How to Get a MiCA License in Poland: Complete 2025 Guide for Crypto Businesses

(Updated: May 2025)

Introduction With the EU’s Markets in Crypto-Assets Regulation (MiCA) taking effect across the European Union, Poland is on track to become one of the first countries to implement detailed national procedures for crypto-asset service providers (CASPs). This article provides a comprehensive overview of what crypto exchanges and other CASPs need to know in order to operate legally in Poland in 2025.

This guide reflects the most recent Polish legislative and regulatory materials available as of 15 May 2025, including the delegated regulations, fee schedules, reporting formats, and post-consultation updates.

1. What Is MiCA and Who Needs a License? MiCA (Regulation EU 2023/1114) is the EU-wide framework for regulating crypto-assets that are not already covered by financial instruments legislation (like MiFID II). Under MiCA, any company that wants to offer crypto services like exchange, custody, transfer, or portfolio management must apply for a license from the national authority of their home Member State.

In Poland, the supervisory authority will be the Polish Financial Supervision Authority (KNF).

Who Needs to Apply:

• Crypto exchanges (spot markets)
• Custodians and wallet providers
• Brokers and order-execution platforms
• Crypto-fiat payment facilitators

2. Application Deadlines and Transition Period

Poland has chosen to shorten the EU-wide transition period:

• 30 June 2025 is the last day existing Polish VASPs (registered under AML law) can operate without a MiCA license.
• To continue operating legally, VASPs must submit a complete application to the KNF by 1 May 2025.
• If accepted for review, the company may continue operating until a decision is made (but no later than 30 September 2025).

If you are not currently operating, you must wait until the license is granted to begin business.

3. Licensing Requirements

The Polish draft law and accompanying May 2025 regulations specify the following:

Organizational:

• Registered legal entity in Poland or another EU country
• Polish or EU-resident management
• Identified directors and compliance officer

Capital Requirements:

• Fixed capital from EUR 50,000 to EUR 150,000, depending on service category

Internal Policies:

• AML/CFT program (aligned with AMLD5 and MiCA)
• Internal control and governance framework
• Business continuity and ICT risk framework
• Complaint handling procedures (aligned with Polish consumer law and MiCA Art. 71)

Technology and Recordkeeping:

• Secure document archiving compliant with Art. 3 regulation
• Timestamped, integrity-protected transaction and user records

Staff Competence Requirements:

• Minimum qualification criteria for personnel who communicate with clients
• Training and evaluation obligations every 12 months

Reporting Obligations:

• Reports to KNF: quarterly, semiannual, annual, and ad-hoc current reports
• Accounting under dedicated crypto service provider regime (Art. 81)
• Disclosure of capital adequacy and outstanding token obligations

4. Application Fee and Supervisory Levy

Application Fee:

• EUR 4,500, payable within 14 days after license grant (in PLN equivalent)

Annual Supervisory Levy:

• CASPs: up to 0.4% of revenue, minimum EUR 500
• Issuers: up to 0.5% of token liabilities
• KNF will publish exact levy rates by 31 October each year

5. Required Documents for Application

• Legal and ownership structure of the firm
• Business plan with financial forecasts
• AML/CFT, internal control, ICT, and training policies
• Draft client documentation (contracts, disclosures)
• Proof of capital and liquidity buffers
• Staff profiles and knowledge validation

6. Timelines and Enforcement

Once the final act and delegated regulations are published in the Dziennik Ustaw, they will enter into force 14 days later. From that point:

• KNF will begin officially accepting applications
• Any CASP operating after 30 June 2025 without a valid MiCA license risks enforcement

7. Additional Regulatory Updates (May 2025)

• The Polish act includes delegated rules on:
  • Electronic document standards (Art. 3)
  • Professional staff requirements (Art. 4)
  • Rules for pledging and blocking crypto-assets (Art. 12)
  • Regular and current reporting obligations (Art. 23)
  • CASP-specific accounting practices (Art. 81)
  • Application fee and levy mechanics (Art. 84)
• Rules for online currency exchanges (kantory internetowe) are now included under Art. 142–158 and will be supervised by KNF.

Conclusion If you are planning to operate a crypto business in Poland or across the EU, obtaining a MiCA license in Poland could provide you with passporting rights across the entire EU. However, the Polish procedure involves specific rules, fees, and deadlines that must be taken seriously.

As of 15 May 2025, the legislative process is nearly complete, and the MiCA framework is expected to enter into force by June 2025. Now is the time to prepare your application, internal systems, and compliance framework.