How To Obtain A CASP License Under MiCA: A Step-By-Step Guide For 2026

Crypto Market in Poland

Poland is one of the most dynamic fintech and crypto markets in Central and Eastern Europe, combining strong technical talent, a developed financial sector, and competitive operating conditions.

Before the full application of MiCA, Poland ranked among the most active crypto registration hubs in the EU, with 1,175 registered VASPs as of June 14, 2024. Retail awareness of cryptocurrencies reached 94%, reflecting significant market engagement and entrepreneurial momentum.

Since January 2026, crypto-asset service providers operate under the fully harmonised MiCA framework. The former registration model has been replaced by a single CASP authorisation regime, enabling EU-wide passporting and greater legal certainty.

For businesses seeking access to the European market, Poland now offers a regulated, scalable, and MiCA-compliant gateway to the entire EU.

What is a CASP License?

Under the Markets in Crypto-Assets Regulation (MiCA), any entity intending to provide crypto-asset services within the European Union must obtain authorisation as a Crypto-Asset Service Provider (CASP). Since 30 December 2024, MiCA has fully applied to CASPs across the EU, replacing previous national registration regimes.

A CASP authorisation is required for services such as:

• Custody and management of crypto assets for clients
• Operation of crypto asset trading platforms
• Exchange of crypto-assets for fiat currencies or other crypto-assets
• Execution of purchase orders for crypto assets
• Placement of crypto assets on the market
• Receiving and transmitting orders for crypto assets
• Providing crypto-asset advice
• Managing crypto-asset portfolios
• Crypto asset transfer services

A CASP licence granted in one Member State enables passporting of services across the entire European Union without the need for additional local licences.

Since January 2026, crypto-asset service providers operating in Poland function exclusively under the MiCA authorisation framework, benefiting from a harmonised regulatory environment and access to the EU single market.

Services Provided Under a CASP License

A CASP license encompasses a broad spectrum of services related to crypto-assets. These services include:

• Custody and Administration: Ensuring the security and management of clients' crypto-assets and access methods.
• Operation of Trading Platforms: Overseeing systems that enable multiple third-party transactions in crypto-assets.
• Crypto-Fiat Exchange: Facilitating contracts for the purchase and sale of crypto-assets using traditional currencies.
• Crypto-Crypto Exchange: Managing contracts for the exchange of one crypto-asset for another.
• Order Execution: Handling purchase and sale agreements for crypto-assets on behalf of clients.
• Marketing of Crypto-Assets: Promoting and placing crypto-assets in the market to attract purchasers.
• Order Reception and Transmission: Accepting orders to buy or sell crypto-assets and forwarding them for execution.
• Crypto-Asset Advisory: Offering tailored advice on crypto-asset transactions and related services.
• Portfolio Management: Administering and managing crypto-asset portfolios as per client instructions.
• Transfer Services: Facilitating the transfer of crypto-assets between different distributed ledger addresses or accounts on behalf of clients.

The nature of the services offered influences the capital requirements needed to obtain a CASP license.

Eligibility for a CASP License

Entities eligible to provide cryptocurrency services under MiCA include:

1. Companies with a CASP License under MiCA: Typically limited liability or joint-stock companies in Poland.
2. Financial Institutions: Such as credit institutions, central securities depositories, investment firms, market operators, electronic money institutions, UCITS management companies, or alternative investment fund managers, provided they comply with MiCA when offering crypto-asset services.

Criteria for CASP Applicants:

1. Headquarters: Have their registered office in a Member State of the European Union.
2. EU-Based Management: Ensure that effective management and decision-making take place within the European Union.
3. Capital Requirements: Meet the minimum capital thresholds set by MiCA.
4. Documentation: Provide all internal documentation required by MiCA, including operational and risk management plans.
5. Qualified Management: Ensure management board members are reputable and experienced, with clean legal records and relevant skills.

How Does the CASP Licensing Process Look?

The process for obtaining a CASP license involves several steps, each crucial for ensuring compliance with regulatory requirements.

Step 1: Application Submission

The first step is to submit an application to the competent authority in the Member State of establishment. For entities in Poland, this application must be submitted to the Polish Financial Supervision Authority (KNF).

Step 2: Acknowledgement

Upon receiving the application, the authority will acknowledge receipt within 5 working days. This acknowledgement confirms that your application has entered the review process.

Step 3: Completeness Check

Within 25 working days from receipt of the application, the authority assesses whether the application is complete.

If any documents or information are missing, the applicant will be notified and given a specific deadline to provide the necessary additional documentation.

Step 4: Assessment

Once the application is deemed complete, the authority will proceed to assess the content of the documents submitted. This step involves a detailed review to verify that all regulatory requirements are met.

Step 5: Request for Additional Information

During the assessment, the authority may request additional information. In such cases, the assessment period may be suspended until the requested information is provided.

Step 6: Final Decision

The authority shall take a decision within 40 working days from the date on which a complete application is received, resulting in either the approval or refusal of the CASP authorisation.

How Much Does a CASP License Cost?

Obtaining a CASP license involves certain costs and procedural requirements. The estimated cost for the license is €4,500.

Additionally, there may be annual contributions based on the average revenue from crypto-asset services over the last three fiscal years. These contributions can be up to 0.5% of this average revenue, but not less than €750.

What Internal Procedures Are Required for a CASP License Application?

When applying for a CASP license, several internal procedures and documents are necessary, organized into key categories:

Operational and Governance Documentation:

• Program of operations.
• Governance arrangements description.
• Specific documentation for each intended service.

Risk Management and Safeguards:

• Proof of prudential safeguards.
• Internal control mechanisms for risk management, including AML/CTF procedures.
• ICT risk management and operational resilience policies (including compliance with DORA, where applicable).
• Procedure for segregating clients' crypto-assets and funds.

Management and Shareholder Information:

• Proof of management board's good repute and relevant experience.
• Identity and holdings of shareholders with qualifying holdings.

Technical and Customer Service Procedures:

• Technical documentation of ICT systems.
• Complaints-handling procedures.

What Are the Management and Ownership Requirements?

Management Board

Members of the management board must have a solid reputation, necessary skills, and relevant experience. The required documents include:

• A clean criminal record.
• A detailed CV.
• Statements on time commitment and past professional conduct.

Shareholders

Shareholders must also be reputable and free from convictions related to money laundering, terrorist financing, or other offenses. The required documents include:

• A clean criminal record.
• An ownership structure chart.

What Are the Capital Requirements?

The minimum capital required depends on the scope of services offered:

• Class 1 Services: €50,000 for services such as order execution, placement, transfer services, order reception and transmission, advice, and portfolio management.
• Class 2 Services: €125,000 for Class 1 services plus custody, administration, and exchange services.
• Class 3 Services: €150,000 for Class 2 services plus trading platform operation.

By adhering to these requirements, entities can effectively navigate the process of obtaining a CASP license under MiCA, ensuring compliance and the ability to offer crypto-asset services across the EU.

FAQ about obtaining a CASP license

Does a CASP license enable operations only in Poland or other Countries?

A CASP license grants passporting rights, allowing your company to provide the same services across the EU once approved in any member state, without the need for additional licensing.

How long does it take to obtain a CASP License?

The minimum time required to obtain a CASP license is minimum 3 calendar months.

Are there any transactional limitations for CASPs?

No, there are no limitations on the volume or number of transactions conducted by CASPs.

Does a Polish-Licensed CASP require a physical presence in the Host Member State?

CASPs offering cross-border crypto-asset services are not required to have a physical presence in the host Member State within the EU.

What is Reverse Solicitation under MiCA?

Under MiCA, a third-country CASP may provide services to an EU client where the service is provided at the client's own exclusive initiative (reverse solicitation). This exemption is interpreted narrowly and cannot be used to systematically market or provide services within the EU without authorisation.

Can I continue to provide services as a VASP after MiCA comes into force?

No. Transitional arrangements for entities previously registered as VASPs have expired. Since January 2026, only entities authorised as CASPs under MiCA may legally provide crypto-asset services in Poland and across the EU.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.