CASP Licence in Poland, 2026 Deadline, KNF Timing, Capital Classes and Mica Passporting

The CASP license Poland deadline of 1 July 2026 marks the hard cut-off after which crypto-asset service providers operating under Poland’s legacy VASP register must hold full MiCA authorisation or cease regulated activities. The Polish Financial Supervision Authority (KNF) has confirmed its role as the national competent authority for CASP licensing, and the transitional regime that has allowed registered VASPs to continue operating is now in its final weeks. This guide consolidates the KNF application process and timing, the MiCA capital classes and thresholds, the transitional checklist every operator needs, and the passporting mechanics that follow a successful authorisation.

TL;DR, What Polish Crypto Businesses Must Do Before the CASP License Poland Deadline

• Hard deadline. 1 July 2026, VASPs that have not obtained CASP authorisation (or had an application pending before the cut-off) must stop providing crypto-asset services in Poland.
• Regulator. KNF is the sole competent authority for granting CASP authorisation in Poland.
• Capital readiness. Confirm which CASP service class applies and hold the corresponding permanent minimum capital (ranging from EUR 50,000 to EUR 150,000 depending on the services offered).
• KNF timing. Allow for a completeness check of up to 25 working days, followed by a substantive assessment period of up to 40 working days, though information requests pause the clock.
• Dossier preparation. Assemble governance documentation, AML/CFT policies, IT security and business continuity evidence, proof of capital, and management suitability assessments now.
• Passporting option. Once KNF grants CASP authorisation, the licence can be passported across all EU/EEA member states via notification to ESMA, no additional national licences required.
• Contingency planning. If authorisation is refused or delayed past the deadline, consider applying under another EU member state’s regime or restructuring service offerings to exclude regulated activities.

What Is CASP Authorisation and Who Regulates It in Poland?

From VASP Registration to CASP Authorisation

Before MiCA, Poland regulated virtual-asset service providers through a national register maintained by the Tax Administration Chamber (Izba Administracji Skarbowej). Registration was a relatively light-touch process, focused primarily on AML/CFT compliance and did not impose prudential capital requirements on operators. A CASP licence under MiCA is fundamentally different: it is a full regulatory authorisation that imposes ongoing prudential, governance, conduct-of-business, and consumer-protection obligations on the licence holder.

CASP authorisation covers ten categories of crypto-asset services defined in MiCA, including custody and administration, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution of orders, placing, transfer services, advice, and portfolio management. Any entity providing one or more of these services to clients in Poland, or from Poland into other EU member states, must hold CASP authorisation after the transitional period expires.

Role of the KNF

The KNF has publicly confirmed its supervisory responsibilities in a formal statement, making clear that it will assess and grant, or refuse, CASP authorisation applications. The KNF also oversees ongoing compliance, can impose sanctions, and coordinates with ESMA on cross-border passporting notifications. For operators considering a crypto licence in Poland under MiCA’s 2026 requirements, the KNF’s approach to documentation completeness and management suitability has proven to be rigorous and detail-oriented.

The 1 July 2026 Transitional Regime, Who Can Keep Operating and Until When

Eligibility Under the Transitional Period

MiCA’s transitional provisions, as transposed into Polish law, allow entities that were already providing crypto-asset services under Poland’s national framework to continue operating beyond 30 December 2024 (the date MiCA became directly applicable) and up to 1 July 2026. This transitional regime applies only to entities that were lawfully registered on the VASP register before the relevant cut-off date and that have submitted, or intend to submit, a CASP authorisation application to the KNF.

The KNF statement confirmed that Poland chose not to extend the transitional period beyond the EU default maximum. The practical consequence is that 1 July 2026 is a firm deadline, not an indicative target.

Three Scenarios for Currently Registered VASPs

• Scenario 1, CASP authorised before 1 July 2026. The entity transitions seamlessly to the MiCA regime. All prudential, governance, and reporting obligations apply from the date of authorisation.
• Scenario 2, Application pending on 1 July 2026. Industry observers expect that entities with a duly filed and complete application may be permitted to continue operations while the KNF completes its assessment, provided the application was submitted before the deadline. However, the KNF has not publicly guaranteed uninterrupted operations in this scenario, so operators should seek written confirmation from the regulator.
• Scenario 3, No application filed by 1 July 2026. The entity must cease all regulated crypto-asset services immediately. Continued operations would constitute unlicensed activity under MiCA, exposing the operator to administrative sanctions, potential criminal liability under Polish law, and supervisory action by the KNF.

Any VASP that has not yet begun the application process should treat the remaining time as critically short. Given KNF processing timelines (discussed below), late filers face significant risk that their application will not even reach the substantive assessment stage before the deadline.

KNF Authorisation Process, Timing, Deadlines and Procedural Steps

Application Checklist: Documents and Governance

The KNF authorisation process for a CASP licence in Poland requires a comprehensive dossier. At a high level, the application must include the applicant’s programme of operations, evidence of organisational structure and governance arrangements, proof of minimum capital, detailed AML/CFT policies and procedures, IT security and business continuity frameworks, identification and suitability assessments for shareholders with qualifying holdings, and fit-and-proper documentation for all members of the management body.

Administrative Timeline

The KNF follows a two-stage assessment process. Understanding the timeline is essential for anyone tracking the CASP license Poland 2026 deadline.

Common Deficiencies and How to Avoid Delays

Practical experience from early applications suggests that the KNF frequently identifies deficiencies in three areas: insufficient detail in the programme of operations (particularly around complaint-handling procedures and conflicts-of-interest policies), incomplete fit-and-proper documentation for management board members, and gaps in IT security testing evidence. Each information request pauses the assessment clock, which can push total processing time well beyond the nominal 40 working days. Applicants should treat the dossier as a regulatory examination, not a box-ticking exercise, and engage compliance counsel before submission.

CASP Classes and Capital Requirements, Poland

How MiCA Categorises CASP Services and Sets Capital Floors

MiCA establishes differentiated CASP capital requirements based on the types of crypto-asset services the applicant intends to provide. The regulation groups services into three broad tiers, each with a corresponding minimum permanent capital requirement. These thresholds represent the higher of a fixed minimum amount or a percentage of the entity’s fixed overheads of the preceding year, the so-called “fixed overheads requirement” (FOR).

Capital Calculation: Practical Notes

The fixed overheads requirement is calculated using the most recent audited annual financial statements. For newly established entities without a full year of operations, MiCA allows the use of projected figures from the programme of operations, but the KNF may scrutinise these projections closely. Capital must be held in the form of Common Equity Tier 1 items (CET1), which means share capital, retained earnings, and certain qualifying reserves. Subordinated loans and hybrid instruments generally do not count.

Where an entity provides services falling across multiple classes, the highest applicable capital threshold applies. A firm offering both custody (Class 2, EUR 125,000 floor) and operation of a trading platform (Class 3, EUR 150,000 floor) must meet the Class 3 threshold at a minimum. The likely practical effect is that most full-service crypto businesses will need to budget for Class 3 capital levels, plus a prudential buffer.

Transitional Evidence and Sample KNF Dossier, Practical Checklist

The following items represent the core evidence package that KNF expects to receive as part of a CASP authorisation application. This checklist is not exhaustive but covers the areas where deficiencies are most commonly identified.

• Programme of operations. A detailed business plan covering services to be offered, target markets, revenue model, complaint-handling procedures, and conflicts-of-interest management policy.
• Proof of minimum capital. Audited financial statements or, for new entities, notarised bank statements and capital subscription documents showing CET1 items meet the applicable threshold.
• AML/CFT manual. Full anti-money laundering and counter-terrorist financing policies aligned with Poland’s AML Act and the EU’s AML package, including customer due diligence procedures, transaction monitoring rules, and suspicious activity reporting protocols.
• IT security and business continuity plan. Evidence of penetration testing, incident response procedures, data backup strategies, and disaster recovery arrangements compliant with DORA (the Digital Operational Resilience Act).
• Governance and organisational structure. Organisational chart, board composition, internal control functions, and outsourcing arrangements documentation.
• Fit-and-proper documentation. CVs, criminal record certificates, declarations of good repute, and suitability questionnaires for all management body members and qualifying shareholders.
• Custodian arrangements (if applicable). Agreements with third-party custodians, segregation-of-assets policies, and insurance or guarantee arrangements covering client crypto-assets.
• Trusted profile and eID requirements. KNF electronic filings require a qualified electronic signature or a trusted profile (profil zaufany). This can be obtained through the Polish government’s ePUAP platform, at a local administrative office, or via select Polish banks. Foreign applicants should arrange this well in advance, as identity verification may require in-person steps.

Fees, Operational Cost Considerations and Prudential Buffers

The KNF has not published a fixed schedule of CASP license Poland 2026 fees comparable to those charged by some other EU competent authorities. Administrative fees for authorisation applications are governed by Polish administrative procedure law and are modest relative to overall compliance costs. Early indications suggest that the application fee itself is a fraction of the total expenditure, the real cost lies in dossier preparation, legal advisory fees, capital lock-up, and ongoing compliance infrastructure.

Operators should budget for the following beyond the application fee: external legal and compliance advisory costs for dossier preparation, capital held in CET1 form above the regulatory minimum (a buffer of 10–20 % is widely recommended), annual audit and reporting costs, DORA-compliant IT resilience investments, and ongoing AML/CFT monitoring systems. For a Class 2 or Class 3 operator, total first-year compliance and set-up costs, inclusive of capital, can reasonably be expected to run into six figures in euro terms.

MiCA Authorisation and EU Passporting, Practical Impacts and Scenarios

How Passporting Works Once KNF Authorises a CASP

One of the most significant benefits of obtaining a MiCA CASP license in Poland is the ability to passport services across the entire EU/EEA without obtaining separate national authorisations. Once the KNF grants authorisation, it notifies ESMA, which adds the entity to the public EU-wide register of authorised CASPs. The authorised entity may then provide the services covered by its licence in any other member state, subject to a notification procedure: the CASP notifies the KNF of its intention, specifying the host member states and services, and the KNF communicates this to the relevant host-state authorities.

No additional capital requirements or local-office obligations arise purely from passporting, though host-state conduct-of-business rules and local marketing regulations may apply. For a deeper overview of how the CASP license functions as the new standard for EU crypto compliance, including cross-border implications, operators should review the full MiCA framework.

When Non-Polish CASPs Can Operate in Poland

The passporting mechanism works in both directions. A CASP authorised in France, Germany, Lithuania, or any other EU member state may provide services into Poland under the same notification procedure, without needing separate KNF authorisation.

Reporting and Prudential Obligations by Entity Type

Understanding how obligations differ across the three entity categories, legacy VASP, newly authorised Polish CASP, and foreign CASP passporting in, is essential for compliance planning. The table below summarises the key distinctions.

What to Do If KNF Refuses or Delays, Contingency Options

If the KNF refuses a CASP authorisation application, the applicant receives a formal administrative decision setting out the grounds for refusal. Under Polish administrative procedure law, the applicant may request a re-examination of the decision by the KNF itself (a form of internal appeal) and subsequently challenge the outcome before the Provincial Administrative Court (Wojewódzki Sąd Administracyjny).

Where the KNF delays its decision past expected timeframes, often triggered by multiple rounds of information requests, operators face a difficult interim period. Engaging directly with the KNF case officer to understand outstanding deficiencies is the most effective practical step. Alternatively, entities that hold authorisation in another EU member state may be able to serve Polish clients via the passporting mechanism while pursuing a separate Polish application. Restructuring the business to remove regulated crypto-asset services from the Polish entity, while offering them through a licensed affiliate in another jurisdiction, is a further contingency that some operators have explored.

For operators tracking the broader European picture, the MiCA compliance deadline for crypto businesses across the EU provides additional context on how other member states are handling transitional cut-offs.

Conclusion, 6-Point Compliance Checklist and Next Steps

With the CASP license Poland deadline now imminent, operators should ensure the following six items are either completed or actively in progress:

1. Confirm service classification. Identify which of the ten MiCA crypto-asset services your business provides and determine the applicable CASP class (1, 2, or 3).
2. Verify capital adequacy. Calculate the higher of the fixed minimum and one quarter of fixed overheads; hold qualifying CET1 capital with a prudential buffer.
3. Complete the KNF dossier. Assemble all governance, AML/CFT, IT resilience, and fit-and-proper documentation to KNF standards.
4. File before the deadline. Submit the complete application to the KNF as early as possible, do not wait until the final days before 1 July 2026.
5. Plan for passporting. If you intend to serve clients across the EU, prepare passporting notifications for immediate filing after authorisation.
6. Build contingency routes. Identify alternative licensing jurisdictions and restructuring options in case of refusal or protracted delay.

Operators that treat this process as a strategic project, rather than a last-minute compliance exercise, will be best positioned to secure authorisation and capitalise on the single-market access that a MiCA CASP licence delivers. For guidance on the full application process, costs, and requirements, see our detailed guide to crypto licensing in Poland under MiCA’s 2026 framework, or explore our resources on launching a crypto exchange from inception to regulatory approval.

Sources

1. KNF, Statement of the Polish Financial Supervision Authority
2. Markets in Crypto-Assets Regulation (MiCA), EUR-Lex consolidated text
3. Kancelaria Prawna Skarbiec, MiCA CASP Licence Poland
4. Osborne Clarke, CASP licence in Poland
5. Dudkowiak & Putyra, CASP License in Poland
6. LawFirmPoland, MiCA in Poland: Capital Requirements Guidance
7. Lexology, MiCA Implementation Commentary
8. ESMA, European Securities and Markets Authority