Polish CASP for Crypto Startups: Is a License Suitable? A Strategic Roadmap

However, the introduction of the Markets in Crypto-Assets (MiCA) framework has shifted the goalposts. The old “check-the-box” registration has been replaced by the gradual implementation of a rigorous “CASP” (Crypto-Asset Service Provider) authorisation. 

This change has many entrepreneurs wondering: Is a Polish CASP license still a viable option for crypto startups and young companies?

The Startup Appeal: Why Poland Remains a Top Choice

For a young company, every resource matters. Poland continues to offer a competitive edge for several reasons that specifically benefit the startup ecosystem, especially crypto companies. 

The Talent-to-Cost Ratio

Poland is home to one of the most sophisticated pools of IT and software developers globally. For a crypto startup, finding developers who understand blockchain architecture, smart contracts, and cybersecurity is vital. 

In Poland, you can access this high-tier talent at a significantly lower cost than in traditional hubs like London, Berlin, or San Francisco.

A Strategic Gateway to the EU

Under the new European framework, a license obtained in Poland is no longer just a local permit — it is a “passport.” Once authorised by the Polish Financial Supervision Authority (KNF), a startup can offer its services across all 27 EU Member States. For a small firm looking to scale, this eliminates the need to hire 27 different legal teams to navigate 27 different sets of national laws.

Digitised Infrastructure

Poland’s administrative systems are built for the modern entrepreneur. Most of the initial bureaucracy, including company formation, can be handled electronically. 

The use of qualified electronic signatures (QES) makes it possible for non-resident founders to set up the legal foundation of their business without the need for constant travel.

Related reading: Is It Possible to Establish a Poland CASP Company Remotely?

What Startups Must Know Before Applying

While the benefits are clear, the new regulatory landscape introduces professional responsibilities that can be daunting for a small team. 

Regulatory compliance and legal structuring are essential for startups entering the Polish market, ensuring adherence to national and EU standards such as AML, KYC, and MiCA.

Here is what every founder needs to consider:

• A clear company structure is required to meet licensing requirements and demonstrate transparent governance;
• When planning your application, you must prepare a detailed business plan that outlines your intended crypto services, including portfolio management services, and addresses related tax and operational implications;
• Additionally, you need to clearly define how you will provide crypto asset services in your application, specifying the scope and nature of your planned activities.

The End of the “Ghost Office”

In the past, many crypto startups operated as “letterbox companies” — a registered address in a foreign country with no physical presence. This is no longer possible. A Polish CASP must have its “place of effective management” within the Union.

For a startup, this means you need “substance.” This involves:

• A physical office in Poland, as required by regulations;
• At least one resident director or a high-level manager accessible to the regulator;
• Local compliance and anti-money laundering (AML) functions.

The “Fit and Proper” Assessment by the Polish Financial Supervision Authority

Startups are often led by brilliant young founders, but the regulator will look closely at their background. Every board member must pass a “Fit and Proper” test. You must prove that the people running the company are of good repute and possess the necessary skills and experience. For a small firm, a clean criminal record and a solid professional history are just as important as the code itself.

Related reading: How Much Is a CASP License in Poland

MICA Compliance and Other Regulations

Achieving MICA compliance is at the heart of securing a CASP license in Poland. The Polish regulatory framework is designed to mirror EU standards, ensuring that crypto asset service providers operate within a robust and harmonised legal environment. 

This means that, as a crypto business, you must implement a comprehensive legal framework that covers every aspect of your operations — from risk management to consumer and investor protection.

To meet the requirements for a CASP license in Poland, your company will need to establish clear internal policies and procedures. These should address not only anti-money laundering (AML) and counter-terrorist financing (CFT) obligations, but also set out formal governance structures and operational protocols. 

Effective risk management is a cornerstone of the regulatory framework, requiring you to identify, assess, and mitigate risks associated with crypto asset services.

Consumer and investor protection are also prioritised under MICA compliance. This involves transparent communication with clients, safeguarding client assets, and ensuring fair treatment at every stage of the customer journey. 

Navigating Financial Guardrails and Regulatory Compliance

For any startup, liquidity is the lifeblood of the business. The new European rules mandate specific capital requirements that act as a safety net for consumers. 

In addition to these, startups must meet minimum capital requirements and maintain adequate capital reserves to satisfy regulatory standards and ensure financial stability. 

While costs vary, founders must categorise their business model to understand the capital they need to set aside:

• Class 1 (Advisory/Execution): Best for startups focusing on advice or transmitting orders; this has the lowest capital entry point;
• Class 2 (Exchange/Custody): If you plan to hold user funds or exchange assets, the requirement increases significantly;
• Class 3 (Trading Platforms): Operating a full-scale exchange, such as a crypto exchange, requires the highest level of capital.

A smart startup strategy often involves starting with a narrower scope (Class 1) and expanding as the company grows, rather than depleting the operational runway by aiming for a full exchange license on day one. 

Crypto firms must carefully plan their capital allocation to ensure compliance with regulatory requirements and maintain operational flexibility.

The Documentation Burden: The Biggest Hurdle for Obtaining a Crypto License in Poland

The complexity of a CASP application can be a shock for young companies. You are essentially applying for a financial license that carries the weight of a traditional banking institution. 

Documentation must cover all planned virtual currency activities and clearly define the scope of services as a virtual asset service provider. You will need to prepare:

1. A 3-Year Business Plan: Including realistic financial projections and growth strategies. The plan should detail any crypto-to-crypto services if these are part of your offering;
2. IT Resilience Policies: Detailed plans on cybersecurity, hack prevention, and data protection, including transaction monitoring systems for the detection of suspicious transactions as part of compliance;
3. Custody Protocols: If you hold assets, you must explain how private keys are managed and how you separate client funds from company funds, with a focus on consumer protection and safeguarding client assets;
4. Tailored AML Manuals: These cannot be generic templates; they must be designed specifically for your business model and Polish legal requirements, emphasising the importance of AML compliance and including procedures for reporting suspicious transactions.

After preparing your documentation, you must establish banking relationships to support your operations. 

This includes opening a corporate bank account and working with financial institutions or electronic money institutions, which can be crucial for account onboarding and overcoming banking restrictions often faced by crypto businesses. 

Application Process and Timeline

The journey to obtaining a CASP license in Poland is structured and transparent, but it requires careful planning and attention to detail. The process begins with company formation, where you establish your legal entity and register with the National Court Register. 

Once your company is set up, you’ll need to prepare a comprehensive set of documents, including your business plan, internal policies, and evidence of compliance with MICA requirements.

Your application is then submitted to the Polish Financial Supervision Authority (KNF), the competent authority overseeing crypto asset service providers. The KNF has 25 working days to review your submission and may request additional information or clarifications. 

Once your application is deemed complete, the KNF has a further 40 working days to conduct a qualitative assessment. If further clarifications are needed, the assessment period can be suspended for up to 20 working days.

Given the complexity of the CASP licensing process and the importance of MICA compliance, it is highly recommended to work with a legal team experienced in Polish law and crypto assets regulation, such as LegalBison. 

We can help ensure that your application is thorough, accurate, and stands the best chance of a smooth approval.

Costs and Fees Associated with a CASP License

When planning your entry into the Polish crypto market, it’s essential to understand the full spectrum of costs associated with a CASP license in Poland. 

• The initial application fee can be up to 4,500 EUR (in PLN equivalent), which covers the administrative review by the regulator;
• Once licensed, your company will be subject to an annual supervisory contribution, calculated as a percentage (up to 0.4%) of your average total revenue over the previous three years, with a minimum annual fee of 500 EUR (PLN equivalent).

Beyond these regulatory fees, you should also budget for company formation, documentation preparation, and the ongoing compliance costs required to maintain your CASP license. These may include expenses for legal advisory services, compliance officer salaries, and regular updates to your internal policies to keep pace with evolving regulations. 

The total cost will vary depending on your business model and the complexity of your crypto asset services, so it’s crucial to factor these expenses into your business plan from the outset.

Fully Remote Setup and Flexible Personnel Structuring

One of the standout advantages for crypto businesses seeking a CASP license in Poland is the ability to set up and operate remotely. International founders can complete company registration, submit documentation, and manage the licensing process entirely online, without the need to physically visit Poland. 

Poland also offers flexible personnel structuring, allowing you to appoint directors and AML officers from within the EU or EEA. This flexibility makes it easier to assemble a qualified management team that meets regulatory expectations, regardless of where your key personnel are based. 

However, it’s important to ensure that all appointed individuals possess the necessary qualifications and experience to satisfy the Polish Financial Supervision Authority’s requirements. 

Conclusion

Navigating the shift to a MiCA-compliant authorisation in Poland requires a solid strategy, especially for young projects. At LegalBison, we don’t treat licensing as just another administrative hurdle, but as the bedrock of your company’s future. 

As FinTech legal specialists, we’re here to handle the heavy lifting — from the initial incorporation of your Polish company to crafting internal policies that actually fit the current European regulatory landscape.

We help you tackle the “substance” requirements by finding the right local talent and infrastructure, ensuring you’re ready for regulatory scrutiny without losing your startup’s agility. 

Think of us as your boots on the ground, turning complex regulations into a strategic asset so you can focus on scaling across the EU with confidence and clarity.