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), the establishment of a local company providing cryptocurrency services is required. The minimum share capital for company registration is 5,000 PLN. Additionally, before submitting a CASP license application to the National Bank of Poland (NBP), the company must comply with capital requirements based on the scope of services it intends to offer.
As part of the registration process, the company must obtain a PESEL number and a digital signature to facilitate administrative and regulatory procedures.
The company is expected to appoint a director and an AML officer who are residents of the European Economic Area (EEA). While the final regulatory confirmation regarding personnel requirements has not yet been officially published, it is anticipated that these positions must be held by individuals from within the EU/EEA. The official confirmation from the Polish regulator is expected to be released in the near future.
However, if you are currently looking to purchase a ready-made VASP company and become its owner, you will need to appoint a director and an AML officer, but these positions can still be held by foreign individuals under the existing VASP framework.
All cryptocurrency enterprises are subject to enhanced regulatory obligations, including strict Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. These requirements align Poland’s national legal framework with the EU-wide MiCA regulation, ensuring transparency and consumer protection. Regulatory authorities retain the right to monitor corporate and financial activities as part of their oversight responsibilities.
The National Bank of Poland (NBP) oversees the regulation and compliance of CASP-licensed companies, ensuring they meet capital, governance, and operational requirements to maintain their license.
Existing VASP-licensed companies in Poland have been granted a transitional (grandfathering) period to comply with the new MiCA framework. The official deadline is set for May 1, 2025, but an extension of this period is expected in the near future, providing additional time for businesses to adapt to the new regulatory requirements.
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.
MiCA CASP License Classes
Under MiCA, all cryptocurrency businesses in Poland must obtain a CASP license, classified into three tiers based on service scope:
- Class 1 – Limited CASP covers fundamental crypto services such as custody and basic execution of orders.
- Class 2 – Standard CASP includes broader services such as cryptocurrency trading, exchange operations, and asset management, requiring higher capital and compliance standards.
- Class 3 – Full CASP grants authorization for the most complex activities, including operating a crypto trading platform or providing crypto lending services, subject to strict regulatory oversight.
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 Blockchain and 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 specific legal, regulatory, and operational requirements.
- Power of Attorney (PoA) – A notarized public document authorizing Legalaes to act on behalf of the company or individual for company incorporation and the CASP license application.
- AML/KYC/CFT Policy – A compliance framework outlining procedures for Anti-Money Laundering (AML), Know Your Customer (KYC), and Countering the Financing of Terrorism (CFT) to ensure client verification, risk assessment, and reporting of suspicious activities.
- Application Form – A structured document submitted to the National Bank of Poland (NBP), detailing the company’s business model, primary and secondary activities, and operational scope.
- Memorandum and Articles of Association (MAA) – A legal document prepared during company incorporation that defines the company’s governance and operational structure.
- Business Plan – A detailed plan outlining the company’s business model, revenue streams, risk management approach, and operational structure, required for the CASP license application.
- Internal Policies and Procedures – A set of compliance documents aligned with MiCA regulations, covering AML/KYC policies, risk management, cybersecurity, client safeguarding, and corporate governance.
- Key Personnel Documentation – Includes Fit and Proper assessments, director credentials, and compliance officer qualifications to demonstrate competency and adherence to regulatory requirements.
This structured approach ensures full compliance with Polish regulatory standards and facilitates a smooth CASP licensing process.
Business Premises Requirements in Poland
- A physical office is not currently required for obtaining a CASP license in Poland
- A registered legal address is sufficient for company formation and meeting regulatory obligations..
- Certain payment service providers and digital banks may request a virtual office with a lease agreement as part of their onboarding process. If needed, Legalaes can assist in arranging this service.
Share Capital and Government Fees in Poland
- Minimum Share Capital:
- The minimum share capital for a limited liability company (LLC) in Poland is 5,000 PLN
- Under MiCA, additional capital will be required before applying for a CASP license, depending on the license class, with the starting threshold beginning at 50,000 EUR for Class 1 CASPs.
- Government Fees: (не на 100% уверен, проверь)
- LLC Incorporation Fees:
- Traditional Registration: Approximately 600 PLN
- Online Registration (S24 System): Approximately 350 PLN
- JSC Incorporation Fees:
- Total: Approximately 600 PLN
Personnel Requirements
- AML Compliance Officer:
- The appointment of an AML officer is mandatory for obtaining a CASP license.
- The final regulatory confirmation on whether the AML officer must be a Polish national or an EU/EEA resident is still pending from Polish authorities.
- For effective communication with Polish regulators, appointing a locally based AML officer may be recommended.
- Legalaes can provide a local AML officer upon request, ensuring compliance and seamless regulatory interactions.
- Director:
- The director is expected to be an EU/EEA citizen, but Polish authorities may introduce a requirement for a Polish resident director – final confirmation is still awaited.
- Additional Personnel Requirements:
- Depending on the business model and operational complexity, the regulator may require the company to appoint additional personnel for risk management or operational oversight.
- Legalaes provides tailored staffing solutions to ensure compliance with all regulatory requirements.
Step-by-Step Process for Obtaining a CASP License in Poland
In Poland, companies engaged in crypto-asset services must comply with MiCA (Regulation (EU) 2023/1114) and adhere to AML/CFT requirements, overseen by the National Bank of Poland (NBP). Businesses operating in the crypto sector must undergo a registration and licensing process to meet legal and regulatory standards.
Polish regulations allow both domestic and foreign companies to obtain a CASP license under the same conditions, ensuring fair access to the market.
Eriks Fijalovs
Head of Blockchain and Crypto
Document Preparation & Company Incorporation
The first step involves preparing and collecting all required documents necessary to launch a CASP business in Poland. This includes providing identification documents such as a passport and proof of address, as well as drafting a business model description outlining the intended crypto activities. In parallel, we assist with checking and reserving three preferred company names with the National Court Register (KRS), preparing and notarising a Power of Attorney (PoA) if remote setup is needed, and incorporating a Polish limited liability company (Sp. z o.o.). As part of this process, legal representatives must also obtain a PESEL number and a qualified digital signature to ensure full legal standing before the Polish authorities.
Business Strategy & Initial Regulatory Consultation
At this stage, we work closely with the client to refine and align the business model with the regulatory expectations under the MiCA framework. This includes a comprehensive review and structuring of the business plan to ensure it meets the compliance criteria set out for CASPs in Poland. We also provide strategic compliance recommendations to prepare for a smooth and risk-free application process. Additionally, we offer to arrange a preliminary consultation with the National Bank of Poland (NBP)—an optional but highly recommended step. This early engagement helps assess the business model’s feasibility, discuss governance structures, AML/CFT compliance, risk management procedures, and capital adequacy in light of the planned license type.
Banking & Financial Infrastructure Setup
Although optional, establishing a reliable financial infrastructure early in the process is highly recommended. At this stage, we assist in preparing all necessary corporate documentation required for onboarding with banks or Electronic Money Institutions (EMIs). Based on the client’s business model, we identify the most appropriate financial partner and support the selection process. Our team also facilitates negotiations and guides the client through the entire account opening procedure. This includes setting up a standard corporate bank account, and if applicable, arranging a safeguard account to meet fund segregation requirements under MiCA.
CASP License Submission & Compliance Implementation
Once the company structure is in place and the financial foundation is secured, we move to the final stage of regulatory preparation and license submission. This includes increasing the company’s share capital in accordance with the selected CASP license classification under MiCA. Our legal team assists in drafting robust AML, KYC, and CFT policies specifically tailored to the company’s crypto operations. At this stage, a Polish or EU/EEA-based director must also be appointed, depending on final regulatory clarification regarding nationality restrictions. We ensure full alignment with governance, compliance, and risk management obligations before submitting the CASP license application to the National Bank of Poland (NBP). Throughout this phase, we maintain all necessary correspondence with the regulator to support a smooth review process.
License Approval & Post-Licensing Compliance
Following submission, we maintain close communication with the National Bank of Poland (NBP) to support a smooth and timely license approval process. Our team assists in providing any additional documentation or clarifications required by the regulator during the review. Once the CASP license is granted, we guide the client through the implementation of MiCA-compliant operational procedures, ensuring that the business is ready for launch. Beyond licensing, we continue to support with regular compliance updates, necessary adjustments to internal governance, and preparation for potential audits or inspections. This ensures full legal and operational alignment with Polish and EU regulatory standards over the long term.
Advantages of CASP Licensing in Poland
01
Fully Remote Registration
The entire company formation and CASP licensing process in Poland can be completed remotely through a Power of Attorney (PoA). This eliminates the need for physical presence, making it convenient for international entrepreneurs.
02
Efficient Licensing Process
Poland offers a clear and structured pathway for obtaining a CASP license. With efficient regulatory processing, businesses can secure licensing and begin operations in a relatively short timeframe.
03
Competitive Operational Costs
Compared to many other EU jurisdictions, Poland provides a cost-effective environment for maintaining a CASP license. Government fees, taxation, and compliance costs are structured to support business sustainability while ensuring full regulatory compliance.
04
Flexible Staffing Requirements
While final regulatory confirmation is awaited, current indications suggest that directors and AML officers must be EU/EEA residents, though a Polish resident may be required. Companies have the flexibility to structure their teams accordingly.
05
Wide Range of Crypto Services
A CASP license in Poland enables businesses to offer a broad spectrum of crypto services, including crypto-to-fiat and crypto-to-crypto exchange, custody, portfolio management, and advisory services, making it a versatile option for crypto entrepreneurs.
06
No Restriction on the Number of Licenses Issued
There is no cap on CASP licenses in Poland, allowing businesses to enter the market without limitations imposed on the number of licenses granted by the regulator.
07
Transparent and Evolving Regulatory Framework
The National Bank of Poland (NBP) is actively shaping the CASP licensing framework under MiCA. While the regulatory environment is stringent, Poland provides a clear and business-friendly approach, ensuring compliance while supporting industry growth.
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.
FAQ about Crypto license in Poland
1. How can I obtain a VASP license in Poland?
To get a VASP license in Poland, you typically need to:
Register a company in Poland, ensuring it meets the legal requirements for providing virtual asset services.
Apply for the VASP license with the Polish Chamber of Tax Administration, which might involve submitting detailed information about your business, including your operational, AML (Anti-Money Laundering), and CFT (Counter-Financing of Terrorism) policies.
Undergo a review process, where the regulatory body assesses your application against Poland’s VASP regulations.
2. What services does a Polish VASP license cover?
A Polish VASP license generally allows you to offer:
Exchange Services: Buying and selling of virtual assets against fiat currencies, other virtual assets, or fiat currencies to virtual assets.
Transfer Services: Facilitating the transfer of virtual assets from one party to another.
Custodian Wallet Services: Providing services to safeguard or control virtual assets on behalf of your clients.
Storage of fiat currency on behalf of your client for a certain period of time for the subsequent exchange to cryptocurrency
3. How long does it take to secure a VASP license in Poland?
The process to secure a VASP license in Poland can vary, typically ranging from 1 to 2 months. This timeframe depends on the completeness of your application, the current workload of the regulatory body, and how quickly you can respond to any queries or requests for additional information.
Fastest option to proceed is with ready-made licensed company.
4. Can foreign individuals apply for a VASP license in Poland?
Yes, foreign individuals can apply for a VASP license in Poland. However, they must establish a Polish company or a branch/representative office in Poland that complies with Polish legal and regulatory requirements. It’s important for foreign applicants to consider local laws regarding foreign ownership and operation.
5. Is it necessary to have a local bank account for a Polish VASP?
While not always explicitly required, having bank account in Poland can facilitate operational processes, such as handling client funds and ensuring compliance with local AML/CFT regulations. It's advisable to establish banking relationships in Poland to support your VASP operations effectively.
6. What are the key compliance obligations for a Polish VASP?
VASPs in Poland are typically required to:
- Implement robust AML/CFT policies and procedures.
- Perform customer due diligence (CDD) and enhanced due diligence (EDD) where necessary.
- Report suspicious transactions to the relevant Polish authorities.
- Keep detailed records of transactions and customer information.
- Ensure the privacy and security of client data in accordance with GDPR and other relevant laws.
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