Poland has not yet passed the national law that would implement MiCA, the EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114). The President vetoed the crypto-assets act for the third time on 11 June 2026. As a result, Poland has no competent authority designated in force for crypto-asset service providers (CASPs), and no Polish regulator can yet grant CASP authorisation under MiCA. The vetoed bills designated the Polish Financial Supervision Authority (KNF) for that role.
MiCA itself is an EU regulation and applies directly in Poland without national law. Its transitional periods ended on 1 July 2026 at the latest in every member state, and ESMA's statement of 17 April 2026 confirmed that the end of the transitional period applies whether or not a member state has implemented MiCA. A firm providing crypto-asset services to clients in Poland therefore needs MiCA authorisation today. Because that authorisation cannot yet come from Poland, it comes from another member state and is passported into Poland.
| Question | Position in October 2026 |
|---|---|
| Can a firm apply for CASP authorisation in Poland? | Not yet: no Polish competent authority is designated in force |
| Does MiCA apply in Poland? | Yes, directly, as an EU regulation |
| Is there a transitional period for Polish VASPs? | No: the EU maximum period ended on 1 July 2026 |
| How can a firm serve Polish clients? | MiCA authorisation in another member state, then a passport notification covering Poland |
| Which regulator would authorise CASPs once a law passes? | The bills designated the KNF |
Before MiCA, crypto firms in Poland registered as virtual currency service providers under the Polish anti-money laundering act. Registration was an AML step, kept by the tax administration, with no prudential capital or governance assessment of the kind MiCA requires. It did not give any right to serve clients in other member states.
A national registration no longer allows a firm to provide crypto-asset services. With the EU-wide transitional period over, a firm that relied only on a Polish registration and has no MiCA authorisation was expected, under ESMA's statement, to stop providing services and wind down in an orderly way, moving client assets to an authorised CASP or to wallets the clients control, after giving clients prior notice.
Firms with a Polish client base that wish to continue now operate through an entity authorised in another member state. A common structure keeps Polish teams for marketing, client support and technology, working for a CASP authorised elsewhere.
There are four routes, and the first is the one most firms use.
| Route | What it gives | Points to weigh |
|---|---|---|
| CASP authorisation in another member state, passported into Poland | Full right to serve Polish clients and the rest of the EU | Effective management and key staff sit in the home state |
| Article 60 notification by an EU bank, investment firm or EMI | Crypto services added to an existing EU licence, passported into Poland | Limited to the services MiCA allows each type of firm |
| Partnership with an authorised CASP | Polish clients served by the partner under its authorisation | The partner holds the client relationship; passing orders on can itself be a regulated service |
| Waiting for the Polish act | A future application to the KNF | No right to serve clients until authorised |
The firm incorporates in a member state of its choice, obtains CASP authorisation from that state's regulator and notifies it that it will provide services in Poland. Under Article 65, the home regulator forwards the notification within 10 working days, and the CASP may start in Poland from the date it receives confirmation or, at the latest, from the 15th calendar day after it submitted the notification. A CASP does not need a physical presence in a host member state.
A bank, investment firm or electronic money institution authorised in another member state can add crypto services by notifying its own regulator at least 40 working days before it starts, under Article 60, and then passport them. An EMI using this route is limited to custody and transfer of the e-money tokens it issues.
The home state should be where the firm's management and key staff will genuinely work. For groups whose clients are mainly in Poland and Central Europe, the common choices are:
A Polish team can work for the authorised entity in marketing, client support and technology, provided the effective management and the regulated control functions sit in the home state. Our comparison of the best EU country for a MiCA licence covers each regulator in more detail.
Any firm providing one or more of MiCA's ten crypto-asset services, on a professional basis, to clients in Poland: custody and administration, operating a trading platform, exchange for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management and transfer services.
Non-EU firms are caught when they market to Polish clients. The reverse solicitation exception in Article 61 applies only where the client approaches the firm entirely on its own initiative, and any marketing, promotion or approach in Poland removes it. Software that lets users hold their own keys, with no control by the provider, generally sits outside MiCA.
The requirements are set by MiCA and are the same whichever member state authorises the firm.
| Class | Services | Minimum capital |
|---|---|---|
| Class 1 | Reception and transmission of orders, advice, execution of orders, placing, transfer services, portfolio management | €50,000 |
| Class 2 | Class 1 services plus custody, exchange for funds or exchange for other crypto-assets | €125,000 |
| Class 3 | Class 2 services plus operating a trading platform | €150,000 |
The firm holds the higher of that minimum and one quarter of its previous year's fixed overheads. Custody and exchange place a firm in Class 2; only operating a trading platform moves it into Class 3.
MiCA sets the same statutory timetable everywhere: 25 working days to check completeness and 40 working days to decide on a complete application, with up to 20 working days of suspension for questions. That is about four months from submission. Firms should plan 2 to 3 months to prepare and around 3 to 5 months from submission to decision in the home state, followed by the passport, which takes at most 15 calendar days.
| Stage | Typical duration | Basis |
|---|---|---|
| Preparation of the file | 2 to 3 months | Firm planning |
| Completeness check | 25 working days | MiCA Article 63 |
| Assessment of a complete file | 40 working days, plus up to 20 working days suspension | MiCA Article 63 |
| Passport into Poland | At the latest 15 calendar days after notification | MiCA Article 65 |
A business that built its client base under a Polish registration moves it into a CASP authorised in another member state. ESMA expects authorised CASPs to onboard clients transferred from other entities with full AML checks, not by simply copying records across.
A passported CASP is supervised by its home regulator, which applies the same MiCA rules to its Polish business as to the rest of its clients.
When Poland designates its competent authority, that authority becomes the host-state contact for the firm's Polish business.
A passported CASP meets MiCA's conduct rules for Polish clients: honest, fair and professional treatment, clear and fair marketing identified as marketing, risk warnings and published fees. Polish consumer protection and advertising rules apply to marketing in Poland, so client documents, risk warnings, fee disclosures and the complaints procedure should be available in Polish.
The Travel Rule under Regulation (EU) 2023/1113 applies to every crypto transfer with no minimum amount, with verification of self-hosted wallets for transfers above €1,000. Suspicious activity is reported under the AML rules that apply to the CASP, and Polish AML law applies to any establishment the firm has in Poland.
Payment services remain fully regulated in Poland by the KNF, which authorises payment institutions and electronic money institutions under Polish payment services law. A crypto business whose flows include payment services, or the transfer of e-money tokens used for payments, may need a payments authorisation alongside MiCA. The European Banking Authority's transition for CASPs providing such services without a PSD2 authorisation ended on 2 March 2026.
A group with a Polish payments business can hold a Polish payment institution licence from the KNF while its crypto services run through a CASP authorised in another member state.
Once a crypto-assets act enters into force and designates a competent authority, firms will be able to apply for CASP authorisation in Poland, and that authority will supervise Polish CASPs and act as host-state contact for passported firms. Firms authorised in another member state keep their authorisation and passport; they do not need to reapply in Poland.
A firm that wants a Polish home state in future can apply when the authority is designated, and may later move its regulated business from another member state into a Polish entity. Until then, the route to Polish clients is an authorisation elsewhere, prepared to the full MiCA standard set out in our MiCA CASP licence guide. The firm's MiCA CASP authorisation service prepares the application and the passport into Poland.
The cost of serving Polish clients is the cost of authorisation in the chosen home state plus the Polish operating layer. The home regulator sets its own application and supervision fees.
Not yet. The President vetoed the crypto-assets act for the third time on 11 June 2026, so Poland has no competent authority designated in force to grant CASP authorisation.
Yes, with MiCA authorisation from another member state and a passport notification covering Poland. The CASP may start in Poland at the latest 15 calendar days after notifying its home regulator.
No. MiCA applies directly in Poland, and the EU-wide transitional period ended on 1 July 2026, so a national registration no longer allows a firm to provide crypto-asset services.
The state where your management and key staff will work. Lithuania, the Czech Republic, Germany and Malta are common choices for firms with Polish clients.
Plan 2 to 3 months to prepare and around 3 to 5 months from submission to decision in the home state, then up to 15 calendar days for the passport.
€50,000, €125,000 or €150,000 by service class, or one quarter of the previous year's fixed overheads if higher.
No. A CASP authorised in another member state keeps its authorisation and its passport into Poland.
Buckingham Capital Consulting has obtained payments and e-money authorisations across the UK and the EU since 2013, including the Central Bank of Ireland EMI licence for Own Solutions and EuroPanPay's UK EMI licence. For firms with Polish clients, the firm obtains MiCA authorisation in the most suitable member state, files the passport into Poland and sets up the Polish client documentation.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.
This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.