Poland opens new horizons for VASP: extension of the transition period and opportunities for crypto business

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With the European MiCA regulation (“Markets in Crypto-Assets”) coming into force, EU countries are actively working on its national implementation, and Poland is no exception.

Recently, the crypto community was stirred by the announcement of Poland’s Deputy Minister of Finance, Jurand Drop, regarding the extension of the transition period for existing Virtual Asset Service Providers (“VASP”).

What does this mean for crypto businesses, investors, and clients? We have analyzed the details and are ready to share the latest insights and practical advantages with you in this article.

Recent changes for VASP in Poland

At the beginning of January 2025, the Polish regulator—the Financial Supervision Authority (“Komisja Nadzoru Finansowego,” “KNF”)—released its position on MiCA implementation during the transition period. According to the statement, existing VASP may continue operating under Poland’s Anti-Money Laundering and Counter-Terrorism Financing Act (“Przeciwdziałanie praniu pieniędzy oraz finansowaniu terroryzmu”) until September 30, 2025. However, to do so, they must submit a complete set of documents for a CASP (“Crypto-Asset Service Provider”) license by May 1, 2025. KNF has even advised businesses to begin preparations for licensing based on the draft law on MiCA implementation in Poland (“Projekt ustawy o kryptoaktywach”), which has yet to be approved by Parliament.

This short transition period, combined with legal uncertainty, raised concerns among businesses in Poland, making it difficult to plan and adapt to the new requirements.

However, a recent statement by Poland’s Deputy Minister of Finance, Jurand Drop, brought optimism to the situation. During the seminar “Risks and Regulation in the Banking Sector 2025,” he announced that the government plans to extend the transition period for existing VASP. Instead of the previous deadline of May 1, 2025, for submitting CASP license applications (as stated in the KNF position), businesses will be granted four months from the date the law comes into force to prepare documents and submit an application to KNF. According to Drop, amendments to the draft law will be presented at a Council of Ministers meeting in March 2025, after which the document will need parliamentary approval.

Important note: This is currently only a statement from an official, as there is no official confirmation from KNF or an updated text of the draft law yet. After analyzing available sources, we found that Drop’s statement is the only basis for the information about the deadline extension. However, we hope that these changes will soon be incorporated into the draft law, providing Poland with a solid legal foundation for realizing its crypto potential. As soon as there are updates, we will promptly cover them in our next article!

Why are these changes beneficial for crypto businesses?

The extension of the transition period is not just a postponement of deadlines but a real advantage for VASP and investors. Here are the key benefits:

  1. Additional time for preparation – Four months from the law’s enactment allow businesses to carefully prepare their documents for a CASP license, avoiding rushed applications and mistakes. This is especially relevant for companies already operating in the market that want to maintain their reputation and client base.
  2. Poland’s favorable stance towards crypto companies – This decision demonstrates that Poland is willing to accommodate businesses by adapting regulations to market realities.
  3. Potential to become Europe’s crypto hub – Thanks to a flexible regulatory approach and its strategic location in the heart of Europe, Poland could attract a significant number of crypto companies. The extended transition period further highlights its ambitions to become an attractive hub for innovative projects.

Unlike Lithuania or the Czech Republic, where clear licensing procedures are already in place, Poland currently does not allow applications due to the absence of an approved law. However, this is only a matter of time—Jurand Drop’s statement confirms that the government is actively working on finalizing the legal framework. Once the draft law is approved by the Council of Ministers in March, the next step will be parliamentary review. The exact dates of the parliamentary vote are unknown, but we are closely monitoring the situation to keep you informed.

More updates from the Deputy Minister’s statement

Jurand Drop’s speech at the European Financial Congress seminar shed light on a broader context of changes. Here are the key takeaways:

  • Client transparency is a priority – “It is extremely important for us that clients participating in the crypto-asset market receive comprehensive information about the entity they intend to do business with and have access to reliable, clear, and non-misleading materials,” Drop emphasized. This suggests that Poland aims to create a safe environment for investors, enhancing its attractiveness.
  • Extensive market consultations – According to the Deputy Minister, the government has conducted large-scale consultations over the past few months, collecting over 700 pages of feedback from stakeholders. “We have considered some comments, even those we were previously unaware of, as this is a less familiar market for both us and regulators,” he added. This approach reflects Poland’s commitment to balanced regulation.
  • Lifting the ban on crypto loans – One of the most notable updates is the decision to remove the ban on crypto-asset lending. This initiative came from KNF and is another signal of Poland’s flexibility toward innovations.

Although these changes are not yet legally formalized, they lay the groundwork for Poland to become a true “crypto haven” for businesses and investors.

As conclusion

The extension of the transition period for VASP in Poland is not just a bureaucratic formality but a strategic step that opens doors for the crypto business. The additional four months allow companies to properly prepare for the new rules, while the government’s pro-business stance and the lifting of restrictions (such as the ban on crypto loans) make Poland one of the most promising jurisdictions in Europe.

While Lithuania and the Czech Republic have already launched their licensing frameworks, Poland offers a unique opportunity to enter the market with minimal risks and maximum potential.

Manimama Law Firm sees this as an opportunity for our clients—from startups to large crypto projects—to establish a presence in Poland and leverage its potential to become a crypto hub. We are ready to support you at every stage, from document preparation to obtaining a CASP license once the law comes into force. Poland is moving forward, and we will help you be among the first to seize its advantages. Stay tuned for updates in our next articles! 

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Manimama Law Firm provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.

The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation.