Poland CASP Passporting: The Practical Route (2026)

Poland is one of the EU’s largest crypto audiences, and most operators with European ambitions want it. So the question we hear constantly is a simple one: “How do I get a Polish crypto licence?” The honest answer surprises people. As of mid-2026 you can’t get one directly — not because the KNF refuses, but because the national law that would let it open the application window has stalled.

In our practice this is the single most misunderstood corner of the EU crypto map. The good news is that “you can’t get a domestic Polish licence yet” and “you can’t serve Polish users” are two very different statements. The first is true; the second is not. MiCA is an EU regulation, and it gives you a clean, fully lawful route into Poland today — passporting a licence obtained in Lithuania or Estonia. This guide explains exactly how that works, what it does and doesn’t buy you, and what changes if Poland’s own law finally passes.

Why you can’t get a domestic Polish CASP today

MiCA applies in Poland exactly as it does everywhere in the EU, and the KNF (the Polish Financial Supervision Authority) is confirmed as the competent authority for Crypto-Asset Service Provider licensing. On paper, that should mean you file with the KNF and get a Polish CASP. In practice, there is a missing piece.

MiCA is a regulation, but it leaves a set of national implementing choices to each member state — things like which authority acts, the procedural rules, fees and transition mechanics. In Poland those choices live in a domestic statute, the Crypto-Assets Market Act. That bill has had a rough passage: it was vetoed twice — on 2 December 2025 and again on 12 February 2026 — and, as of mid-2026, it is not in force. Without it, the KNF does not have the fully operational domestic framework it needs to run a normal CASP application pipeline.

The result is a gap that catches operators out. Poland is unmistakably an EU MiCA jurisdiction, so founders reasonably assume a Polish licence is available on the same terms as, say, a Lithuanian one. It isn’t yet. Filing into a procedure that isn’t reliably open wastes months, and — with the MiCA transition deadline approaching — that is time serious operators cannot spare. The honest framing matters here: we don’t file into a window that isn’t open, we place the licence where it can actually be granted.

How MiCA passporting solves it

This is where MiCA’s design does the heavy lifting. Because it is a single EU regulation rather than 27 separate national laws, a CASP authorisation issued by any one member state’s regulator carries across the whole union. That mechanism lives in MiCA Article 65 — the freedom to provide crypto-asset services on a cross-border basis throughout the EU-27.

The process is a notification, not a fresh application, and it runs in three moves:

• Authorise in a home state. You obtain a full MiCA CASP licence from a live regulator — for the reasons below, Lithuania or Estonia.
• Notify the host state. Your home regulator sends the KNF (and any other host states you name) a passporting notification listing the services you intend to provide into Poland.
• Serve Polish users. After the short statutory notification period, you may lawfully provide those services to customers in Poland under your single home-state licence.

There is no second Polish licence to obtain, no re-authorisation and no separate KNF application fee for the cross-border passport. One licence, granted once, reaches Poland and the rest of the single market — roughly 450 million people. If you want the fuller picture of what a Polish CASP structure looks like end to end, our Poland crypto licence guide sits alongside this route explainer, and the requirements breakdown covers the substance and governance you’ll build regardless of where the licence is issued.

Why Lithuania or Estonia as the home state

Any EU member state’s CASP passports into Poland identically, so the home-state choice is about which regulator can authorise you well and quickly. On both counts, Lithuania and Estonia lead.

Lithuania runs one of the EU’s most mature CASP pipelines. The Bank of Lithuania built its process off a very large legacy VASP sector, reviews are well-understood and typically run around three to six months, and the ecosystem — banking partners, service providers, MLRO talent — is deep. It is consistently among the fastest routes to a live MiCA licence, which is why it is our default recommendation for reaching Poland; our Lithuania crypto licence guide walks through the full process. Estonia offers a comparable profile through its Financial Supervision Authority, with e-government efficiency and a distributed-profits tax regime that many operators find attractive.

Crucially, the licence you build in either state is not a compromise or a workaround. It is a full MiCA CASP with the same capital, substance and conduct obligations you would face anywhere in the EU. The capital tiers are fixed union-wide and do not change by country: €50,000 for Class 1 (reception and transmission, advice, execution and placing), €125,000 for Class 2 (adds custody and exchange) and €150,000 for Class 3 (operating a trading platform). You also carry a DORA-compliant ICT resilience programme, a dedicated MLRO, AML/CFT to the EU’s directives and the Travel Rule. None of that is Poland-specific; it travels with the passport. What the home-state choice buys you is speed and a smooth authorisation — not a lighter licence.

Passport now vs. wait for the KNF

Here is the decision as we lay it out for clients targeting Poland:

The 1 July 2026 MiCA cutoff is the pressure point. That date is the hard EU deadline after which legacy national VASP activity can no longer be relied on and full MiCA authorisation is required to provide crypto-asset services. An operator waiting on Poland’s stalled law risks arriving at that deadline with no valid authorisation at all. A live Lithuanian or Estonian CASP clears that bar comfortably. The economics of the passport route therefore track your home-state licence — class-based capital, substance and the AML/DORA build — and our Poland crypto licence cost breakdown maps the full year-one picture against the domestic alternative.

What passporting does and doesn’t give you

It is worth being precise about the boundaries, because “passport” gets over-read. On the “does” side: a passported CASP can serve Polish customers with each crypto-asset service it is authorised for, on a cross-border basis, under its single home-state licence — no Polish licence, no KNF re-authorisation. That is genuine, lawful market access, and for the large majority of exchanges, wallets and brokers it is everything they need to reach Poland.

On the “doesn’t” side, three things. First, a cross-border passport is not a physical Polish branch; if you want an establishment on the ground, that requires a separate branch notification, which we handle where it makes sense. Second, the passport does not exempt you from Polish rules of general application — local marketing and advertising standards, consumer-protection expectations and language conventions still apply. Third, it is not a Polish-domiciled licence, so if your strategy specifically calls for a KNF-issued authorisation (for local optics, procurement or otherwise), the passport is a bridge to that, not a substitute.

That last point is where the “if Poland’s law passes” scenario lands. A passported CASP stays valid whatever Warsaw enacts, so there is never a forced migration. But operators who do want a domestic licence benefit from being structured for it in advance — capital, governance and AML already at MiCA standard — so a direct KNF filing is a formality rather than a fresh build. We watch the regime and tell you the moment a domestic application becomes worthwhile.

The route we run

For an operator whose goal is “reach Polish users compliantly, soon,” the path is settled: build a full MiCA CASP in Lithuania or Estonia, notify the KNF under Article 65, and go live — while keeping the option to file a direct KNF application open for the day Poland’s domestic regime finally opens. A Polish operating company, local staff and marketing can all sit alongside a passported licence if you want a real presence in the market.

We won’t sell you a filing into a window that isn’t open, and we won’t pretend the domestic route exists yet when it doesn’t. We’ll place the licence where it can actually be granted, passport it cleanly into Poland, and keep you first in line for the KNF regime when the law changes. Book a free consultation and we’ll map the route around your real target market, not a template.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.