareholder will pay additional insurance tax monthly.
Types of crypto licensing in Poland
Before MiCA, cryptocurrency businesses in Poland operated under the Virtual Asset Service Provider (VASP) registration, which allowed companies to offer key crypto-related services, including cryptocurrency exchange (crypto-to-fiat, fiat-to-crypto, and crypto-to-crypto), custody of virtual assets, and facilitating transactions between wallets.
Legalaes offers ready-made VASP-registered companies, enabling businesses to enter the market quickly while ensuring compliance with MiCA’s new CASP licensing framework.
Under MiCA, all cryptocurrency businesses in Poland must obtain a CASP license, classified into three tiers based on service scope:
| License type | Description of license |
|---|---|
| Class 1 |
|
| Class 2 |
|
| Class 3 |
|
Legalaes assists businesses in acquiring existing licensed entities and transitioning to MiCA-compliant CASP licenses, ensuring a seamless regulatory approval process in Poland.
Overview of requirements to obtain crypto license in Poland
- Provide desired company names for registration
- Submit copies of passport and proof of address for future shareholders and directors
- Provide a non-criminal record for shareholders and directors
- Appoint a director and AML officer (nationality requirements to be confirmed by Polish authorities soon)
- Company must have AML/KYC policies in place
- Registered share capital of 5,000 PLN (at company registration)
- Obtain a PESEL number and digital signature
- Fulfillment of the structured application
Additional requirements:
- Develop internal policies in accordance with Regulation (EU) 2023/1114 (AML, risk management, cybersecurity, etc.)
- Submit a business plan outlining operations and financial projections
- Conduct a preliminary meeting with the National Bank of Poland (advisable)
- Perform a Fit and Proper check for key management members
- Obligation to store client data and report suspicious transactions (red flags)
- Additional capital must be deposited before the CASP license application, based on the regulatory class of the license
- Corporate bank account recommended, but not required for initial registration
Estimated Timeline for Obtaining a CASP License in Poland:
- Business name verification – 1-3 days
- Company formation – up to 2 weeks
- PESEL obtainment – 3 days
- Documents review and analysis – 1-3 weeks
- Development of required policies and compliance documents – 3-4 weeks (if applicable)
- Increase of required share capital – 2 weeks (if applicable)
- Filling out the structured application and submission to the National Bank of Poland (NBP) – 1 week
- Ongoing communication and license approval process – 3-5 months
Estimated time frames to obtain crypto license in Poland
Gathering documents and information from clients side
1-3 days
Company formation
1-2 weeks
Crypto license application and process
2 weeks
Legal services for obtaining Crypto license in Poland
Basic Package
Designed for startups and businesses seeking to establish a company and begin the CASP licensing process in Poland.
- Company registration and incorporation
- Provision of a registered office address for one year
- Standard AML/KYC policy documentation
- Preparation and submission of the CASP license application to the National Bank of Poland (NBP)
- Drafting and preparation of corporate documents
- Representation before regulatory authorities and handling official communications
- Legal guidance throughout the licensing procedure
- Assistance with required documentation
- Due diligence review
This package ensures a structured and efficient approach to obtaining a CASP license in Poland, covering all key regulatory and legal requirements.
Comprehensive Package
Designed for businesses that require full-scale compliance documentation, legal structuring, and regulatory preparation for obtaining a CASP license under MiCA in Poland.
Includes all services from the Basic Package, plus:
- Development of essential internal policies (AML/KYC, Risk Management, Cybersecurity, Client Safeguarding, and more) in accordance with MiCA regulations
- Business plan preparation tailored to the company’s operations and licensing requirements
- Regulatory strategy consultation and advisory on MiCA compliance
- Fit and Proper assessment preparation for key personnel
- Structured application preparation ensuring full compliance with NBP requirements
- Legal opinion from a certified lawyer for regulatory and operational compliance
- Preliminary meeting with the National Bank of Poland (NBP) – preparation and presence for regulatory discussions on your behalf
- Assistance in increasing share capital before the CASP license application to meet MiCA requirements
- Provision of local staff
Optional add-ons:
- Accounting services and tax compliance
- Corporate bank account assistance (current and safeguard accounts)
- Apostilled corporate documents
- Legal opinion for regulatory compliance
- Custom legal framework for launching crypto projects
- AML/CFT training and governance structuring
This package ensures a comprehensive and fully compliant approach to securing a CASP license in Poland, addressing all key regulatory, financial, and operational requirements.
Ready-Made CASP Solution
A fast-track solution for businesses seeking an operational company with an existing crypto license, ensuring rapid market entry.
- Pre-registered company with an active license
- Legal address for one year
- No debts or liabilities – clean company
- Registered share capital of 5,000 PLN (additional capital must be deposited before the CASP license application)
- Corporate documents transfer and regulatory compliance review
- Assistance with ownership transfer and regulatory filings
- PESEL number obtainment for company operations
This solution allows businesses to quickly enter the Polish market while ensuring full compliance with the transition to MiCA regulations.
Eriks Fijalovs
Head of Crypto
Requirements for Crypto licensing in Poland
Requirements for CASP Licensing in Poland
To obtain a Crypto-Asset Service Provider (CASP) license in Poland under the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114), companies must meet defined legal, regulatory, and operational requirements.
List of Required Documents:
- Power of Attorney (PoA): Notarized public document authorizing Legalaes to act on behalf of the company or individual to facilitate company formation and CASP license application in Poland.
- AML/KYC/CFT Policy: Internal compliance framework outlining procedures for Anti-Money Laundering (AML), Know Your Customer (KYC), and Countering the Financing of Terrorism (CFT).
- Application Form: Structured document for the National Bank of Poland (NBP) detailing the company’s business model, services, and operations.
- Memorandum and Articles of Association (MAA): Legal documents prepared during incorporation, defining governance and company structure.
- Business Plan: Detailed plan describing business operations, revenue streams, risk management, and overall strategy for the CASP license.
- Internal Policies and Procedures: Comprehensive compliance documents aligned with MiCA, including AML/KYC, risk, cybersecurity, and governance frameworks.
- Key Personnel Documentation: Includes Fit and Proper assessments, resumes, and evidence of regulatory qualifications for key management roles.
Share Capital and Government Fees in Poland
- Minimum Share Capital:
- Required capital for a limited liability company (LLC) in Poland is 5,000 PLN.
- Under MiCA, additional capital is required before applying for the CASP license, depending on the license class (starting from 50,000 EUR for Class 1 CASPs).
- Government Fees:
- Traditional Registration: ~600 PLN
- Online Registration (S24 System): ~350 PLN
- JSC Incorporation (if applicable): Additional fees apply
- Estimated Total: ~600 PLN for LLC
Personnel Requirements
- AML Officer:
- Appointment of an AML officer is mandatory. While final clarification from Polish authorities is pending, the officer is currently expected to be from the EU/EEA.
- For smoother communication with regulators, appointing a Poland-based AML officer is recommended.
- Legalaes can assist with local AML officer placement upon request.
- Director:
- The company must appoint a director from the EU/EEA. While current rules permit this, future updates may introduce a requirement for a Polish resident director.
- Additional Staff:
- Depending on your business model, additional roles such as risk officers or operational personnel may be required.
- Legalaes provides staffing solutions to help meet these regulatory standards.
- Business Premises Requirements in Poland
- A physical office is not currently required for CASP licensing.
- A registered legal address is sufficient for company formation and official communication.
- Some payment providers and banks may request a virtual office lease.
- Legalaes can assist in arranging this if needed.
Roadmap for Obtaining a CASP License in Poland
The CASP licensing process in Poland is governed by the Markets in Crypto-Assets Regulation (MiCA) and relevant AML/CFT laws. Foreign and domestic companies may apply for a CASP license under equal conditions, subject to compliance with Polish corporate and regulatory standards. Oversight is provided by the National Bank of Poland (NBP).
Eriks Fijalovs
Head of Crypto
Document Collection & Company Formation
The process begins with the preparation of required documents, including identification, proof of address, and a clear business model description. Clients propose up to three company names, which are verified and reserved with the National Court Register (KRS). We prepare a notarized Power of Attorney (PoA) for remote setup, incorporate a Polish limited liability company (Sp. z o.o.), and assist legal representatives in obtaining a PESEL number and qualified digital signature.
Business Plan & Preliminary Regulatory Consultation
We support the development of a detailed business plan aligned with MiCA requirements, covering revenue models, compliance strategies, and governance. Based on your business model, we provide regulatory insights and advise on required improvements. A preliminary consultation with the National Bank of Poland (NBP) is optional but highly recommended to review the proposed service scope, AML/CFT measures, governance, and capital adequacy.
Financial Infrastructure & Banking Support (Optional)
To ensure readiness, we assist in selecting a crypto-friendly financial partner — including EMIs or banks — based on your business model. Our team prepares corporate documentation, manages onboarding, and supports setup of operational and safeguard accounts in line with MiCA fund segregation standards.
CASP Application & Compliance Documentation
Before license submission, the company’s share capital is increased according to MiCA thresholds. Internal AML/KYC/CFT policies are drafted, and a director from the EU/EEA is appointed, subject to final local requirements. Our legal team prepares and submits the CASP application to the NBP, ensuring full regulatory alignment and managing communication throughout the review process.
License Approval & Ongoing Compliance
Upon approval, we assist with the implementation of MiCA-compliant operating procedures, support ongoing interaction with the regulator, and help adapt governance as your business scales. We remain available for audits, compliance updates, and regulatory reporting, ensuring your long-term alignment with Polish and EU standards.
Advantages of CASP License in Poland
01
Fully Remote Setup
Company formation and CASP license application can be completed entirely online via Power of Attorney (PoA), allowing international founders to incorporate and apply without traveling to Poland.
02
Clear and Predictable Licensing Pathway
Poland offers a transparent and structured licensing process under MiCA. With defined regulatory steps and proactive guidance, companies can obtain a CASP license efficiently and enter the EU market with confidence.
03
Business-Friendly Cost Structure
Operational and compliance costs in Poland remain competitive. Government fees, taxation policies, and corporate maintenance costs are moderate, supporting long-term scalability for crypto service providers.
04
Flexible Personnel Structuring
Although final rules are pending, current regulations allow directors and AML officers from the EU/EEA. A Polish resident director may be required in the future, but for now, businesses benefit from flexible team setup.
05
Comprehensive Service Scope
CASP licensing in Poland covers a wide range of activities — including exchange, custody, crypto-fiat conversion, and investment advisory — enabling diverse and scalable crypto business models.
06
No Licensing Quotas
There are no limits on the number of CASP licenses issued by the Polish regulator, allowing unrestricted market entry for qualifying applicants.
Links for legislation related to Crypto business in Poland
Oversees tax administration in Poland, ensuring compliance and enforcement of tax laws to maintain the integrity of the fiscal system.
Katowice tax office is separately regulating virtual currency activities in Poland, administrated as Register of Virtual Currencies.
Provides a digital gateway to various public administrative services in Poland, streamlining access to governmental processes for individuals and businesses.
Establishes a comprehensive legal framework in Poland for the detection, prevention, and reporting of money laundering and terrorist financing, aligning with international standards.
Regulates the market for financial instruments in Poland, defining the supervision and operation of financial market participants to ensure market transparency and investor protection.
Contains provisions relevant to financial crimes, including penalties for money laundering and terrorist financing, setting the legal basis for criminal prosecution in the financial sector.
VII. Crypto market bill
Tracks the progress of the adoption of new financial and regulatory legislation in Poland, including updates related to the MiCA framework
Official website of the Polish Financial Supervision Authority (PFSA), responsible for supervising financial markets and ensuring compliance with regulatory standards in Poland.
Frequently Asked Questions (FAQ) – CASP Licensing in Poland
1. How to obtain a cryptocurrency license in Poland?
The process begins with registering a Limited Liability Company (Sp. z o.o.) in Poland, ensuring the required minimum share capital (5,000 PLN) is deposited, and setting up AML/KYC/CFT compliance policies. The company must appoint a director and AML officer (EEA-based, with final regulatory confirmation pending on Polish residency requirements) before submitting the CASP license application to the National Bank of Poland (NBP).
2. How long does it take to obtain a CASP license in Poland?
The timeframe varies based on the application complexity and regulatory processing:
• A ready-made VASP-licensed company can be transferred to new ownership in approximately one month.
• Setting up a new company from scratch and preparing for the CASP license takes about two months.
• The NBP licensing review process is expected to take 3-5 months after submission under the MiCA framework.
3. Can foreign nationals apply for a CASP license in Poland?
Yes, foreigners can own a crypto company in Poland. While the final rules regarding personnel requirements are pending confirmation, it is expected that the director and AML officer must be EEA residents, with a possible requirement for a Polish resident director.
4. What is the share capital requirement for a CASP license in Poland?
- The minimum share capital for a Polish Sp. z o.o. (LLC) is 5,000 PLN at the time of company registration.
- Under MiCA, additional capital injection is required before submitting the CASP license application, with amounts starting at 50,000 EUR, depending on the license class.
5. How to open a corporate bank account for a crypto company in Poland?
Licensed crypto businesses in Poland can open bank accounts in EU-based banks or Electronic Money Institutions (EMIs). Legalaes partners with crypto-friendly financial institutions across Europe, offering assistance with account onboarding and compliance negotiations.
6. Do existing VASP companies in Poland need to transition to MiCA?
Yes, all companies registered under Poland’s VASP regime must apply for a CASP license in accordance with MiCA regulations. The transitional period for compliance runs until May 1, 2025, with an extension expected soon.
7. When should a company apply for a CASP license under MiCA in Poland?
- The official CASP license application period under MiCA opens on December 30, 2024.
- The company must meet all MiCA regulatory requirements before submission, including governance, capital reserves, and compliance obligations.
8. What documents are required for a CASP license in Poland?
Companies must prepare a full regulatory compliance package, including:
• AML/KYC/CFT policies
• Business plan with financial projections
• Memorandum and Articles of Association (MAA)
• Internal risk management and cybersecurity policies
• Corporate governance framework
A complete list of required documents is available upon request from Legalaes.
9. Is a business plan mandatory for a CASP license in Poland?
Yes, under MiCA, companies must submit a detailed Business Plan (Programme of Operations) to the National Bank of Poland (NBP). This document should include:
• The company’s planned crypto services and operational activities
• Financial projections and capital planning
• Governance structure, risk management, and compliance strategy
10. How long does the National Bank of Poland (NBP) take to approve a CASP license?
- There is currently no exact timeframe published for MiCA CASP license approvals in Poland.
- However, based on similar regulatory procedures, the NBP review process is expected to take 3-5 months.
11. Is a physical office required for CASP licensing in Poland?
- No, a physical office is not currently required for obtaining a CASP license in Poland.
- A registered legal address is sufficient for company formation and compliance.
- Some banks and financial institutions may require a virtual office with a lease agreement, which Legalaes can arrange if needed.
12. Is an AML Compliance Officer mandatory?
- Yes, a designated AML officer is a requirement for CASP licensing in Poland.
- While a final decision from Polish regulators is still pending, it is expected that the AML officer must be an EEA resident, with the possibility of requiring a Polish-based officer.
- Legalaes can provide a local AML officer to ensure smooth communication with regulators.
13. What additional requirements apply to CASP-licensed companies in Poland?
Beyond the basic licensing requirements, businesses must:
• Ensure ongoing compliance with MiCA regulations.
• Maintain proper reporting systems for suspicious transactions.
• Conduct periodic AML/KYC audits and implement risk-based monitoring.
Legalaes provides full legal and regulatory support to ensure businesses remain compliant post-licensing.
Each of our projects receives unique and tailored solutions in accordance with the initial objectives and vision of the shareholders.
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