Nikolai Timofejev
15 years in FinTech and payments. Chooses the home state with you - ČNB or Bank of Lithuania - and leads the file to the decision and the Polish passport, banking included.
Get a crypto license for Poland.
Poland cannot issue its own CASP authorisations - the national act was vetoed three times. The working route in 2026 is a MiCA licence in another EU state passported into Poland, and we run it end to end from our Prague and Vilnius offices.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Crypto licenses obtainedlicenses obtained
Updated
Poland in brief
A huge market with no licence desk of its own.
Poland is the largest crypto market in Central Europe - and, in 2026, the EU's strangest licensing story. MiCA applies directly, but the national Crypto-Assets Act that would let the KNF issue CASP authorisations has been vetoed three times, most recently on 11 June 2026. The UKNF itself confirmed that the 1 July 2026 deadline could not be extended by Polish statute, and ESMA made clear that serving EU clients without a MiCA authorisation after that date is a breach of EU law.
The consequence is simple: you cannot obtain a Polish CASP licence, but you can serve Polish clients in full compliance with a CASP authorised in another member state and passported into Poland under Article 65 of MiCA. That is exactly what we build: authorisation in the Czech Republic or Lithuania from our own offices there, a notification covering Poland, and - for existing Polish VASPs - an orderly redomiciliation instead of a forced wind-down.
The largest crypto market in Central Europe - with a national act vetoed three times, most recently on 11 June 2026. MiCA applies; a Polish licence desk does not exist.
The route: a CASP in the Czech Republic or Lithuania plus an Article 65 passport into Poland. We run both desks from our own offices, and rescue old Polish VASPs.
The working routes
Two ways into the Polish market in 2026.
With no domestic authorisation available, everything runs through MiCA's single market machinery. For new projects that means a home-state authorisation plus a passport notification; for the hundreds of companies from Poland's old VASP register it means moving the business under an EU licence before enforcement catches up.
No Polish desk. A home-state CASP plus an Article 65 notification covers Poland.
01 - PASSPORT ROUTE
EU CASP + Article 65 notification
A CASP authorised in any EU member state may serve Polish clients cross-border after a passport notification - no Polish licence exists or is needed. We authorise you where the desks actually work.
A CASP authorised in any EU member state may serve Polish clients cross-border after a passport notification - no Polish licence exists or is needed. We authorise you where the desks actually work.
- ✓CASP authorisation in the Czech Republic or Lithuania
- ✓Capital by MiCA class - €50,000 / €125,000 / €150,000
- ✓Article 65 notification listing Poland as a host state
- ✓UKNF oversees conduct - your home regulator stays in charge
- ✓Polish-language client communications where required
- ✓Full EU coverage - the same passport opens 27 markets
02 - POLISH VASP EXIT
Deadline passed 1 July 2026Redomicile or wind down properly
Firms from the old Polish VASP register had to stop serving clients by 1 July 2026 unless covered by an EU CASP. We move the business. Clients, assets, contracts. Under a licence, or close it without regulatory damage.
For firms from the old VASP register. Move under an EU licence or wind down properly.
- ✓Gap analysis of your VASP-era operations
- ✓Transfer of clients and crypto-assets to an authorised CASP
- ✓ESMA-grade wind-down plan where you choose to exit
- ✓Restart under a Czech or Lithuanian authorisation
- ✓AML/CFT continuity throughout the transfer
- ✓Defence file for UKNF conduct queries
Costs and timelines are confirmed for your case before any work begins. The passport route prices as a home-state authorisation. Capital €50,000-€150,000 by MiCA class - plus the notification work; government and third-party fees are itemised in your quote.
Why it works this way
What the three vetoes actually mean for your project.
The framework is MiCA (Regulation (EU) 2023/1114), which applies in Poland directly. What Poland lacks. After the Crypto-Assets Act was vetoed on 11 June 2026 for the third time. Is the national plumbing that would let the KNF receive applications and issue authorisations.
✓
MiCA is in force - the desk is not
The regulation binds Poland like every member state, but without the national act the KNF has no procedure to license anyone. Three vetoes. The last on 11 June 2026. Left the country with rules and no counter to file at.Three vetoes (last: 11 June 2026). Rules apply, no counter to file at.
✓
The passport fills the gap
Under Article 65 of MiCA, a CASP authorised anywhere in the EU serves Polish clients after a notification. Lawful, explicit, ESMA-confirmed. Host conduct sits with the UKNF; authorisation stays with your home regulator.Article 65: an EU CASP serves Polish clients after a notification.
✓
1 July 2026 was the cliff
The transitional window closed. ESMA's April 2026 statement is blunt: providing crypto services to EU clients without a MiCA authorisation after this date breaches EU law even where a state failed to implement it.Transition over. Unauthorised service now breaches EU law (ESMA).
✓
The market did not shrink
Millions of Polish users and one of CEE's deepest talent pools remain. While local firms wind down. A passported CASP enters a large market with suddenly thin competition.Millions of users; local firms wound down - competition thinned.
✓
We authorise where desks work
The Czech ČNB (4-6 months, Act No. 31/2025) and the Bank of Lithuania (Newcomer programme, English files) are our home-state desks. With Prifinance offices in Prague and Vilnius running the files.ČNB and Bank of Lithuania. Via our Prague and Vilnius offices.
✓
Polish taxes only if you sit in Poland
Cross-border service does not by itself create a Polish taxable presence. A Polish branch or company pays 19% CIT (9% for small companies); the operating CASP in CZ or LT pays 21% or 17% respectively.Passporting alone creates no Polish taxable presence; 19%/9% if you do.
How it compares
Poland against the working licence desks.
The rulebook is the same MiCA everywhere. The difference is whether a country can actually authorise you. Poland currently cannot, so the comparison that matters is between the home states you would passport from.
Poland vs other jurisdictions
| Feature |  Poland | Other jurisdictions |
|---|---|---|
| Regulatory regime | MiCA direct - national act vetoed ×3 | MiCA with a working licence desk |
| Getting licensed | Not possible domestically | CASP authorisation available |
| Market access | Inbound via Article 65 passport | Home market + passport to 27 states |
| Practical route | Authorise in CZ or LT, notify into PL | Authorise at home |
Regulatory regime
PolandMiCA direct - national act vetoed ×3
Other jurisdictionsMiCA with a working licence desk
Getting licensed
PolandNot possible domestically
Other jurisdictionsCASP authorisation available
Market access
PolandInbound via Article 65 passport
Other jurisdictionsHome market + passport to 27 states
Practical route
PolandAuthorise in CZ or LT, notify into PL
Other jurisdictionsAuthorise at home
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Poland | None - act vetoed, passport in | 19% CIT · 9% small companies | Serve via an EU CASP + Art. 65 |
 Czech Republic | MiCA CASP (ČNB) | 21% CIT, 3-year exemption for individuals | Clear, technical, predictable |
 Lithuania | MiCA CASP (Bank of Lithuania) | 17% CIT · 7% small companies | Engaged regulator, strict AML |
 Estonia | MiCA CASP (Finantsinspektsioon) | 0% retained / 22% on payout | Experienced, demanding supervisor |
PolandLicense typeNone - act vetoed, passport in
Taxation19% CIT · 9% small companies
RequirementsServe via an EU CASP + Art. 65
Czech RepublicLicense typeMiCA CASP (ČNB)
Taxation21% CIT, 3-year exemption for individuals
RequirementsClear, technical, predictable
LithuaniaLicense typeMiCA CASP (Bank of Lithuania)
Taxation17% CIT · 7% small companies
RequirementsEngaged regulator, strict AML
EstoniaLicense typeMiCA CASP (Finantsinspektsioon)
Taxation0% retained / 22% on payout
RequirementsExperienced, demanding supervisor
Before you start
What the passport route into Poland requires.What the passport route requires.
The checklist is a home-state CASP file plus the Polish leg. Nothing here is exotic. It is the standard MiCA package, pointed at the right regulator, with Poland added as a host state.
01
Home-state legal entity. A Czech s.r.o. or Lithuanian UAB with a registered office there.
02
Real substance in the home state. Office, part of management and the compliance function on the ground.
03
Fit & proper management. Clean records and demonstrated competence for directors and shareholders.
04
Share capital - €50,000 / €125,000 / €150,000 by CASP class under MiCA Annex IV.
05
Programme of operations. A three-year plan that explicitly covers cross-border service to Poland.
06
AML/CFT framework. Home-state law, an appointed MLRO, travel-rule readiness.
07
ICT resilience (DORA). Security and continuity arrangements under Regulation (EU) 2022/2554.
08
Safeguarding of client assets. Segregation of client crypto-assets and funds.
09
Article 65 notification. Filed through the home regulator, listing Poland among host states.
10
Polish-facing compliance. Consumer-law and language requirements for Polish clients, marketing rules.
11
No reliance on reverse solicitation. The exemption is narrow and ESMA reads it narrowly; build on the passport, not on loopholes.
01
Home-state entity. Czech s.r.o. or Lithuanian UAB.
02
Real substance in the home state. Office, management, compliance.
03
Fit & proper management. Clean records, competence checks.
04
Share capital - €50k / €125k / €150k by CASP class.
05
Programme of operations. With Poland as a target market.
06
AML/CFT framework. MLRO, policies, travel rule.
07
ICT resilience. DORA security arrangements.
08
Safeguarding. Segregation of client assets.
09
Article 65 notification. Poland listed as a host state.
10
Polish-facing compliance. Consumer law, language, marketing.
Reflects MiCA Articles 59-68 and Article 65 passporting practice as of 2026. If Poland eventually enacts its law, passported CASPs continue seamlessly. The authorisation does not need to be redone.Reflects MiCA Arts. 59-68 and Art. 65 practice, 2026. If Poland enacts its law, passported CASPs continue seamlessly.
How it works
From first call to serving Polish clients.
01
Choose the home state
We map your services to a CASP class, then weigh the ČNB against the Bank of Lithuania on timeline, capital and supervision style, and fix the route in writing.Service map → CASP class → ČNB or Bank of Lithuania, fixed in writing.
02
Entity and application file
Czech s.r.o. or Lithuanian UAB, class-appropriate capital, and the full MiCA package: business plan, AML/CFT, DORA, safeguarding. With Poland written in as a target market.s.r.o. or UAB, capital, full MiCA package with Poland written in.
03
Home regulator review
The statutory clock - 25 working days for completeness, 40 for assessment - plus Q&A rounds we answer for you.25 + 40 working days plus Q&A. We answer every query.
04
Passport into Poland
The Article 65 notification goes through your home regulator and Poland joins your service map; UKNF oversees conduct while authorisation stays at home.Article 65 notification; UKNF oversees conduct, home desk keeps authorisation.
05
Launch and ongoing compliance
Polish-language client flows, consumer-law compliance, reporting, DAC8 and travel-rule plumbing. We keep it healthy while you grow.Polish client flows, reporting, DAC8 and travel rule.
Quick facts
Polish CASP deskNone - act vetoed
RouteEU CASP + Art. 65
Home states we useCzech Rep. · Lithuania
Timeline incl. passport4-7 months
Capital€50k / €125k / €150k
Host supervisorUKNF (conduct)
Wind-down deadline1 July 2026 - passed
Client commsPolish where required
If the Polish act is eventually adopted, passported CASPs continue without re-authorisation. The route is future-proof by design.
On the ground in Poland
Run from our Warsaw office.
Prifinance - Poland
Warsaw · Poland
Warsaw, Poland
01
Choosing the home state
Czech ČNB or Bank of Lithuania. We scope your services, capital and timeline against both desks and recommend one in writing.ČNB vs Bank of Lithuania. A written recommendation.
02
The authorisation itself
Company formation, the full MiCA file and the regulator dialogue. Run by our Prague and Vilnius teams, the same ones behind our other CASP mandates.Entity, MiCA file and regulator dialogue. Prague and Vilnius teams.
03
The Polish leg
Article 65 notification listing Poland, Polish-language client documentation, consumer-law and marketing review for the local market.Art. 65 notification, Polish-language docs, consumer-law review.
04
VASP rescue work
For firms from the old Polish register. Client and asset migration under an EU licence, or a defensible ESMA-grade wind-down.Migration under an EU licence - or a defensible wind-down.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Dubai
UAE
33 Level, Al Saqr Business Tower
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Good to know
Taxation around the Polish crypto market.
Where you pay depends on where the operating company sits. Cross-border service under a passport does not by itself create a Polish taxable presence, but a Polish branch, company or team does, so the structure is a tax decision as much as a legal one.
Polish CIT: 19% / 9%
A Polish company or branch pays 19% corporate income tax, with a 9% rate for small taxpayers up to €2 million of revenue. Crypto gains of companies fall under the standard regime.19% standard; 9% for small taxpayers up to €2M revenue.
Individuals: 19% flat
Polish residents pay a flat 19% on crypto-to-fiat gains under the PIT Act, and crypto-to-crypto exchanges are expressly tax-neutral, a rule many EU states still lack.Crypto→fiat gains; crypto↔crypto is expressly tax-neutral.
Solidarity levy 4%
Annual income above PLN 1 million attracts an additional 4% solidarity levy. Worth modelling before founders take large gains personally.On annual income above PLN 1 million.
VAT-exempt exchange
Exchanging crypto for fiat is VAT-exempt across the EU under the ECJ's Hedqvist ruling (C-264/14); Polish practice follows it.Hedqvist (C-264/14): crypto ↔ fiat exchange is VAT-exempt.
Home-state taxes for the CASP
The operating company pays where it is authorised: 21% CIT in the Czech Republic or 17% (7% small companies) in Lithuania. Often the decisive argument in the route choice.21% CZ or 17% (7% small) LT. Often decides the route.
DAC8 from 2026
EU-wide crypto reporting under DAC8 applies from January 2026 and reaches Polish clients of any passported CASP. We build the flows in from day one.EU-wide crypto reporting reaches Polish clients of any CASP.
Tax summary
Polish CIT19% · small 9%
Personal crypto rate (PL)19% flat
Crypto ↔ crypto (individuals)Tax-neutral
Solidarity levy4% over PLN 1M
VAT on crypto exchangeExempt
CASP home-state CIT21% CZ · 17% LT
DAC8 reportingfrom 2026
*Figures as of 2026. The split between Polish and home-state taxation follows your structure. We model it before you commit.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from choosing the home state and building the application to the Article 65 notification and ongoing compliance - with in-depth MiCA expertise and an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: the entity, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, passported CASP.
Follow Prifinance
Active across our channels.
Poland · MiCA passporting
Serve the Polish market with an EU CASP licence.
Full-service assistance - home-state authorisation, the Article 65 notification and Polish-facing compliance.
Get a consultation →Free legal opinion
Is the passport route the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which home state, CASP class, or rescue route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
Crypto licensing for Poland - the questions we hear.
Can I get a Polish CASP licence?+
No. The Polish Crypto-Assets Act - the law that would let the KNF issue CASP authorisations - was vetoed for the third time on 11 June 2026. Until a version is enacted, no domestic authorisation exists to apply for.
Does MiCA apply in Poland at all?+
Yes, directly. MiCA is an EU regulation and binds Poland without national implementation. What is missing is only the national procedure for issuing licences - the obligations, including the ban on unauthorised services, are fully in force.
What happened on 1 July 2026?+
The MiCA transitional period ended. ESMA and the UKNF both confirmed the deadline could not be extended: firms from the old Polish VASP register without an EU CASP authorisation had to stop serving clients and execute wind-down plans.
How do I serve Polish clients legally then?+
With a CASP authorised in another EU member state and an Article 65 passport notification listing Poland as a host state. Your home regulator remains in charge of the authorisation; the UKNF oversees local conduct.
Which home state should I choose?+
We run two desks: the Czech ČNB - technical, predictable, 21% CIT, and the Bank of Lithuania - Newcomer programme, English files, 17%/7% tax. The right answer depends on your service mix; the written comparison is part of our free opinion.
How long does the whole route take?+
The home-state authorisation runs 4-7 months in practice (the statutory clock is 25 + 40 working days); the Polish passport notification adds weeks, not months, and can be prepared in parallel.
Do I need a Polish company or office?+
Not for cross-border services under the passport. A Polish branch is optional - it helps with local hiring and marketing but creates a Polish taxable presence, so we model it before you commit.
I ran a Polish VASP. What now?+
Two real options: redomicile - move clients, assets and contracts under a Czech or Lithuanian CASP and continue serving Poland via the passport - or wind down properly with an ESMA-grade plan. Doing nothing risks enforcement and personal liability.
Can I rely on reverse solicitation instead?+
No. The exemption covers only services a client requests entirely on their own initiative, is read narrowly by ESMA, and collapses the moment you market anything. It is a defence for edge cases, not a business model.
What if Poland finally adopts the act?+
Nothing breaks. A passported CASP continues seamlessly - MiCA authorisations are EU-wide by design. You would simply gain the option of dealing with a local desk; re-authorisation is not required.
Can I get a Polish CASP?+
No - the act was vetoed three times, most recently 11 June 2026. No domestic desk exists.
Does MiCA apply in Poland?+
Yes, directly - obligations included. Only the licensing procedure is missing.
What happened on 1 July 2026?+
Transition ended; VASP-register firms without an EU CASP had to stop and wind down.
How do I serve Polish clients?+
An EU CASP + Article 65 notification listing Poland. UKNF oversees conduct only.
Which home state?+
ČNB (technical, 21% CIT) or Bank of Lithuania (Newcomer, 17%/7%). We compare in writing.
How long does it take?+
4-7 months for the authorisation; the passport adds weeks, prepared in parallel.
Do I need a Polish company?+
Not for cross-border service. A branch is optional and creates taxable presence.
I ran a Polish VASP - what now?+
Redomicile under an EU CASP or wind down properly. Doing nothing risks enforcement.
Reverse solicitation instead?+
No - it is narrow, ESMA reads it narrowly, and it dies the moment you market.
What if Poland adopts the act?+
Nothing breaks - passported CASPs continue seamlessly; no re-authorisation.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which home state, CASP class, or rescue route fits your business.Free legal opinion: which home state and route fit your project and what it will cost.
✓Written legal opinion within 2-5 business days - free of charge✓A clear recommendation on the home state, not a sales pitch✓Transparent fixed fees, confirmed up front✓EN · RU · ES speaking team
Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the KNF/UKNF, the ČNB, the Bank of Lithuania or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.