VASP Registration in Poland: Requirements & Timeline [2026]

VASP registration in Poland means an entry in the national "register of activities in the field of virtual currencies," maintained by the Director of the Tax Administration Chamber in Katowice under the 1 March 2018 AML Act. In 2026 that register is closed to new entrants, and Poland cannot yet grant the MiCA CASP licence intended to replace it.

If you arrived here looking for a clean "how to register a VASP in Poland" walkthrough, the honest answer in 2026 is different from what most older guides still promise. Poland sits in a legislative deadlock. The old route is shut to newcomers, the new route is not yet operational, and the country is at risk of missing a hard EU deadline. This page keeps the two regimes strictly separate, explains exactly who runs each one, sets out the historical requirements and timeline, and walks through why the future licensing route remains blocked. It closes with responsible alternatives in other EU jurisdictions.

By Magnus Müller · Reviewed by Magnus Müller · Last updated: 2026-06-14

Can you register a VASP in Poland in 2026? (Short answer)

No. As of 2026 you cannot register a new Polish VASP and you cannot obtain a Polish MiCA CASP licence. New entries to the Katowice "virtual-currency register" stopped around the point where MiCA became fully applicable EU-wide (≈30 December 2024), and the future CASP route is not operational because Poland's implementing act has been vetoed three times and is not in force.

The honest 2026 position

Neither path is open to a new applicant right now. The old Katowice register no longer admits new entrants, and KNF, the regulator intended to authorise crypto-asset service providers under MiCA, cannot lawfully grant a single CASP authorisation until Poland passes a national Crypto-Asset Market Act. The popular "register in 4 to 6 months" pitch you may have read elsewhere is not deliverable in Poland under current conditions. The realistic options are to wait for the act to pass or to license in another EU Member State where the route is live.

Poland's two crypto regimes, kept separate

The single biggest source of confusion about Poland is that two completely different regimes get merged into one. They have different authorities, different legal bases and different requirement sets. Treating them as one is the central error in most outdated guidance, so the rest of this page keeps them apart.

The old "virtual-currency register" (Katowice tax administration)

The historical Polish "VASP" route is an entry in the register of activities in the field of virtual currencies (rejestr działalności w zakresie walut wirtualnych). It is maintained by the Director of the Tax Administration Chamber in Katowice (Dyrektor Izby Administracji Skarbowej w Katowicach), with the legal basis sitting in Articles 129m–129z of the Polish AML Act of 1 March 2018. Note carefully: this register is run by the tax administration, not by KNF. That distinction matters because the query "KNF VASP registration" carries a false premise, KNF never ran the old register.

The new MiCA CASP regime (KNF as intended NCA)

The forward-looking route is a CASP authorisation under MiCA, Regulation (EU) 2023/1114, with KNF (Komisja Nadzoru Finansowego) intended as Poland's national competent authority. The key word is intended. KNF cannot exercise CASP powers until a national implementing act designates it and gives it statutory authority. Because that act is not in force, the MiCA CASP regime is not yet operational in Poland.

VASP vs CASP in Poland: which is which

For a deeper treatment of the distinction across the EU, see the difference between a VASP and a CASP. Mapped to Poland specifically:

Old VASP register requirements (historical, closed to new entrants)

The old register is the regime that actually had concrete, statutory rules, so it is where the word "requirements" genuinely applies. We set these out for context, since the register no longer admits new entrants. Crucially, it imposed no MiCA-style minimum capital, no EU-resident director requirement and no KNF authorisation. Those belong to the CASP regime described below.

Activities covered by the register

The register covered the virtual-currency activities defined in Art. 2(1)(12) of the AML Act: exchange between virtual currencies and means of payment; exchange between virtual currencies; intermediation in such exchange; and maintaining accounts (wallets). A business performing any of these activities in Poland historically needed an entry in the register before operating.

Statutory conditions for officers and beneficial owners

The statutory conditions attached to a register entry were comparatively light. The entity's officers and beneficial owners needed a clean criminal record for AML-relevant offences, plus documented knowledge or experience in virtual-currency activity (Art. 129m–129z, AML Act). There was no fit-and-proper licensing review of the kind MiCA introduces.

What the old register did NOT require

This is where most outdated guidance goes wrong. The old Katowice register did not require:

• A minimum capital amount.
• An EU-resident or Polish-resident director.
• A Polish-speaking MLRO.
• A KNF authorisation.

Anyone presenting MiCA capital tiers or an "EU-resident director" as the live Polish VASP requirement is conflating the two regimes. The capital tiers are genuinely MiCA's, but they were never part of the Katowice register.

How the old register worked: application, fee and timeline

For the historical register, the process and timeline were straightforward. We present these strictly as historical facts, since new applications are no longer accepted.

• Application: submitted electronically only, via the e-PUAP platform, using one of four form types (registration, change, suspension, deletion).
• Processing time: entry made within 14 days of a complete application with the required declaration.
• Fee: 616 PLN, paid on submission to the indicated PKO BP account.

e-PUAP application and the 14-day entry

Applications ran exclusively through e-PUAP, Poland's electronic public-administration gateway, with no paper route. Once a complete application and the required declaration were filed, the Katowice authority entered the business within 14 days. This was an administrative registration, not a discretionary licensing decision.

The 616 PLN fee and where it was paid

The single statutory fee was 616 PLN, paid on submission to a designated PKO BP account. Because the register sits under the tax administration rather than a financial regulator, the fee and authority structure reflect that administrative, rather than supervisory, character.

The MiCA CASP route (for context, not yet available in Poland)

Many searchers half-expect a future-licence answer: what would a Polish CASP licence require once the act passes? We set out the MiCA-level picture here for context, clearly marked as aspirational rather than live. None of it is currently obtainable in Poland.

MiCA-level requirements (EU-wide context)

Under MiCA, a CASP authorisation broadly requires a legal entity with a registered office in the EU, fit-and-proper management, an AML/CFT program, and governance, custody and segregation, ICT and operational resilience, complaints-handling and conflicts-of-interest policies. MiCA also sets minimum capital by class. For the full framework, see the MiCA regulation. These figures should be confirmed against the regulation text itself before being relied on (VERIFY against Regulation (EU) 2023/1114, see Open questions).

Draft Polish CASP fees (from the unsigned act)

The draft Polish act reportedly set an application fee of around €4,500 and an annual fee from year two of 0.4% of average revenue, with a minimum of about €500. These figures are draft only and not in force, because the act has not been signed. Treat them as indicative of legislative intent, not as a live cost.

Why Poland cannot license CASPs yet: the three vetoes

Poland's inability to authorise CASPs comes down to a single, dated narrative: the implementing act has been vetoed three times. The Crypto-Asset Market Act was vetoed by President Karol Nawrocki around 1 December 2025, again on 12 February 2026, and a third time around 11 to 12 June 2026. On the third veto he said parliament had incorporated "only one out of 16" of his proposed modifications, adding: "A bad law passed a hundred times is still a bad law."

What President Nawrocki objected to

The stated objections across the vetoes were consistent: that KNF was given excessive powers; that a website-blocking provision was "opaque and potentially open to abuse"; that regulatory fees would "prevent small businesses and startups from developing"; and that the bill ran to more than 100 pages, against roughly a dozen in the Czech Republic, Slovakia and Hungary. The criticism was directed at the design of the act, not at MiCA itself.

The override that never happened (3/5 majority)

The Sejm adopted versions of the act repeatedly and sent them back through the Senate, but it never assembled the three-fifths majority needed to override the veto outright. Repeated adoptions without a successful override mean there is still no law in force. The result is a deadlock: parliament wants the act, the President will not sign it, and the votes to bypass him are not there.

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Timeline to the 1 July 2026 MiCA cliff

The whole Polish situation runs against a fixed EU clock. Below is the dated chronology, from the register opening through the three vetoes to the transitional deadline.

Key dates at a glance

• 31 October 2021: the virtual-currency register opened, with e-PUAP-only applications.
• 30 December 2024: MiCA's CASP regime became fully applicable EU-wide; new entries to Poland's old register stopped around this point.
• December 2025 / 12 February 2026 / ~11 June 2026: three presidential vetoes of the Crypto-Asset Market Act.
• As of 13 June 2026: no act in force; KNF cannot issue CASP licences; Poland is at risk of missing the 1 July 2026 deadline.
• 1 July 2026: the hard EU deadline (see below).

The 1 July 2026 transitional cliff (Art. 143(3) MiCA)

Under Art. 143(3) MiCA, entities that lawfully provided crypto-asset services under national law before 30 December 2024 may continue only until 1 July 2026, or until a MiCA authorisation is granted or refused, whichever is earlier, and Member States may shorten this window. The same date is the deadline by which Member States must have designated their NCA. For the EU-wide picture, see the MiCA transition deadline. Poland reaching that date without a national act means existing operators run out of grandfathered cover with no domestic licensing route to step into.

What this means for existing Polish VASPs and new applicants

The consequences differ depending on whether you already hold a register entry or are coming to Poland fresh.

Existing register entrants: the transition cliff

Existing Polish VASP-register entities have been operating under MiCA's grandfathering window. Without a national act, KNF cannot grant them CASP authorisations, so they face the 1 July 2026 cliff with no domestic route forward and lose, or never gain, MiCA passporting. Analysts note that operators may freeze growth or relocate, with France, Germany and Malta named as destinations.

New entrants today: no available Polish route

For a brand-new applicant the position is simpler and harder. The register is closed to new entrants and no CASP authorisation can be issued, so there is no Polish route to start today. Because no Polish CASP authorisation is obtainable, EU passporting via a Polish licence is also unavailable.

Where to register a VASP or get a MiCA CASP licence instead

Because Poland is currently a dead end for new licensing, the sensible move is to consider EU Member States where the route is live. We name these as alternatives for orientation, not as recommendations to be acted on without per-jurisdiction confirmation.

EU jurisdictions with operational CASP routes

Other Member States with operational NCAs, such as France, Germany, Malta and Lithuania, can grant MiCA CASP authorisations today, although you should confirm the current status of each before deciding. If your starting point is a register-style entry rather than a full CASP licence, the neighbouring routes are worth comparing: see VASP registration in Lithuania and Estonia's updated VASP route. To weigh options side by side, compare VASP routes by country. For the underlying VASP framework, start with how to become a licensed VASP.

How a Swiss/Crypto-Valley advisor approaches the choice

From our practice, the questions that decide jurisdiction are rarely about a headline timeline. They are about which activities you actually perform, where your customers sit, whether you need EU passporting on day one, and how much regulatory change you can absorb. A jurisdiction in legislative limbo, like Poland in 2026, fails on the last point regardless of how attractive its draft fees look. We work through those trade-offs from Zug, in Switzerland's Crypto Valley, and frame Poland honestly: a market worth watching for re-entry once the act is in force, but not a place to start a new application today. For the Polish KNF and country-overview angle specifically, see our Poland crypto licensing overview (KNF).