Starting in 2025, the introduction of the MiCA regulation will significantly reshape the crypto-asset service landscape across the European Union, including Poland. For any company intending to offer crypto-asset services in Poland, obtaining a CASP license (Crypto-Asset Service Provider license) will be mandatory.
This new legal framework aims to strengthen regulatory compliance, particularly in areas such as anti-money laundering (AML) and counter-terrorism financing (CFT), while also increasing market transparency and user protection.
This guide provides a step-by-step overview of the CASP license application process in Poland, based entirely on the regulatory framework that will soon come into effect.
What Is a CASP License?
The CASP license is a regulatory authorization required for businesses offering crypto-asset services under the MiCA regulation. In Poland, this includes entities involved in:
- cryptocurrency exchanges,
- digital asset custody services,
- crypto-asset transfers.
Without this license, companies will not be permitted to operate legally in the crypto sector after the new law comes into force.
How to Apply for a CASP License in Poland
1. Define the Scope of Services
Applicants must clearly define the nature of the crypto-asset services they plan to offer. This may include:
- executing orders on behalf of clients,
- providing investment advice,
- managing crypto portfolios.
2. Assess Your Business Model
A thorough assessment of the business model is required to ensure alignment with MiCA standards. This includes evaluating service structures, financial planning, and internal compliance mechanisms.
3. Company Setup and Capital Requirements
Applicants must meet specific capital thresholds based on the class of service provided:
| Service Class | Minimum Capital Requirement |
| Class 1 – Executing client orders | €50,000 |
| Class 2 – Custody of crypto-assets | €125,000 |
| Class 3 – Operating a trading platform | €150,000 |
These requirements can be fulfilled either by increasing the share capital or purchasing a qualifying insurance policy.
4. Governance and Staffing Structure
According to ESMA guidelines, applicants must implement a robust internal governance system, including:
- at least two members on the management board,
- separate departments for risk management, internal control, and IT security,
- department heads with relevant education and experience.
5. Prepare Required Documentation
Applicants must submit comprehensive documentation, including:
- a 3-year business operations plan,
- description of the governance structure,
- AML and CFT compliance policies,
- technical documentation of IT systems,
- client asset segregation procedures,
- risk management and market abuse prevention policies.
6. IT Infrastructure Audits and Policies
Companies must conduct IT audits and establish written policies related to:
- data protection,
- cybersecurity,
- incident response management.
These elements are critical for demonstrating operational readiness.
7. Staff Training
Key employees must undergo training to ensure full understanding of regulatory requirements and day-to-day compliance obligations under MiCA.
8. Submit the CASP License Application
Once all documents and internal processes are in place, the CASP license application can be submitted to the Polish Financial Supervision Authority (KNF). The authority will review the application for compliance with MiCA standards.
9. Ongoing Compliance Obligations
After obtaining the CASP license, businesses must comply with regular reporting and auditing requirements and ensure continued adherence to regulatory obligations.
Who Will Issue CASP Licenses in Poland?
Although MiCA does not explicitly assign a responsible authority, Polish law designates the KNF as the national body in charge of processing CASP license applications. The final version of the crypto market legislation is expected to come into force by September 2025.
When Can You Apply for a CASP License?
Applications may be submitted once the new legislation is enacted, likely in Q3 of 2025. Companies already providing crypto services as of December 29, 2024, may continue operating for up to four months without a license, provided they submit their application early. Early applicants will benefit from a nine-month transition period.
What If You Have Not Provided Crypto Services Before?
New entrants cannot register in the current VASP (Virtual Asset Service Provider) register, which will be abolished on October 1, 2025. To enter the market, businesses should:
- acquire a company already registered as a VASP, or
- prepare all documentation to apply for a CASP license once the legislation is in force.
CASP License Costs
The application fee for a CASP license is approximately €4,500, regardless of service class. Ongoing supervision fees also apply, calculated based on company revenue over the previous three years, with a minimum fee of €500.
EU Passporting: Offering Services Beyond Poland
Once the Polish crypto market law is enacted, crypto service providers licensed in other EU member states will be able to offer services in Poland under the passporting mechanism. This requires notification to the home country’s supervisory authority but allows legal operation throughout the EU without a separate license in each country.
Conclusion: Start Preparing for Your CASP License Today
Obtaining a CASP license in Poland requires detailed planning, proper documentation, and compliance with both MiCA and Polish regulatory standards. The process, while complex, can be efficiently managed with expert legal support.
If your business intends to offer crypto-asset services in Poland, early preparation is essential.
Contact our Fintech team for assistance in navigating the CASP license application process. We’ll help ensure your company is fully compliant and ready to operate in Poland’s regulated crypto market.
