MiCA applies directly in Poland, but as of October 2026 Poland has still not adopted the act that implements it. No Polish authority can yet grant a CASP authorisation, and since the MiCA transitional period ended on 1 July 2026 a Polish VASP registration no longer covers crypto-asset services. The Polish AML Act applies on top. Which route you need depends on where you are: already authorised elsewhere in the EU, applying for the first time, holding a legacy VASP registration or planning a token project. This page helps you pick the path and points to the detailed guides and to the lawyers who handle the work. It does not repeat the licence guide itself.
Not sure which route applies? Describe the services you provide, where your entity is incorporated and whether you already hold any authorisation. Our Client Relationship Manager will reply within 24 hours with a free quote and the lawyer who will take the matter. No public price list: every quote reflects the actual scope.
Choose your situation
I am authorised as a CASP in another EU state and want Polish clients
Passporting under MiCA: the notification through your home regulator, which Polish rules apply locally while the implementing act is pending, marketing and client-facing rules in Poland, and when a branch or a Polish entity makes more sense.
I want a CASP authorisation in Poland
Applications cannot be filed in Poland until the implementing act designates the competent authority. What you can do now: prepare the file (legal entity and governance, capital and prudential safeguards, business plan, ICT and security, AML programme, custody and conflict policies) and compare Poland with authorisation in another EU state.
I hold a Polish VASP registration and need to know what happens next
The register of virtual currency activities no longer covers crypto-asset services after 1 July 2026. What existing providers can do now: passport an authorisation from another EU state, apply elsewhere, or pause and wind down Polish activity in an orderly way.
I want to issue a token or run a crypto project from Poland
Classification of the asset (utility token, asset-referenced or e-money token), white paper duties, offers to the public and admission to trading, and which activities need an authorisation at all.
I need AML and KYC compliance for a crypto business
Obligated-institution duties under the Polish AML Act: risk assessment, customer due diligence, transaction monitoring, GIIF reporting, the travel rule and internal procedures that stand up to an inspection.
I need the corporate side: company, bank, taxes
A Polish sp. z o.o. or another vehicle for the venture, directors and shareholders, bank account onboarding, accounting and tax set-up, handled together with the regulatory work.
How we work on crypto matters
- ScopingYou describe the business model, the assets involved, the entities and any existing authorisation. We reply within 24 hours and confirm which MiCA and AML regime applies.
- Route and gap analysisPassporting, a Polish CASP application, a white paper, or no authorisation at all. You get a written path with the documents, bodies and timeline, and a quote before any work starts.
- Preparation and filingWe draft the application or notification pack, the policies and the corporate documents, set up the Polish entity where needed and handle the correspondence with the regulator.
- Operating compliantlyAML programme, reporting, regulatory updates and board support continue on a retainer, with one point of contact for the regulatory and corporate side.
Fees and how we quote
We do not publish a price list, because a passporting notification, a first-time CASP application with custody and trading services, and an AML remediation after an inspection are different projects. What we commit to is a written quote before you engage us and a fee model that fits the work:
- Fixed fee for cross-border notifications, white paper reviews, legal opinions on classification and standard policy sets.
- Staged project fee for a CASP authorisation, split by milestone: gap analysis, document pack, filing and supervisory proceedings.
- Monthly retainer for ongoing AML and regulatory compliance and board support.
- Hourly rates with a cap for supervisory proceedings, inspections and disputes.
What drives the cost: the services in scope (custody, exchange, trading platform, transfer services), the group structure and whether an EU authorisation already exists, the maturity of your AML and ICT documentation, and whether a Polish entity has to be set up alongside. Supervisory, court and notarial fees are statutory, passed on at cost and shown separately from our fee.
Who handles these matters
Michał Gawlak
Contact an expert
office@cgogroup.pl
Michał Gawlak is attorney-at-law and partner at CGO Leglal Counseling. He graduated with a law degree from the Faculty of Law and Administration at the University of Lodz (specialisation – corporate and economic law). Michał was a participant of the postgraduate American Law School run by the Michigan State University.
Michał has vast experience in corporate and tax law having advised Polish and foreign entrepreneurs on transformations, corporate and tax solutions.
Michał is a founder of the Lodz branch of the Academia Iuris Foundation – an organisation which provides legal services to indigent persons. Michał gained his legal experience in the Property and Corporate department of the international law firm – CMS Cameron McKenna and the renowned Polish law firm – Sołtysiński Kawecki & Szlęzak.
His areas of expertise are in civil, economic and tax law. He speaks fluent English and German. He runs a tax blog: spolkazagranica.pl
Corporate set-up alongside the regulatory work:
- Jakub ChajdasPartner, attorney-at-law. Corporate set-up, governance and ongoing legal assistance for the Polish entity.Profile and articles
Guides on crypto regulation in Poland
Written by our lawyers and updated as the Polish implementing act progresses. Start with the licence guide, then go to the page that matches your route.
MiCA and licensing
AML compliance
Setting up the Polish entity
Frequently asked questions
I am authorised as a CASP in another EU country. Do I need a Polish licence?
No. A MiCA authorisation granted in one member state can be passported to Poland through a notification made via your home regulator. You still have to respect Polish rules on marketing, consumer protection and AML, and host-state supervision in Poland will be organised by the implementing act, which is still pending. Our cross-border guide explains the notification and what to prepare before you start serving Polish clients.
Is a Polish VASP registration still enough to operate?
No. The MiCA transitional period ended on 1 July 2026 and Poland has not adopted the implementing act, so a Polish VASP registration no longer covers crypto-asset services. If you still rely on the register, the practical options are to passport an authorisation obtained in another EU state, apply elsewhere, or pause the activity in Poland. The licence guide tracks the state of play.
Can I apply for a CASP authorisation in Poland now?
Not yet. Until the implementing act enters into force there is no Polish authority to file with. Once an application can be filed, MiCA gives the authority 25 working days to check completeness and 40 working days to decide on a complete file. In practice preparing the documents takes longer than the decision period, so many clients start the gap analysis now and choose the jurisdiction once the Polish timeline is clear.
Can a company from outside the EU get authorised?
Only through an EU legal entity. MiCA requires the applicant to be established in a member state, with its registered office where it carries on at least part of its services and at least one director resident in the EU. The entity is set up in the member state where you apply; while the Polish act is pending, that is usually another EU state, with Poland served by passporting. We handle the company and the authorisation together.
Which route is right for a token issuer rather than a service provider?
Issuing tokens and providing crypto-asset services are regulated separately. Depending on how the asset is classified, you may need a white paper notified to the competent authority, an authorisation as an issuer of asset-referenced tokens, or an e-money licence for e-money tokens, while a pure utility token offer has lighter duties. We classify the asset first and only then design the path.
Describe your crypto business
Tell us what services you provide, where you are incorporated and what authorisation you hold. You will hear back within 24 hours with the route we recommend, a free quote and the lawyer who will handle it.
