Founded 1998
Licensed provider specialising in
fintech licensing and compliance
Poland has not yet passed its MiCA implementing law, so no Polish licences are granted yet; the MiCA rules below already apply.Until then, serve Polish clients with a MiCA licence from another EU state, passported into Poland.
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Overview
The EU MiCA Regulation (EU) 2023/1114 applies directly in Poland, but a national law must name the authority that grants CASP licences. Poland has not yet adopted that law, and the Polish Financial Supervision Authority (KNF) has confirmed that a Polish licensing procedure can only start once a law designates the competent authority. The MiCA transitional period ended on 1 July 2026, and an entry in the Polish virtual currency register is not a MiCA licence.
A MiCA licence from another EU state is passported into Poland by a simple notification
The KNF confirms that CASPs licensed in other EU states may serve clients in Poland
Capital, governance and AML rules are the same EU-wide, so no preparation is wasted
A Polish company can be set up now, ready for a Polish licence once the law is in force
No office in Poland is needed to serve Polish clients under a passport
A licence in Latvia or Lithuania takes about 6 to 10 months, then the passport follows
For a crypto business targeting Poland, the realistic route today is a licence in an EU state that already grants them, such as Latvia or Lithuania, and a passport into Poland. We prepare that application, set up the company, governance and AML framework, and plan a Polish licence for when the law allows it. Licence, company and compliance come from one team.
Coverage
Polish crypto businesses now choose between waiting for a Polish licence and getting licensed elsewhere in the EU. Whichever you pick, your services set the MiCA class and the capital behind it.
You need: to keep serving clients after the MiCA transitional period ended, as a virtual currency register entry is not a MiCA licence.
MiCA gives you: a licence from an EU regulator for the services you run today, passported back to your Polish clients.
You need: to take, pass on or fill crypto orders and give advice, while clients keep their own assets.
MiCA gives you: an entry-level authorisation with €50,000 of capital, usable in Poland under the passport.
You need: to exchange crypto-assets for złoty or euro and keep clients’ coins or keys on their behalf.
MiCA gives you: a custody-level authorisation with €125,000 of capital, recognised in Poland through the passport.
You need: to run a platform where Polish and other EU users trade crypto-assets with each other.
MiCA gives you: the top authorisation with €150,000 of capital, covering a trading platform across the EU.
Capital follows the class, not the country. Every EU regulator applies the same MiCA minimums below, or a quarter of the past year’s fixed overheads if that is more.
A passported licence is the route the KNF itself points to. You keep full access to the Polish market now, and the same MiCA file is the basis for a Polish licence later.
Many former Polish VASPs have moved to MiCA licences in Latvia and Lithuania.
The home regulator forwards your notification; services can start no later than the 15th calendar day after you notify.
Capital, governance, custody and AML follow MiCA, so a Polish licence later builds on the same work.
A Polish company can be prepared now, so you can move quickly once a Polish authority is designated.
Pricing
From a first review to a passported licence. Gold picks the licensing state, Platinum gets you licensed and passported into Poland, and Custom also provides the team and offices.
Gold
€15,000fixed fee, credited towards Platinum
We map your Polish business to MiCA, recommend Latvia or Lithuania as the licensing state and plan the passport into Poland and a later Polish licence.
Platinum
From €80,000
The complete application in the chosen Baltic state, filed with its central bank, followed by the passport notification that opens Poland.
Custom
From €150,000
Licence, team and set-up: managers and an MLRO, an office, bank and payment partners, AML outsourcing, and a Polish company ready for the Polish law.
* Indicative prices, excluding VAT and subject to final confirmation; the Platinum and Custom quote follows your class, the licensing state and the services in scope. Not included: own funds, company registration, the regulator’s application and supervision fees.
Timeline
A Baltic licence usually takes 6 to 10 months, and the Polish passport then follows within weeks. The regulator’s questions are what stretch the timeline, so a well-built first file pays off.
Company, people and documents in the licensing state.
Pick the class, form the company in Latvia or Lithuania, appoint managers, fund it and draft the business plan and policies.
~2 to 4months
MiCA: The CASP needs its registered office in the licensing state and effective management in the EU.
Core documents
They describe the real business.
The central bank checks the file is complete.
The application goes to the central bank of the licensing state, which first checks that nothing is missing.
~1 to 2months
MiCA terms: Up to 25 working days for the completeness check under MiCA.
Completeness check
Every annex must be there.
The regulator reviews and decides.
Management, owners, capital, controls, AML, IT security and custody are reviewed before the licence is granted.
~2 to 4months
In practice: The clock can stop for further information, so most decisions take longer than the legal minimum.
Focus areas
Where questions usually come.
Notify, then serve Polish clients.
Ask your home regulator to notify Poland and any other EU/EEA states, then start serving clients there.
~6 to 10months total
Passporting note: The home regulator forwards the notification within 10 working days; services can start by the 15th calendar day after notifying.
Running the CASP
Supervised by your home regulator.
* Indicative duration including preparation, for a licence in Latvia or Lithuania. A Polish licence becomes possible only once a Polish law designates the competent authority.
Process
Step 1
We check your services against MiCA and pick Latvia or Lithuania as your licensing state.
Step 2
We form the licensing company, appoint managers and arrange capital and local substance there.
Step 3
We write and file the application with that state’s central bank and answer its questions.
Step 4
We file the passport notification for Poland and keep AML and reporting running.
Requirements
Whether licensed in Riga, Vilnius or later Warsaw, a CASP meets the same MiCA rules. Preparing to them now is the work a Polish licence will also need.
The licence holder is a company registered in the licensing state, managed from within the EU and with at least one EU‑resident director.
Every EU regulator uses the same MiCA templates. A complete file covers:
At least the class minimum, or a quarter of the previous year’s fixed overheads where that is higher:
A CASP applies EU anti-money laundering rules through the law of its licensing state.
FAQ
Not yet. Poland has not adopted its MiCA implementing law, so no Polish authority has been designated to grant CASP licences, and the KNF has confirmed that a Polish procedure can only start once a law designates one.
Yes. MiCA is an EU regulation and applies directly in Poland. What is missing is the national law that names the Polish licensing and supervisory authority.
Not as a basis for crypto-asset services. The register entry is not a MiCA licence, and the MiCA transitional period ended on 1 July 2026, so services now need a MiCA licence from an EU state.
A full MiCA application with us starts from €80,000 (Platinum), and a Gold readiness audit from €15,000. Not included: own funds (€50,000 to €150,000), company registration and the regulator’s fees. Contact us for a detailed estimate.
Plan for about 6 to 10 months for a licence in Latvia or Lithuania, including preparation. The passport into Poland follows quickly: services can start no later than the 15th calendar day after you notify your home regulator.
It depends on the class, not the country: €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3), or a quarter of the previous year’s fixed overheads where that is more.
Not to serve Polish clients under a passport. Your company needs its registered office and real operations in the licensing state, effective management in the EU and at least one EU‑resident director.
The Polish Financial Supervision Authority (KNF), which the Polish draft law names as the competent authority. Until the law is in force, no Polish licence can be applied for.
Only if a Polish licence itself matters more than time to market. A passported licence lets you serve Poland now, and the same MiCA preparation counts towards a Polish licence later. We can also set up a Polish company in the meantime.
Those of the licensing state, based on EU law: know your client, screen against sanctions, monitor and report suspicious transactions, and send Travel Rule data with every crypto transfer.
The CASP itself, with our help where useful: an outsourced compliance officer or MLRO, an AML team for client checks, regulatory reporting and DORA for IT risk. See our compliance services.
Contact
Tell us about your project and receive a tailored proposal with indicative timelines and a budget from our legal and compliance team.
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