Short answer: As of October 2026, Poland has no operational domestic KNF route to file a MiCA CASP authorisation. The national Crypto-Asset Market Act is not in force after repeated presidential vetoes and a failed Sejm override, so KNF cannot open Article 63 proceedings. To serve Polish and EU clients today, obtain a CASP in another EEA home state and passport into Poland under Article 65. There is no confirmed published Polish CASP application fee schedule in force.
Poland is still a large crypto market — but the licensing path that founders expect locally does not exist yet. This guide covers cost, requirements and timeline for a MiCA CASP licence Poland strategy: what the old virtual-currency register does (and does not) give you, what EU capital and clocks will apply when a domestic route opens, and how passporting from Estonia or Malta compares. Every figure links to a primary source and is stated as of October 2026.
Does Poland offer a domestic MiCA CASP licence today?
No. MiCA (Regulation (EU) 2023/1114) applies directly, but Member States must designate the competent authority that runs CASP authorisations. Poland has not completed that designation in force.
UKNF stated on 23 June 2026 that the MiCA transitional period under Article 143(3) ends on 1 July 2026, and that — because the implementing act has not entered into force — no Polish public authority, including KNF, has been designated as competent for MiCA supervision of crypto-asset services (with a limited exception for e-money token issuers) (KNF komunikat, updated 23 June 2026).
The parliamentary path remains blocked. The Sejm passed crypto-asset market acts that the President vetoed; the attempt to override the third veto (act of 15 May 2026, veto of 11 June 2026) failed on 4 September 2026 (241 votes for, short of the 266 three-fifths majority). New bills may be pending, but a draft or announcement is not an open filing window.
Poland has no domestic CASP filing desk you can use as of October 2026.
What happened when the MiCA transition ended on 1 July 2026?
The EU-wide transitional period for legacy virtual-asset providers ended on 1 July 2026. Poland's Ministry of Finance told clients on 3 July 2026 that:
- the transitional period under MiCA ended on 1 July 2026;
- entry in the Rejestr Działalności w zakresie Walut Wirtualnych does not authorise activity as a CASP or as a VASP, in Poland or abroad;
- crypto-asset services in the EU may be provided only by entities with a valid MiCA authorisation (gov.pl / Ministerstwo Finansów, 3 July 2026).
KNF relayed the same point from the Tax Administration Chamber in Katowice: a Polish virtual-currency register entry is not a MiCA authorisation and does not allow continued activity after 1 July (same KNF komunikat, as of June 2026).
An old Polish register entry is not a MiCA CASP licence and is not a passport.
How can you serve Polish clients without a Polish CASP?
Use another EEA home state. Under MiCA Article 65, an authorised CASP notifies its home supervisor of the Member States where it intends to provide services, the services, the start date and other non-MiCA activities. The home authority communicates that information to host single points of contact, ESMA and EBA within 10 working days. The firm may start in the host state from the date it is informed that the notification was communicated, or at the latest on the 15th calendar day after submitting the information to the home authority.
KNF's own pre-transition English statement already recognised that CASPs authorised elsewhere can serve Poland under Article 65 even while Poland lacked a designated competent authority and single point of contact (KNF statement PDF). ESMA's MiCA registers may show firms notified into Poland with a home Member State elsewhere — that is passporting in, not a Polish home-state authorisation.
Practical path for founders targeting Poland today:
- Choose a home state with an open Article 62/63 route (for example Estonia or Malta — see Malta vs Estonia for a MiCA CASP licence).
- Build substance, capital and governance for that home regulator.
- After authorisation, file the Article 65 host notification list including Poland.
- Keep Travel Rule, AML and client-asset controls ready for cross-border operations.
What will a Poland home-state CASP cost when the route opens?
Until a domestic act is in force and KNF (or another designated authority) publishes an application schedule, treat "Polish CASP application fee" as unavailable.
There is no confirmed published Polish KNF CASP application fee schedule in force as of October 2026. Draft bills discussed in the legislative process have mentioned figures such as an application fee capped around the PLN equivalent of €4,500 — those numbers are proposed / not in force and must not be budgeted as a live tariff. Prefer the conservative statement: no domestic fee schedule in force.
When (and if) Poland opens an Article 63 route, the capital and statutory clock will still be EU MiCA figures, not Polish inventions:
| Item | Figure | Source (as of) |
|---|---|---|
| Class 1 permanent minimum capital | €50,000 | ESMA MiCA Annex IV / Art. 67, Oct 2026 |
| Class 2 | €125,000 | Same |
| Class 3 | €150,000 | Same |
| Alternative floor | Higher of the class amount or 25% of prior-year fixed overheads | ESMA Art. 67, Oct 2026 |
| Completeness check | 25 working days from receipt | ESMA Art. 63, Oct 2026 |
| Assessment after complete | 40 working days (may pause up to 20 WD on a first information request) | Same |
Class 1 covers order execution, placing, transfer, reception/transmission, advice and/or portfolio management. Class 2 adds custody and/or exchange for funds or other crypto-assets. Class 3 adds operation of a trading platform.
EU capital classes will apply in Poland the same way they apply in Tallinn or Valletta.
Poland home-state vs passport-in vs Estonia and Malta
| Factor | Poland (home-state Art. 63) | Poland (host / Art. 65 passport-in) | Estonia (home) | Malta (home) |
|---|---|---|---|---|
| Domestic route status | Not open — no designated CASP authority in force (Oct 2026) | Open for EEA-authorised CASPs | Open (Finantsinspektsioon) | Open (MFSA) |
| Published application fee | None in force | Home-state fee only; FI states no processing fee for cross-border notification | €3,000 processing (FI, May/Oct 2026) | Class 1 €10,000 / Class 2 €20,000 / Class 3 €25,000 (SL 647.01, Oct 2026) |
| Min capital | MiCA Annex IV (when route opens) | Same MiCA capital at home | Same MiCA classes | Same MiCA classes |
| Statutory clock | Art. 63: 25 + 40 WD (+ pause) when available | Art. 65: home communicates in 10 WD; start by day 15 calendar after submission | Art. 63: 25 + 40 WD | Art. 63: 25 + 40 WD |
| Market access | Full home + future passport out | Serve Poland (and other notified hosts) from foreign home | EU passport after authorisation | EU passport after authorisation |
For a wider fee and capital map beyond the EU, see VASP licence cost: 8 jurisdictions compared. Token projects that need a white paper route rather than a full CASP should start with MiCA white paper notification.
What requirements will a future Polish CASP application need?
Expect the MiCA Article 62 file, not a lighter local checklist. Core pieces (same EU package everywhere):
- legal entity with registered office and programme of operations for the services sought;
- proof of prudential safeguards under Article 67 (own funds and/or qualifying insurance);
- governance, internal control, AML/CFT and business-continuity arrangements;
- fit-and-proper evidence for the management body and qualifying holders;
- ICT and security documentation (DORA-aligned in practice);
- client-asset segregation, complaints handling, and service-specific policies (custody, trading platform rules, exchange pricing, execution, advice/PM competence, transfer).
Local Polish implementing rules will add language, forms, fee payment proofs and any KNF-specific substance expectations — but those details are not law until the act and secondary measures are in force. Do not invent a Polish "office headcount" rule from drafts.
Timeline: what founders should plan for now
Three clocks matter, and only one is usable today.
- Passport timeline (available now). Authorise in an open EEA state, then Article 65 into Poland. Home-state preparation usually dominates (months of substance and drafting). The MiCA assessment clock after a complete file is 25 WD completeness + 40 WD decision, pausable. Host notification itself is days, not months.
- Domestic Poland timeline (not available). There is no statutory Polish CASP clock running because there is no designated authority accepting Article 62 applications. When the law enters into force, the EU 25 + 40 WD framework applies — after secondary rules, forms and fee schedules exist.
- Political timeline (uncertain). Third veto override failed on 4 September 2026; further bills may appear. Do not peg a go-live date to a Sejm calendar rumour.
If your first clients are in Poland this quarter, plan a foreign home-state CASP plus Article 65 — not a Polish KNF filing.
Checklist for a Poland-facing MiCA strategy
- Confirm you need a CASP (services to clients) rather than only a white paper / offer path under MiCA.
- Do not treat a Katowice virtual-currency register entry as ongoing authorisation after 1 July 2026.
- Shortlist home states with live Article 63 processes; compare published fees and substance (Estonia €3,000 processing vs Malta class fees).
- Budget MiCA capital (€50k / €125k / €150k or 25% fixed overheads if higher) plus legal, key persons, ICT and Travel Rule tooling.
- Map Poland as a host Member State on your Article 65 notification list after authorisation.
- Re-check knf.gov.pl / gov.pl before assuming a domestic Polish fee or form exists.
This article is general information, not legal advice. MiCA implementing status, fee schedules and supervisory practice change; verify every figure against KNF, Ministry of Finance, EUR-Lex/ESMA and your counsel before you apply or passport.
Planning a Poland-facing CASP via another EEA home state, or watching for a future KNF route? Book a free 15-minute consultation with OnScale at contact@onscale.org.
FAQ
Can I get a MiCA CASP licence from KNF in Poland today?
No. As of October 2026 Poland has no operational domestic CASP authorisation route because the national Crypto-Asset Market Act is not in force and no competent authority has been designated for ordinary CASP supervision. KNF cannot open Article 63 proceedings until that designation exists in law.
Does a Polish virtual currency register entry equal a CASP or VASP licence under MiCA?
No. The Ministry of Finance and KNF state that entry in the Rejestr Dzialalnosci w zakresie Walut Wirtualnych does not authorise CASP or VASP activity in Poland or abroad after the MiCA transitional period ended on 1 July 2026.
How can I serve Polish crypto clients without a Polish CASP?
Obtain a MiCA CASP authorisation in another EEA home Member State, then notify Poland as a host state under Article 65. You may start after the home authority communicates the notification, or at the latest on the 15th calendar day after you submit the information to your home supervisor.
What is the cost of a MiCA CASP licence in Poland?
There is no confirmed published Polish KNF CASP application fee schedule in force as of October 2026. Draft bills mentioned proposed figures such as up to about EUR 4,500, but those are not live tariffs. When a domestic route opens, EU MiCA capital still applies: Class 1 EUR 50,000, Class 2 EUR 125,000, Class 3 EUR 150,000, or 25 percent of prior-year fixed overheads if higher.
What is the statutory timeline for a CASP authorisation under MiCA?
Under Article 63, the competent authority checks completeness within 25 working days of receipt and then has 40 working days from a complete application to grant or refuse authorisation. A first written information request may pause the 40-day period for up to 20 working days. That clock applies in Member States with a designated authority; it is not running for Polish home-state filings until Poland designates one.
How do Estonia and Malta compare if I passport into Poland?
Both use the same MiCA capital classes and Article 63 clock. Estonia publishes a EUR 3,000 processing fee; Malta publishes Class 1 EUR 10,000, Class 2 EUR 20,000 and Class 3 EUR 25,000 application fees under SL 647.01. After authorisation, Article 65 notification into Poland works the same from either home state.