Overview of the Poland VASP License
Poland operates a Virtual Asset Service Provider (VASP) registration regime that allows companies to legally provide cryptocurrency exchange, custody, and transfer services within the European Union's largest Central European economy. The registration is maintained by the Tax Administration Chamber in Katowice (Izba Administracji Skarbowej w Katowicach), a division of the Ministry of Finance.
Poland's VASP registration has become one of the most accessible entry points into the EU crypto market, requiring only PLN 5,000 (approximately EUR 1,200) in minimum share capital and a registration fee of just PLN 616 (approximately EUR 150). With approximately 90 registered VASPs currently on the register, Poland has established itself as a credible and cost-effective jurisdiction for crypto businesses seeking EU-based operations.
The regulatory landscape is currently in a state of transition as the EU-wide Markets in Crypto-Assets Regulation (MiCA) requires member states to implement national frameworks for full CASP (Crypto-Asset Service Provider) licensing. Poland's attempts to enact national MiCA implementation legislation have been vetoed twice by the President, creating significant regulatory uncertainty heading into the July 2026 transition deadline.
Regulatory Framework
Poland's crypto regulatory environment is built on existing anti-money laundering legislation and is supervised by several authorities:
Tax Administration Chamber in Katowice (Izba Administracji Skarbowej w Katowicach): The body responsible for maintaining the VASP register, receiving and reviewing registration applications, and supervising registered VASPs under the current regime. This is a division of the Ministry of Finance.
General Inspector of Financial Information (GIIF - Generalny Inspektor Informacji Finansowej): Poland's Financial Intelligence Unit responsible for receiving suspicious transaction reports and enforcing AML/CFT obligations across all obligated entities including VASPs.
Polish Financial Supervision Authority (KNF - Komisja Nadzoru Finansowego): Designated as the national competent authority for future CASP licensing under MiCA. The KNF will assume supervisory responsibilities once the national implementing law enters into force.
Key Legislation:
- •Act of 1 March 2018 on Counteracting Money Laundering and Financing of Terrorism (Ustawa o przeciwdzialaniu praniu pieniedzy) - Articles 129m through 129z specifically govern the VASP register
- •November 2021 AML Act amendments activated the Virtual Currency Activity Register, making virtual currency activities a regulated activity
- •EU Regulation 2023/1114 (MiCA) - directly applicable across the EU from 30 December 2024
- •EU Regulation 2023/1113 (Transfer of Funds / Travel Rule) - applicable from 30 December 2024
Registration Process
The Polish VASP registration follows a structured process administered by the Tax Administration Chamber in Katowice. The registration is technically an entry in the Register of Virtual Currency Activities rather than a full license, making it a lighter-touch regulatory approval compared to jurisdictions requiring comprehensive licensing.
Step-by-Step Process:
- •Step 1: Incorporate a Polish limited liability company (Sp. z o.o.) with a minimum share capital of PLN 5,000 and register with the National Court Register (KRS)
- •Step 2: Appoint a management board with at least one member who has a clean criminal record and relevant knowledge or experience in cryptocurrency, finance, or IT
- •Step 3: Develop and adopt comprehensive AML/KYC policies and internal procedures in accordance with the AML Act
- •Step 4: Appoint an AML Officer (MLRO) with relevant qualifications
- •Step 5: Prepare approximately 40+ required documents including articles of association, business plan, organizational structure, CVs of participants, and AML compliance documentation
- •Step 6: Submit the application electronically to the Director of the Tax Administration Chamber in Katowice
- •Step 7: Pay the stamp duty of PLN 616 and any applicable power-of-attorney fees (PLN 17 per proxy)
- •Step 8: The Director enters the applicant into the register within 14 days of receipt of a properly completed application
Expected Timeline:
- •Statutory registration decision: 14 days from receipt of a complete application
- •Starting from scratch (incorporation + application): approximately 2 to 5 months
- •Typical practical timeline: approximately 3 months including company formation, document preparation, and registration
Capital Requirements
Poland's VASP registration has among the lowest capital requirements in the European Union, making it highly accessible for startups and smaller crypto businesses.
Current VASP Registration:
- •Minimum issued share capital of PLN 5,000 (approximately EUR 1,150 to EUR 1,200) for a Sp. z o.o.
- •The share capital is declared but not necessarily deposited into a bank account at the time of registration
- •No additional prudential capital requirements beyond the standard corporate minimum
Future CASP License Requirements (under MiCA):
Once Poland enacts its national MiCA implementation law, significantly higher capital thresholds will apply based on the type of crypto-asset services provided:
- •Class 1 (EUR 50,000): Reception and transmission of orders, advice, execution of orders on behalf of clients, placement of crypto-assets
- •Class 2 (EUR 125,000): Exchange services including crypto-to-fiat and crypto-to-crypto
- •Class 3 (EUR 150,000): Custody and administration of crypto-assets on behalf of clients, operation of a crypto-asset trading platform
The prudential requirement under MiCA is the higher of the relevant fixed minimum or one-quarter of the preceding year's fixed overheads, reviewed annually.
Fees
The cost structure for Poland's VASP registration is among the most competitive in the European Union:
VASP Registration Fees:
- •Stamp duty: PLN 616 (approximately EUR 143 to EUR 150)
- •Power of attorney duty: PLN 17 per proxy (if applicable)
- •No ongoing supervisory fee under the current VASP registration regime
Company Formation Costs:
- •Standard Sp. z o.o. incorporation costs through the KRS
- •Notarial fees for articles of association (or reduced fees if registered online through the S24 system)
Proposed CASP License Fees (under pending MiCA legislation):
- •Application fee: EUR 4,500
- •Additional EUR 4,500 for foreign EU entities seeking authorization in Poland
- •Annual supervisory fee (proposed): Up to 0.4% of average annual revenue over the preceding three financial years
The proposed 0.4% annual supervisory fee was one of the most controversial provisions in the vetoed legislation, as critics argued it could place Polish-registered providers at a substantial cost disadvantage relative to competitors in other EU member states with more proportionate fee structures.
Tax Considerations:
- •Standard corporate income tax (CIT): 19%
- •Small taxpayer CIT rate: 9% (available for companies with annual revenue below EUR 2 million, though crypto income may still be taxed at 19%)
- •Cryptocurrency exchange services are generally VAT-exempt following CJEU case law
Permitted Activities
Registered VASPs in Poland are authorized to provide the following services under the current AML Act framework:
Current VASP Registration Activities:
- •Crypto-to-fiat exchange: Exchanging virtual currencies for traditional currencies such as PLN, EUR, or USD
- •Crypto-to-crypto exchange: Exchanging one virtual currency for another (e.g., BTC to ETH)
- •Intermediation in exchanges: Acting as an intermediary in the above exchange services
- •Custody services: Storing cryptographic keys on behalf of clients and providing wallet services
- •Account provision: Providing and maintaining accounts that enable the use of virtual currencies
Future CASP Activities (under MiCA - 10 categories):
Once CASP licensing is available, authorized providers will be able to offer a broader range of services including operation of trading platforms, execution of orders on behalf of clients, placement of crypto-assets, investment advice on crypto-assets, portfolio management, and transfer services for crypto-assets on behalf of clients.
The MiCA framework will also introduce EU-wide passporting rights, allowing a CASP licensed in Poland to provide services across all 27 EU member states without requiring separate authorizations in each country.
Ongoing Compliance Obligations
Registered VASPs in Poland must maintain continuous compliance with AML/CFT requirements and regulatory obligations:
AML/CFT Reporting:
- •Report suspicious transactions to the General Inspector of Financial Information (GIIF) through the official reporting system
- •Apply enhanced financial security measures (customer due diligence) for occasional transactions of EUR 1,000 or more
- •Identify ownership and control of unhosted wallets involved in any transaction
Customer Due Diligence (KYC):
- •Customer identification and verification procedures
- •Beneficial owner identification for all clients
- •Enhanced due diligence for high-risk clients and politically exposed persons (PEPs)
- •Ongoing monitoring of business relationships
Transaction Monitoring:
- •Continuous monitoring of all transactions for consistency with the customer's business profile and risk assessment
- •Sanctions screening against applicable EU and national sanctions lists
- •Analysis of transaction patterns to detect potential money laundering or terrorism financing
Record Keeping:
- •Minimum 5-year retention period from the end of the business relationship or completion of the transaction
- •Records must include customer identification data, due diligence documents, risk assessments, transaction logs, internal reports, and training records
Travel Rule Compliance (EU Regulation 2023/1113):
- •From 30 December 2024, VASPs must collect and transmit originator and beneficiary information with all crypto-asset transfers
Internal Controls:
- •Maintain and regularly update internal AML/KYC policies and procedures
- •Conduct regular AML training for all employees (at least annually)
- •Implement whistleblowing procedures
- •Perform periodic internal risk assessments
- •Register beneficial owners in the Central Register of Beneficial Owners (CRBR)
Advantages of Poland VASP Registration
Poland's VASP registration offers several strategic advantages for crypto businesses seeking an EU-based presence:
Low Barrier to Entry: With a minimum share capital of just PLN 5,000 and a registration fee of PLN 616, Poland offers one of the most affordable crypto registrations in the European Union. The total cost of establishing a registered VASP is significantly lower than in jurisdictions such as Germany, France, or Malta.
Fast Registration Timeline: The statutory 14-day registration period (once all documents are complete) is among the fastest in the EU. The overall process from incorporation to registration typically takes approximately 3 months.
EU Member State Status: Registration in Poland provides the credibility and regulatory recognition associated with EU membership, access to the EU single market, and eligibility for future MiCA passporting once CASP licensing becomes available.
Large Domestic Market: Poland is the largest economy in Central and Eastern Europe with a population of approximately 38 million and a growing crypto adoption rate. The country offers a substantial domestic market for crypto services.
Competitive Operating Costs: Office space, labor, and general operating costs in Poland are significantly lower than in Western EU jurisdictions such as Germany, France, or the Netherlands, while maintaining access to a highly educated workforce.
MiCA Transition Opportunity: Existing registered VASPs benefit from grandfathering provisions that allow continued operations during the MiCA transition period, providing time to prepare for full CASP licensing.
Stable Legal Environment: Poland's legal system is based on continental European law, providing predictable commercial frameworks and strong property rights protection.
MiCA Transition and Recent Regulatory Developments
Poland's path to MiCA implementation has been marked by significant political challenges, creating a period of regulatory uncertainty for the crypto industry.
Legislative Timeline:
- •30 December 2024: MiCA became directly applicable across the EU as an EU regulation
- •26 September 2025: The Polish Sejm (lower house of parliament) passed the Crypto-Assets Market Act (Ustawa o rynku kryptoaktywow)
- •1 December 2025: President Karol Nawrocki issued a formal veto of the Act, citing concerns about over-regulation and disproportionate supervisory fees
- •19 December 2025: The Sejm re-passed the legislation in largely unchanged form and sent it back to the President
- •12 February 2026: The President vetoed the Act for a second time
Reasons for Presidential Vetoes:
The legislation was criticized as exceeding MiCA requirements by imposing additional national obligations. The proposed 0.4% annual supervisory fee on gross revenues was viewed as commercially prohibitive. Concerns were also raised about overly broad enforcement powers granted to the KNF, including website blocking authority and the potential for multimillion-zloty fines.
Current Situation (February 2026):
Poland has no enacted national implementing law for MiCA. While MiCA itself is directly applicable as an EU regulation, the national framework required for KNF to process CASP license applications does not exist. The ruling coalition lacks the three-fifths parliamentary majority needed to override the presidential veto. Existing VASP registrations remain valid under transitional provisions, with operations permitted until 1 July 2026 under the legacy registration framework.
Impact on Businesses:
A legal vacuum looms after July 2026 if no legislation is enacted. Some Polish crypto businesses have begun exploring licenses in other EU jurisdictions such as Lithuania, Malta, and France, where regulators have moved faster to implement MiCA. Companies considering Poland VASP registration should monitor the legislative situation closely and plan for potential CASP licensing requirements under MiCA.