Step-by-step guide to registering a crypto license in Poland

Poland is one of the EU leaders in terms of the number of registered crypto companies. According to the Polish National Revenue Administration (KAS), more than 1,200 crypto operators were active in the country as of 2024. However, the rules have tightened significantly: the MiCA Regulation has entered into force, and now operating on the market requires obtaining CASP status. Companies that fail to apply for a CASP license risk being banned from operating, facing multimillion-zloty fines, and having their accounts blocked. At the same time, the licensing procedure itself has become more complex: the Polish Financial Supervision Authority (KNF) requires dozens of documents, a strict internal control structure, and technical readiness. How can you complete the registration process step by step? This article provides a detailed guide to obtaining a crypto license in Poland: from setting up a company to registering in the official EU-wide CASP register.

Who can apply for a CASP license in Poland?

To apply for a Crypto-Asset Service Provider license in Poland, an applicant must be a legal entity registered in an EU Member State and meet a wide range of organizational and regulatory requirements. The new regime, effective from mid-2024, eliminates the possibility of operating “without presence” and requires companies to demonstrate real, ongoing operations within the country.

Key requirements for applicants:

1. Registered legal entity in the EU. The company must be incorporated in Poland or another EU Member State. If the business intends to operate in Poland specifically, the headquarters and core operations should be based in the country.
2. Identified Ultimate Beneficial Owner (UBO). Ownership structures must be transparent, and all ultimate beneficial owners must be disclosed. Offshore jurisdictions or nominee structures may trigger additional scrutiny and increase the risk of license rejection.
3. Local presence. A real physical office in Poland is required, along with personnel based in the country, including an AML officer, compliance officer, and technical specialist. These individuals must be available for KNF inspections and supervision.
4. Communication in Polish or English. All official documents must be submitted in either Polish or English. Correspondence with the regulator is also conducted in one of these languages, depending on the case and the preferences of KNF.
5. Verified qualifications of key personnel. The application must include personal data, CVs, and evidence of qualifications for key individuals (e.g., compliance officer, AML officer). These staff members are subject to reputation and experience checks.

Special considerations for non-EU residents

Companies registered outside the European Union are not eligible to apply for a CASP license directly. If they intend to serve clients in Poland or anywhere in the EU, they must:

1. Establish a subsidiary or branch in the EU;
2. Complete the full CASP licensing process through the local entity;
3. Appoint personnel and establish a presence within the EU.

Important! Even if your business lacks a physical presence in the EU but provides services to EU clients (via website, advertising, or customer support), you are subject to MiCA requirements and must obtain a license. Non-compliance may result in a ban on operations, financial penalties, and exclusion from the EU market.

Step-by-step procedure for CASP registration in Poland

Registering a CASP company in Poland involves several stages, each requiring careful preparation, legal precision, and ongoing communication with the regulator. The process is similar to obtaining a license for financial institutions and requires professional support at every step.

Initial consultation and compliance gap analysis

Before applying, it is strongly recommended to carry out a preliminary audit — a so-called gap analysis. This helps assess whether the company’s structure meets MiCA requirements, whether qualified staff are in place, and whether the IT infrastructure complies with security and transparency standards.

1. Assessing the business model for CASP eligibility;
2. Identifying readiness level for submission;
3. Providing advice on corporate structure and UBO requirements.

Company incorporation

At this stage, a Polish or other EU-based company is incorporated, which will formally apply for the license. Important factors include:

1. Capital structure and Articles of Association;
2. Appointment of a director, AML officer, and compliance officer;
3. Opening a bank account and securing a physical office.

Poland allows 100% foreign ownership but requires local management and a transparent corporate structure.

Dossier preparation (compliance, AML/KYC, IT, personnel)

The applicant must prepare a comprehensive application package, which typically includes:

1. AML/KYC policy and internal control procedures;
2. Description of IT systems, data protection, and cybersecurity measures;
3. Business model and operational description of services;
4. Information on personnel and governance structure.

KNF may request internal policies, technical specifications, whitepapers, and security audit results.

Submission of the application to KNF

The application is submitted in both digital and paper form via KNF’s platform. It must be accompanied by an official statement, proof of fee payment, and a power of attorney if a expert or consultant represents the applicant. KNF conducts a preliminary check for completeness and compliance with formal requirements.

Correspondence with the regulator

KNF may issue requests for additional information, clarifications, or document corrections. This is a standard part of the process. At this stage, it is important to:

1. Respond promptly and accurately to all inquiries;
2. Ensure the availability of key contacts;
3. Adjust documentation or replace team members if required.

Delays often occur at this stage due to insufficient preparation.

Final decision and ESMA register entry

After completing all verifications, KNF issues a decision. If approved, the company receives its CASP license and is officially registered. In case of rejection, the reasons are provided, and the applicant may reapply after resolving the issues. Licensed companies are automatically added to the EU-wide CASP register maintained by ESMA, giving them the right to operate throughout the European Economic Area without re-licensing.

Timing and cost of obtaining a license

The procedure for obtaining CASP status consists of several key stages:

1. Compliance assessment and dossier preparation: 1–2 months (depends on the company’s level of readiness and availability of qualified personnel);
2. Application review by KNF (formal and substantive assessment): up to 80 business days, or around 4 months;
3. Additional requests, correspondence, and revisions: 1 to 2 months;
4. Publication in the register and launch of operations: up to 10 business days.

The average time to obtain the license ranges from 3 to 6 months, provided that the dossier is complete and correctly submitted. In case of major revisions or documentation gaps, the process may take up to 8–9 months.

Cost of licensing

The total budget for obtaining a CASP license includes several components:

1. Government fee for application review: approximately €1,250–1,500;
2. Company registration and initial setup costs: from €800 to €2,000;
3. Regulatory and compliance support: from €5,000 to €15,000, depending on the complexity of the case;
4. Personnel (compliance officer, AML officer, IT director): from €3,000/month (as salary or outsourced support);
5. IT and technical infrastructure (data protection, cybersecurity audit, hosting): from €2,000;
6. Translations, notary services, apostilles, etc.: from €500.

In total, the overall cost of obtaining a CASP license in Poland typically ranges from €10,000 to €25,000, which is significantly lower than in most Western European jurisdictions.

How Key2Law can help with getting a crypto license in Poland

Obtaining a CASP license in Poland is a complex regulatory and compliance project that requires in-depth knowledge of the MiCA Regulation, KNF requirements, and the technical aspects of the crypto sector. The Key2Law team provides comprehensive support at every stage of the registration process and assists clients both before and after obtaining the license.

Here’s how we help our clients:

1. MiCA compliance assessment. We conduct a thorough audit of your company’s structure, business model, and compliance practices. We identify potential risks and develop a step-by-step adaptation plan.
2. Preparation of the complete application package for KNF. We draft all necessary documents, including AML/KYC policies, internal control procedures, IT system descriptions, whitepapers, employee CVs, and governance structures.
3. Company and physical presence setup in Poland. We assist with establishing a legal entity, securing an office address, opening a bank account, and hiring key personnel.
4. Communication with Polish and EU regulators. We handle all correspondence with KNF, prepare responses to inquiries, and support clients during interviews and the licensing process.
5. Post-licensing support. We ensure ongoing compliance with ESMA and KNF requirements, prepare for inspections, update documentation, and advise on scaling operations across the EU.

Our team combines experienced specialists, compliance officers, and IT experts. We are deeply embedded in the Polish and EU regulatory ecosystems and know how to navigate them effectively. Want to obtain a CASP license in Poland quickly and with minimal risk? Contact Key2Law — we’ll provide end-to-end support from the first consultation to publication in the ESMA register.