VASP License in Poland | Guide to Polish Crypto License

Updated: 11.02.2026

Crypto status in Poland

Since MiCA came into force on December 30, 2024, it is no longer possible to register new Companies in the Register of virtual currency activities. Currently Poland is awaiting its own act regulating the cryptocurrency market that will implement MiCA into the Polish legislative landscape.

VASP’s registered in 2024 and before can make use of the MiCA transitionary period and perform their services up until July 1st, 2026, or up until their MiCA application is accepted/rejected (whichever happens first).

Companies wishing to start their crypto-business venture in Poland in 2026 can either:

• purchase existing Company entered in the VASP register, and take advantage of the MiCA grace period,
• start working towards a cryptoasset service provider (CASP) license under MiCA in Poland, to be ready as soon as the Polish cryptoasset market act comes into force.

Registered VASP (virtual asset service provider) can provide the following services:

• exchange between virtual currencies and FIAT money (for example EUR to BTC or BTC to USD),
• exchange between virtual currencies (for example BTC to ETH),
• intermediation in exchange indicated in a – b above,
• custody services (providing crypto wallets).

Benefits to starting cryptoassets venture in Poland

Poland remains a compelling jurisdiction for launching a crypto venture in 2026 despite the temporary closure of the VASP register. It offers a large and increasingly crypto-aware consumer base, a deep pool of tech talent, and a well-developed fintech and payments ecosystem, which together create favourable conditions for scaling both retail and B2B crypto services.

For investors, the key advantage today is timing. By entering the market now, either through acquiring a company already in the VASP register or by building a MiCA ready compliance and operating model, you can secure early mover positioning and shorten the runway to full CASP authorisation once the Polish Crypto Assets Act becomes effective. In practical terms, this means using 2026 to set up corporate governance, AML and CTF and safeguarding frameworks, product documentation and customer flows, and institutional partnerships, so that the business can move from the transitional regime to a fully licensed MiCA model with minimal disruption and strong credibility with clients, banks, and counterparties.

As per Fintech Foundation report of 2023, the Polish FinTech ecosystem, though relatively young, is already well-developed and set for further growth. Poland is the biggest financial services market in CEE which will likely allow it to attract talent and investment from the entire region. Macroeconomic forecasts show space for future growth. 

As of January 13, 2026, there are 1,298 entities actively registered VASPs in the Register of virtual currency activities. Not all crypto companies are operational though.

Difference between VASP and CASP license

Under MiCA (in force since December 30, 2024), those companies, who wish to provide services related to cryptocurrency will need to obtain a CASP license to legally operate in the EU.

A cryptocurrency exchange license is essential for those looking to start a crypto exchange, as it ensures compliance with regulatory requirements and enhances business credibility.

Entities that have not engaged in cryptocurrency activities until December 30, 2024, will have to apply for CASP license before they start operating. Current VASPs (entities registered in Register of virtual currency activities) will be allowed to provide services under VASP license during the grace period – until July 1, 2026.

CASP license will enable passporting rights, so once the applicant is approved in one member state, then your company can provide the same services across the EU without added licensing.

CASP license will be required for the following services:

• providing custody and management services for crypto assets on behalf of clients,
• managing a trading platform for crypto assets,
• exchanging crypto-assets for FIAT currencies,
• exchanging crypto-assets for other crypto-assets,
• executing purchase orders for crypto assets,
• placement of crypto assets on the market,
• accepting and transmitting orders for crypto assets,
• providing advice on crypto-assets,
• managing a portfolio of crypto-assets,
• providing of crypto asset transfer services.

Detailed information on the CASP license is available under this link.

What are the requirements for VASP’s in Poland?

Companies already entered in the register of virtual currency activities that intend to continue conducting business involving virtual currency transactions must comply with the specific requirements applicable to crypto-asset trading authorisations:

• no criminal record requirement,
• professional qualifications requirement.

Only entities that continuously satisfy both of the above-mentioned requirements may retain their entry in the register of activities in the field of virtual currencies. It should be noted that these conditions must be met at all times by all members of the management board and all beneficial owners, including individuals who were previously associated with the VASP.

Our Law Firm conducts dedicated training sessions culminating in obtaining a relevant certificate, which may constitute evidence of possessing the required knowledge in the field of crypto-assets.

VASP obligations under Polish law

If the company conducts business activity as a virtual currency service provider, it shall perform several specific obligations established in Polish law, in particular it shall:

• identify and assess the money laundering and terrorist financing risks relating to its activities,
• perform the financial security measures especially:
  • customer identification and verification of identity,
  • identification of the real beneficiary and taking reasonable steps to:
    • assessment of business relations and, as appropriate, obtaining information on their purpose and intended nature,
    • ongoing monitoring of the customer’s business relations,
• introduce an internal procedure for counteracting money laundering and terrorist financing,
• notify Polish authorities about the particular transactions,
• cooperate with Polish authorities in a case of crime suspicion,
• report to the General Inspector of the Financial Information quarterly on the VASP activity.

What are VASP reporting obligations in Poland?

Virtual asset service providers (VASP) in Poland are subject to mandatory reporting of quarterly statistical data to GIIF via a designated portal. Reports shall be submitted on a quarterly basis within 18 days of the end of the quarter.

Sanctions for violation of the crypto-business obligations under Polish law

In the case of improper performance or non-performance of the post-registration crypto-business obligations, there might by imposed administrative penalties by Polish authorities, covering in particular:

• publication of information about the entity and it’s illegal activity in the Public Information Bulletin on the website of the office servicing the Minister of Finance,
• an order to cease specific actions by the entity,
• deletion from the register of activities in the field of virtual currency,
• prohibition of performing duties in a managerial position by a person responsible for a, for a period not longer than one year,
• financial penalty, which shall be imposed up to the amount of twice the amount of the benefit gained or the loss avoided by the entity as a result of the infringement or – if the amount of this benefit or loss cannot be determined – up to the equivalent of EUR 1,000,000.

In addition, a person acting for or on behalf of the entity, which fails to notify Polish authorities about crime suspicion or provides false or conceals true data concerning transactions, accounts or persons, shall be punished by imprisonment from 3 months to 5 years.

What to look for while purchasing a VASP?

Acquiring a Virtual Asset Service Provider (VASP) requires a deep dive into regulatory compliance and corporate governance. Before closing the deal, your due diligence must go beyond financials to ensure the entity is in good standing with the law and operational requirements.

Key areas to verify include:

• Board Members and UBOs: Strictly verify the background of all Board Members and Ultimate Beneficial Owners (UBOs). You must confirm that they meet the statutory requirements regarding competence, meaning they possess the necessary education or practical experience in the crypto-asset sector. Additionally, ensure they have a clean criminal record, particularly regarding financial crimes or money laundering.
• Regulatory Responsiveness: Investigate the VASP’s history of communication with regulatory bodies. It is crucial to verify if the entity promptly responds to official summons and inquiries from the authorities, as any history of negligence here is a major red flag.
• Reporting Obligations: Audit the company’s compliance track record. Verify whether the VASP consistently meets its periodic reporting duties (e.g., to the Financial Intelligence Unit) and if all required AML/CFT (Anti-Money Laundering/Counter-Terrorist Financing) filings are up to date.

Navigating these strict requirements is critical for a secure investment and a smooth transition of ownership. We support clients in performing comprehensive pre-acquisition due diligence, verifying both the legal standing of the VASP and the statutory qualifications of its management. Our team ensures the target entity is fully compliant and responsive, mitigating the risk of license revocation or regulatory penalties after the purchase.

Crypto & VASP in Poland – Q&A