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How to Obtain a MiCA CASP Licence in Poland

  • Writer: Buckingham Capital
    Buckingham Capital
  • Jan 13
  • 5 min read
How to Obtain a MiCA CASP Licence in Poland


Introduction

If you want to operate a crypto exchange, custody platform, brokerage, wallet service, or any business handling crypto assets in the European Union, you will need a MiCA CASP licence. From 2024 onwards, MiCA replaced fragmented national crypto regimes with a single EU wide regulatory framework.


Poland is emerging as one of the most commercially attractive jurisdictions to obtain a CASP licence under MiCA. It combines EU passporting rights, moderate regulatory cost, access to skilled compliance and technology talent, and a regulator that already supervises large numbers of crypto firms.


Buckingham Capital Consulting has been helping financial and crypto businesses secure regulatory approvals across Europe and internationally for over 15 years. This guide reflects how CASP licensing works in practice in Poland.



What is a MiCA CASP Licence

MiCA, the Markets in Crypto Assets Regulation, is the EU wide regulatory framework for crypto. Under MiCA, crypto firms are authorised as Crypto Asset Service Providers, known as CASPs.


A CASP licence allows a company to provide crypto services across all 27 EU member states from one home regulator.


Under MiCA, the following activities require CASP authorisation:

  1. Crypto to fiat exchange

  2. Crypto to crypto exchange

  3. Execution of orders on behalf of clients

  4. Custody and safekeeping of crypto assets

  5. Operating a trading platform

  6. Reception and transmission of crypto orders

  7. Placing of crypto assets

  8. Providing advice on crypto assets


If you provide any of these services to EU customers, you need a CASP licence.



Why Poland is a strong CASP jurisdiction

Poland offers a rare combination of commercial practicality and regulatory credibility.


Polish crypto firms are supervised by the Polish Financial Supervision Authority (KNF), which is one of the largest financial regulators in Central Europe and already oversees banks, payment institutions, investment firms, and crypto providers. This gives Poland strong standing with banks and counterparties.


Poland also benefits from:

• Lower operating and staffing costs than Western Europe

• A deep pool of compliance, technology, and fintech talent

• A regulator experienced in crypto supervision• Full EU passporting under MiCA

• A large domestic market plus EU wide reach


For many crypto businesses, Poland offers the fastest path to a scalable EU licence without the cost base of Germany, France, or Luxembourg.


Core CASP Licence Types in Poland

Under MiCA, CASP licences are issued based on the services you provide. The three most commercially relevant categories are:


1. Exchange and brokerage services

This covers crypto to fiat exchange, crypto to crypto trading, order execution, and brokerage.

This is the licence used by most exchanges and OTC platforms.

Minimum capital under MiCA: €125,000


2. Custody and wallet services

This covers holding client crypto, operating wallets, safeguarding private keys, and administering assets on behalf of customers.

This category is treated as higher risk.

Minimum capital under MiCA: €150,000


3. Trading platform operators

This applies to firms running an exchange or order book where buyers and sellers meet.

Minimum capital under MiCA: €150,000

Firms offering multiple services must meet the highest applicable capital threshold.



What regulators look for in a Polish CASP application

1. Polish operational substance

You must have a real Polish company with local staff. This includes a physical office, local compliance personnel, and management with day to day control in Poland.

Shell structures or nominee arrangements are rejected.


2. AML and transaction monitoring

You must demonstrate how you identify customers, screen them, monitor transactions, and investigate suspicious activity. Blockchain analytics tools must be integrated into monitoring workflows.


3. Governance and control

You need a proper management structure, risk ownership, escalation processes, and board level oversight. Regulators expect decision making to happen in Poland, not offshore.


4. Technology and security

Custody firms and exchanges must demonstrate wallet architecture, key management, penetration testing, and cyber security controls.


5. Financial viability

You must show that the company has enough capital to operate through the licensing process and after authorisation.



How long it takes

A well prepared CASP application in Poland typically takes 6 to 10 months from submission to authorisation.

Firms that have already operated under the Polish VASP regime and are transitioning into MiCA can be faster, but new applicants should plan for a full regulatory review cycle.



What it costs

Costs depend on the services you provide and the level of operational setup you build in Poland.


You should budget for:

• Regulatory fees

• Company formation and local office

• Local compliance and management staff

• IT security audits and penetration testing

• Legal and regulatory advisory


Poland remains one of the lowest cost ways to obtain a serious EU crypto licence.


Transition from Polish VASP to MiCA CASP

Existing Polish VASPs can apply to convert into CASPs under MiCA using a transitional process. They must upgrade capital, governance, and systems to meet MiCA standards.


This pathway is only available to firms that were genuinely operating under the Polish regime. New entrants must apply directly for CASP authorisation.



How Buckingham Capital Consulting can help with the Poland CASP licence

Buckingham Capital Consulting has been helping financial and crypto firms obtain regulatory licences for over 15 years across Europe, the UK, Middle East, and Asia Pacific.


We support CASP projects end to end, including:

• Jurisdiction and licence type selection

• Polish company setup and local substance planning

• CASP application drafting

• AML, transaction monitoring, and governance frameworks

• Technology and custody model reviews• Regulator engagement and interviews

• Support through authorisation and into live operation


Our role is to ensure your licence is not just approved, but commercially usable with banks, counterparties, and payment partners.



Most asked questions about CASP licensing in Poland

How long does a Poland CASP licence take?

Most well prepared applications take 6 to 12 months, depending on complexity and regulator queries.


Can I passport my Polish CASP across the EU?

Yes. Once authorised by Poland under MiCA, you can operate in all 27 EU member states.


Do I need to be based in Poland?

Yes. MiCA requires real local substance, including management, compliance, and operations.


Is Poland cheaper than Germany or France?

Yes. Poland offers much lower staffing and operating costs while still providing EU wide regulatory credibility.


Can Buckingham Capital Consulting manage the full process?

Yes. We handle the full licensing lifecycle, from structuring and company setup through to CASP authorisation and live compliance.



About Buckingham Capital Consulting

Buckingham Capital Consulting has been helping financial and crypto businesses secure regulatory licences and build compliant operating models for over 15 years. We work with exchanges, custody providers, brokers, and crypto platforms across Europe and internationally.


Our team supports clients from jurisdiction selection and company setup through to CASP authorisation, regulatory engagement, and ongoing compliance.


For assistance with a Poland MiCA CASP licence, contact Buckingham Capital Consulting on 020 7866 2512 or email info@buckinghamcapitalconsulting.co.uk.

 
 
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