CASP License in Poland

Poland’s legislation concerning the regulation of crypto-asset service providers (CASPs) is still in the process of being developed.

However, starting from December 30, 2024, Regulation (EU) 2023/1114 on crypto-asset markets – MiCA – is in effect throughout the entire European Union. Therefore, all EU member states must already comply with the updated requirements for registration, licensing, and operation of CASPs.

It is on these new provisions that the Polish national legislation is based, and this legislation will guide the actions of the Komisja Nadzoru Finansowego (KNF) in all aspects of regulation and supervision of the crypto market.

In this article, we will discuss in detail the procedure of obtaining a CASP license in Poland and the benefits of licensing for crypto-asset service providers. We will also explain why it is important to obtain this license now – while the cryptocurrency legislation in Poland is still in its formative stage.

What is a Poland CASP License?

A CASP license is an official authorization that companies need in order to conduct legal activities in the field of crypto assets in Poland and other EU countries. This document is issued in accordance with the MiCA requirements and is mandatory for legally operating a crypto business in the mentioned jurisdictions.

Why should you obtain a CASP license now? The point is that a transitional period is currently in effect in Poland – a time granted to companies to adapt to the new regulations and apply for licensing. Therefore, to meet the established deadlines, it is important not to delay in contacting the regulatory authorities. Otherwise, CASPs will have to cease their operations.

Benefits of Obtaining a CASP License in Poland

If you are still unsure about the advisability of obtaining a Poland CASP license, we present to you the key benefits this step offers to businesses:

1. Compliance with EU legislation. Licensing allows CASP in Poland to comply with pan-European legal standards. A crypto business license obtained in this country is recognized by all EU member states.
2. Clear and understandable regulation. Unified MiCA rules replace fragmented national laws. This simplifies compliance with requirements and helps avoid fines and other sanctions from regulators.
3. Budget savings. Poland has relatively low administrative costs, especially when compared to other Western European countries. You will spend less on legal and accounting services here, allowing for greater economic efficiency.
4. Favorable environment for crypto business. Poland is experiencing stable growth in the fintech sector. Blockchain and cryptocurrency technologies are actively being implemented in the country. This allows companies in the field to move forward and receive state support.
5. Formation of a positive reputation. Having a Poland CASP license helps providers gain the trust of investors, clients, and partners. This document automatically confirms compliance with strict EU standards in KYC, AML, financial transparency, and IT security.

Are you interested in entering the Polish crypto market as quickly as possible? Enlist the support of professional lawyers and experience all the advantages of a CASP license for your business.

Services Covered by a CASP License in Poland

A CASP license allows Polish entrepreneurs to provide a wide range of services in the field of crypto-assets. Carefully review the list of services and contact the KNF if you plan to operate in one of these areas.

• Custody and management of crypto-assets. A company may store assets on behalf of clients, manage keys, or provide access to users’ wallets.
• Operation of a crypto platform. This refers to launching a digital service that allows the sale/purchase of cryptocurrency and other virtual assets. This service also includes facilitating peer-to-peer or centralized token trading.
• Exchange of crypto-assets. This can include the exchange of digital currencies for fiat money or the conversion of one cryptocurrency into another.
• Offering of virtual assets. A Poland CASP license is required for companies engaged in the promotion or distribution of new assets. For instance, they might serve as a link between the asset issuer and potential investors.
• Consulting. Planning to offer advice on investments in virtual assets? Assisting clients in making informed decisions is also not allowed without proper licensing.
• Transfer of crypto-assets. This service involves the transfer of digital currencies or other assets between different wallets — on behalf of the client.
• Management of virtual asset portfolios. This service includes the development and execution of investment strategies — that is, making discretionary decisions regarding financial investments.

Who Can Apply for a CASP License in Poland?

In Poland, there are several categories of persons who may be eligible to apply for licensing in the field of crypto services.

You may apply to the KNF in the following situations:

• Your company is registered as a Polish legal entity. This could be a limited liability company (Sp. z o.o.) or a joint-stock company (S.A.).
• You are the owner of a foreign company registered in another EU country or outside the EU. However, to obtain a CASP license in Poland, you will be required to set up a subsidiary or branch within this jurisdiction.
• You are an existing VASP (virtual asset service provider). In this case, you must apply for CASP licensing before the end of the transitional period (by June 30, 2025).

Do you meet one of the above criteria? Hurry to apply for obtaining a CASP license in Poland to gain the opportunity to legally earn in a promising field.

Regulation of Cryptocurrency Activities in Poland under MiCA

The MiCA Regulation entered into force across all EU member states on December 30, 2024. In Poland, compliance is overseen by the Komisja Nadzoru Finansowego (KNF).

Its key provisions include:

• Mandatory Poland Crypto License for all companies providing services in the field of virtual assets.
• Compliance with strict rules regarding the offering of crypto-assets to the public. For instance, the company must publish technical documentation in open access and notify the KNF about any upcoming asset offering.
• Guaranteeing consumer protection. This includes ensuring transparency and fair practices in service provision. Companies are also required to develop complaint procedures and establish reliable customer support.
• Fulfillment of key requirements for legal entities, such as minimum capital requirements, risk management, employment of qualified staff, and more.
• Submission to the local regulatory authority. Cryptocurrency businesses in Poland are obliged to interact with the KNF on all matters related to their operations. This includes undergoing audits, notifying about asset offerings, complying with requirements, etc.

In accordance with the MiCA Regulation, specific requirements are imposed on Polish crypto entrepreneurs. We will discuss them further.

Key Requirements to Get a Polish CASP License

Let’s focus on the conditions entrepreneurs must meet to obtain a license for activities in the field of virtual assets.

Requirements Towards Shareholders

Not everyone can engage in crypto business in Poland. In order to do this, it is necessary to:

• Pass a fitness and propriety test. Usually, this must be completed by all shareholders with a qualified holding (>10% of shares).
• Prove the absence of a criminal record. You must provide a certificate confirming no history of financial crimes.
• Confirm financial stability. The KNF must be confident that the company can maintain long-term financial well-being.
• Disclose information about shareholders. It is important to provide details about ultimate beneficial owners and sources of funds for contributing to the share capital. If the company is part of a larger group, its structure must be disclosed.

Capital Requirements

This is a variable amount depending on the type of services provided. Here are some threshold values:

• Note: The capital must be fully paid in and kept in a bank account.

Registration of a Legal Entity in Poland

Poland Company Formation is a mandatory condition for CASP licensing. As an option, you can establish a branch of a foreign firm or a subsidiary. However, there are additional requirements:

• a registered office in Poland and actual operational presence;
• on-site management (with at least one director who is an EU resident);
• registration in the Polish National Court Register (KRS).

Comprehensive AML/CFT Policy

Crypto companies must conduct thorough customer checks, monitor transactions, and report suspicious activities to the Polish Financial Intelligence Unit (GIIF).

Process of Obtaining a Poland CASP License

Poland has a clearly defined process for acquiring a CASP license. However, if you want to speed up the procedure and avoid comments from the KNF, seek assistance from legal experts.

Below are the key steps you’ll need to complete:

Gather Necessary Documents

Prepare a package of documents, without which your application will not be considered. It includes:

• A business plan with a three-year forecast, a list of services, and client types;
• AML/KYC policies with detailed procedures;
• Corporate documents, including the Charter and registration certificate from the KRS;
• A bank statement confirming the deposit of initial capital;
• Identification documents and CVs of key personnel;
• Statements confirming the fitness and integrity of shareholders and executive management;
• IT security and risk management policies;
• Ownership structure, including information about beneficiaries. 

Open a Corporate Bank Account

Opening an account in Poland is a mandatory step. At the very least, because you must deposit the minimum capital and interact with the tax authority.

Most banks require:

• A certificate of company registration;
• AML/KYC procedures completed;
• A detailed explanation of the business model.

Submit an Application to the Polish CASP Register

Once the documents are ready, it’s time to submit an application to the KNF. Attach digital and printed copies of the documents. It is important that they are in the Polish language. If this condition is not met, provide certified translations.

• Note: At the time of submitting the license application, you must already have a registered legal entity and the minimum capital deposited.

Regulatory Review and Approval

The KNF typically takes three to six months to review the application. This procedure includes:

• AML/KYC compliance check;
• Financial and organizational assessment;
• Verification of information about beneficial owners.

At this stage, the regulatory authority may request additional documents, conduct interviews, or even reject incomplete applications. Qualified legal support can help you avoid this.

Inclusion in the CASP Provider Registry

After your application is approved, your firm will be included in the official CASP registry. This is a public list of licensed crypto-asset service providers in Poland.

Now you can conduct legal activities in the field of cryptocurrency in this jurisdiction.

Obtaining a CASP License in Poland

The final step is obtaining official permission to provide services in the field of crypto-assets.

• Note: You may provide only those services that are specified in the license you receive.

Once the document is obtained, you can operate under MiCA, launch marketing campaigns, and carry out other business development activities.

Ongoing Compliance and Reporting Requirements

Having a Poland CASP license is not the end of the road. The entrepreneur must continue to stay vigilant. Certain obligations must be fulfilled:

1. Compliance with AML/KYC requirements. It is not enough to develop appropriate policies — it is crucial to strictly follow them. This includes verifying clients, monitoring transactions, and reporting suspicious activities to the relevant authorities.
2. Consumer rights protection. It is important to adhere to the principle of transparency in communication with clients, inform them of potential risks, and ensure an effective dispute resolution mechanism.
3. Data security assurance. The provider is required to implement reliable cybersecurity and data protection systems.
4. Reporting to the KNF. A CASP in Poland must timely submit the following documents:

• annual report;
• quarterly or semi-annual operational reports;
• reports on transactions and clients.

It is also important to inform the KNF of any changes in the company’s activities — for example, expansion of the service portfolio, transformation of ownership structure, planned entry into new markets, etc.

Failure to comply with reporting obligations may result in fines, public warnings, or even suspension of the provider’s activity.

Costs and Timeline Involved in Obtaining a CASP License in Poland

The process of obtaining a license to conduct crypto business in Poland takes on average from three to six months. The duration depends on several factors, including the complexity of the application and the entrepreneur’s readiness to respond to additional KNF requests.

As for the cost, be prepared to pay a registration fee of €4,500. Additional expenses may include the cost of legal services and the approval of the technical documentation for a crypto-asset.

Later — after obtaining the license — providers must pay an annual supervision fee. Its amount is not fixed and is calculated as a percentage of the average annual revenue.

To simplify financial matters, entrust company registration and business licensing to professional lawyers.

Why Choose Lawrange for CASP Licensing in Poland

The Lawrange Law Firm is your reliable partner in conducting crypto business abroad. Our lawyers specialize in company registration and further support, allowing you to focus on achieving your global goals.

AA Lawrange offers:

• 10+ years of experience, allowing us to say with confidence — we understand the specifics of working with virtual assets.
• A trusted team consisting of legal experts, tax consultants, and attorneys.
• Comprehensive business support — from company registration to representation in court (if necessary).
• In-depth knowledge of current legislation and registration procedures in different jurisdictions.

Planning to launch a crypto business in Poland? Contact our manager and forget about bureaucratic issues during the registration and licensing of your company.

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