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October 28, 2026 | 7 m. to read
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CASP License in Poland
Prepare for CASP authorisation in Poland under MiCA with legal support for company formation, governance, AML/CFT compliance, prudential safeguards and application documentation. Submission assistance will be available once the Polish CASP authorisation procedure becomes operational.
Status checked on 23 October 2026. Poland has not yet brought into force national legislation designating a competent authority for CASP authorisation. KNF is therefore not currently accepting Polish CASP authorisation applications. The previous Polish virtual currency activity registration does not replace authorisation under MiCA.
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4.9
(552 reviews)About the Service
Crypto-asset service providers generally require authorisation under MiCA to offer regulated crypto-asset services in the European Union, unless an applicable exemption or alternative regulatory route applies. Poland’s domestic CASP authorisation procedure is not yet operational because the necessary national framework has not entered into force.
Manimama helps clients prepare for authorisation by establishing a Polish company, reviewing the proposed services and ownership structure, designing governance and AML/CFT arrangements, assessing prudential safeguards, and drafting regulatory documents. Once the Polish procedure becomes operational, we can assist with submission and regulatory correspondence.
Key Numbers about a CASP License in Poland
Poland has not yet designated a competent authority to authorize CASPs under MiCA.
€50,000, €125,000 or €150,000 depending on the class of services, MiCA Annex IV.
At least one EU-resident director; additional directors may be required.
Applicable personal income tax range in Poland.
9% CIT for eligible small taxpayers; 19% standard rate.
Tax rate applied to investment income.
Legal Opinion about a CASP License in Poland
MiCA establishes a harmonised authorisation and operating framework for crypto-asset service providers in the EU. Applicants must demonstrate appropriate governance, competent management, AML/CFT compliance, prudential safeguards, operational resilience and service-specific controls. Businesses planning a Polish application can prepare these arrangements now, while submission remains unavailable under the current Polish national framework. Once authorised, a CASP may provide the services covered by its authorisation throughout the EU subject to the applicable cross-border procedures and continuing obligations.
Ganna Voievodina
Manimama, CEO
Types of Activities with a CASP License in Poland
Providing custody and administration of crypto-assets on behalf of clients
This service means safekeeping or controlling, on behalf of third parties, crypto-assets or the means of access to such crypto-assets, where applicable in the form of private cryptographic keys. Holdings of crypto-assets on behalf of the clients shall be segregated from CASP’s holdings.Operation of a trading platform for crypto-assets
This service contains of the management of one or more multilateral systems, which brings together or facilitates the bringing together of multiple third-party buying and selling interests for crypto-assets – in the system and in accordance with its rules – in a way that results in a contract, either by exchanging one crypto-asset for another, or a crypto-asset for funds.Exchange of crypto-assets for funds
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for funds by using proprietary capital.Exchange of crypto-assets for other crypto-assets
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other crypto-assets by using proprietary capital.Execution of orders for crypto-assets on behalf of clients
This service means concluding agreements to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets on behalf of third parties and includes the conclusion of agreements to sell crypto-assets at the moment of their issuance.Placing of crypto-assets
This service includes the marketing, on behalf of or for the account of the offeror or of a party related to the offeror, of crypto-assets to purchasers. Before placing the crypto-assets a CASP shall obtain the agreement of the issuers or any third party acting on their behalf.Reception and transmission of orders for crypto-assets on behalf of clients
This service means the reception from a person of an order to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets and the transmission of that order to a third party for execution.Providing advice on crypto-assets
This service means offering, giving or agreeing to give personalized recommendations to a third party, either at the third party’s request or on the initiative of the a CASP providing the advice, in respect of one or more transactions relating to crypto-assets, or the use of crypto-asset services.Providing portfolio management on crypto-assets
This service includes managing portfolios in accordance with mandates given by clients on a discretionary client-by-client basis where such portfolios include one or more crypto-assets.Providing transfer services for crypto-assets on behalf of clients
This service means transfer, on behalf of a natural or legal person, crypto-assets from one distributed ledger address or account to another. Such service may be provided without virtual currency wallet opened for a CASP’s client.
Benefits of CASP Authorisation under MiCA
Cross-border EU operations
- An authorised CASP may provide the services covered by its authorisation in other EU Member States, subject to the applicable MiCA notification procedure.
Client confidence
- Authorisation demonstrates that the provider has been assessed against an EU regulatory framework and is subject to continuing compliance obligations.
Clear operating framework
- MiCA provides harmonised rules on governance, conduct of business, safeguarding and prudential safeguards for authorised CASPs.
Institutional relationships
- Regulatory authorisation may support discussions with banks, investors and counterparties, but does not guarantee account opening, funding or partnerships.
Long-term compliance planning
- Preparation for and maintenance of authorisation can strengthen internal controls, operational resilience and regulatory readiness; authorisation does not eliminate regulatory or business risks.
Step by Step Description
We support businesses with incorporation and MiCA readiness now and can assist with the regulatory submission process once Poland’s domestic authorisation framework becomes operational.
Step 1
Incorporation stage
- Company formation in Poland
- Arrangements for a registered address, where required
- Support with corporate banking arrangements, subject to the bank’s approval
- Appointment of the management body in accordance with Polish corporate law and MiCA
- Documentation of the ownership and governance structure
Step 2
Pre-authorisation stage
- Preparation of legal, financial and compliance documentation under MiCA
- Review and updating of existing policies and procedures
- Assessment of the intended services, prudential safeguards, AML/CFT framework and IT governance
Step 3
Authorisation stage
- Assistance with CASP application submission once Poland’s procedure becomes operational
- Regulatory communication and responses to information requests during the authorisation process
Our Experts in This Area
Yuliia Kravchenko
Head of Licensing & Advisory
Timeline description
Name Selection and Availability Check
Review the proposed company name and availability.
Company Registration and Tax Setup
Prepare incorporation documents, register the entity and complete relevant tax and corporate formalities.
Application Submission — Once Available
Submit the application after the Polish CASP authorisation procedure becomes operational.
Legal Structure and Ownership Model
Determine the corporate form, ownership, management and planned MiCA services.
Regulatory Documentation and Compliance Preparation
Prepare the application package, AML/CFT policies, prudential safeguards, governance and operational arrangements.
Regulatory Review and Decision
Support correspondence with the designated competent authority and responses to regulatory information requests.
Polish National Legislation
To operate under MiCA in Poland, it is vital to understand the key legal framework, licensing rules, relevant timelines, and regulatory requirements
Regulation
Regulation (EU) 2023/1114 (MiCA) applies directly in Poland and sets EU requirements for authorisation and ongoing operation of crypto-asset service providers. However, the Polish national act intended to establish the domestic CASP supervisory and authorisation framework has not entered into force. The Act on the Crypto-Assets Market adopted by the Sejm on 15 May 2026 was not re-enacted after the presidential veto on 4 September 2026.
Licensing Authority
KNF was envisaged as the Polish competent authority for CASP authorisation under the proposed national framework, but has not been designated for that purpose. Its position on CASP authorisation must be distinguished from certain responsibilities concerning e-money token issuers under the separate applicable framework.
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Procedure, timelines, fees:
Under Article 63 of MiCA, a competent authority must assess completeness within 25 working days of receiving an application and assess a complete application within 40 working days, subject to applicable procedures and suspensions. These periods do not mean that Polish CASP applications can currently be filed or that authorisation is guaranteed within that time. The Polish Act on the Crypto-Assets Market adopted by the Sejm on 15 May 2026, which did not enter into force, provided for a fee for granting CASP authorisation capped at the PLN equivalent of EUR 4,500 and an annual supervisory contribution of up to 0.4% of the relevant statutory revenue base, with a minimum equivalent of EUR 500. These are not currently applicable national CASP fees and future legislation may differ.
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Requirements for Obtaining CASP Authorisation
Key regulatory requirements for obtaining a CASP license in Poland, including requirements related to organizational structure (such as company formation and governance), minimum capital thresholds, and necessary documentation (such as policies and AML procedures)
Requirements for key persons
Management body: MiCA does not impose a universal minimum of two or more directors. For a Polish sp. z o.o., the management board may have one or more members under Article 201 §2 of the Commercial Companies Code. At least one director must be resident in the EU. Management body members must meet applicable good repute, competence, experience and sufficient-time-commitment requirements.
Shareholders and qualifying holdings: Information is required about shareholders or members with qualifying holdings and their reputation. Professional fitness requirements for management body members must not automatically be imposed on every shareholder. Ownership transparency, criminal-record information where applicable and assessment of qualifying holdings must follow the relevant MiCA requirements.
Capital Requirements
- Class 1 — EUR 50,000: reception and transmission of orders, execution of orders, placing, transfer services, advice and portfolio management.
- Class 2 — EUR 125,000: Class 1 services plus custody and administration, exchange for funds and exchange for other crypto-assets.
- Class 3 — EUR 150,000: Class 2 services plus operation of a trading platform.
Under Article 67 of MiCA, the required prudential safeguards equal the higher of the applicable Annex IV threshold or one quarter of fixed overheads, calculated under the relevant rules. Prudential safeguards may be met using eligible own funds, insurance or a comparable guarantee, or an allowed combination.
Documentation Requirements
The following is a non-exhaustive overview of the information and documentation generally required under Article 62 of MiCA and applicable technical standards; service-specific materials will depend on the scope of the proposed authorisation.
- Corporate documents, including articles of association, registered-office and ownership information
- Programme of operations identifying the proposed crypto-asset services, their delivery and marketing
- Details of management body members, their reputation, experience and time commitment
- Information on shareholders and members holding qualifying interests
- Description of prudential safeguards under Article 67 of MiCA
- Governance, internal controls, risk management and business continuity arrangements
- AML/CFT policies, controls and procedures
- Technical and non-technical descriptions of ICT systems and security arrangements
- Client complaints-handling procedures
- Proposed cross-border activities, where relevant
- Service-specific policies for custody, segregation, trading platforms, exchanges, execution, advice, portfolio management or transfers, as applicable
Taxes in Poland
Discover the main taxes affecting businesses and individuals in Poland, including key corporate, capital gains, and personal income tax rates, essential rules, and basic compliance requirements.
Corporate Income Tax (CIT)
The standard corporate income tax rate in Poland is 19%.A reduced corporate income tax rate of 9% may apply to small taxpayers and certain start-ups that meet the statutory criteria.Companies in Poland are generally subject to corporate income tax on their worldwide income if they are tax residents of Poland.Corporate income tax returns are generally filed electronically through the Polish tax authorities’ online system.In Poland, the taxation of crypto-assets depends on the nature of the activity and the applicable Polish tax rules.
Capital Gains Tax (CGT)
Income derived from crypto-assets in Poland is generally subject to a flat tax rate of 19%.Taxation typically applies when crypto-assets are exchanged for fiat currency, goods, services, or property rights.Transactions between cryptocurrencies are generally not taxable until they are converted into fiat currency or another taxable event occurs.
Personal Income Tax (PIT)
All individuals who are tax residents of Poland are generally subject to Polish personal income tax on their worldwide income. Non-residents may also be subject to tax on certain income derived from sources in Poland.Poland applies a progressive personal income tax scale:Up to PLN 120,000 — 12%
Above PLN 120,000 — 32%Depending on the taxpayer’s circumstances, additional social security contributions may also apply.
Clients Confirm Our Quality
“Thank you for your expertise and patience!”
Before signing the contract, we made six rounds of negotiations, because my client had a lot of questions that concerned the technical infrastructure, the board creation, and the formation of the authorized capital. We got the most complete picture, which allowed us to choose this provider. Thank you for your expertise and patience!
“It is the comprehensive approach that they use and the willingness to help with any issue”
During the preparation of documents for MiCA, Manimama advised us on labor, administrative, and corporate law. Usually, providers do not do this, strictly limiting the list of works that they do under the contract. It is the comprehensive approach that they use and the willingness to help with any issue that arises along the way that attracts us as a client.
AddUps | CLO
FAQ
CASP authorisation under MiCA allows the provision of authorised crypto-asset services across the EU, but the domestic application procedure in Poland is not yet operational.
The Polish CASP authorisation procedure is not currently operational; the relevant national competent authority has not been designated. Applicants prepare the required documents and may submit them to the designated authority once the Polish CASP authorisation procedure becomes operational.
Depending on the authorisation granted, CASPs may provide custody, trading-platform, exchange, order-related, placing, transfer, advisory and portfolio-management services.
Applicants must meet MiCA requirements covering governance, management fitness, prudential safeguards, AML/CFT, ICT and operational controls, and relevant documentation.
MiCA requires a registered office and at least part of the crypto-asset services to be carried out in Poland, with effective management in the EU, but does not universally mandate a separately leased office.
MiCA sets minimum thresholds of EUR 50,000, EUR 125,000 or EUR 150,000 depending on the services, subject to potentially higher prudential safeguards.
Applicants prepare the required documents and may submit them to the designated authority once the Polish CASP authorisation procedure becomes operational.
MiCA provides for a 25-working-day completeness check and a 40-working-day assessment of a complete application, subject to permitted suspensions; Poland does not currently accept applications.
A Polish Act adopted in May 2026 but not brought into force envisaged a fee capped at EUR 4,500 and an annual contribution of up to 0.4% with a minimum equivalent of EUR 500, and these are not current tariffs.
The required documents depend on the scope of the proposed authorisation and generally include corporate documents, a programme of operations, information on management and qualifying shareholders, prudential safeguards, governance, AML/CFT and ICT arrangements, complaints-handling procedures, proposed cross-border activities and applicable service-specific policies.
Once authorised, a CASP may provide the services covered by its authorisation throughout the EU subject to the applicable cross-border procedures and continuing obligations.
MiCA CASP authorisation is distinct from the former Polish virtual currency registration, which does not itself authorise MiCA-regulated services.
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