Head of International Corporate Law and Fintech Practice
Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.
OBTAINING A CRYPTO LICENSE IN POLAND
Obtaining a crypto license in Poland today means operating under MiCA, but thanks to the transition period, the Polish VASP regime is still in place and can be used as a temporary, cheaper solution. For many crypto businesses, the optimal strategy for 2026 is to purchase a ready-made Polish VASP company with a subsequent transition to MiCA/CASP when the national regime is fully operational.
MiCA in the EU and its role
MiCA (Regulation (EU) 2023/1114) creates uniform rules for the crypto-asset market in all EU countries and introduces the status of a crypto-asset service provider (CASP). A licensed CASP will be able to provide services almost throughout the EEA after obtaining a permit in one EU country thanks to the passporting mechanism.
For crypto businesses, MiCA means significantly tightening requirements: authorized capital, corporate governance, risk management policies, transparent rules for the custody of client assets, reporting and supervision by the national regulator. This increases the trust of banks, payment institutions and institutional investors, but at the same time makes entry more expensive and time-consuming.
Polish VASP regime: what is in place now?
Until the full launch of MiCA at the national level, the Polish market operates under the VASP (Virtual Asset Service Provider) model – registration of crypto companies in a special registry under the AML law. VASPs are subject to local AML requirements, but there are no full-fledged MiCA-level licensing procedures, which makes the entry threshold lower in terms of costs and deadlines.
Poland has not yet completed the implementation of the national law for MiCA, so at the beginning of 2026 there is a situation of “regulatory pause” in practice: MiCA at the EU level is already in force, but the authority responsible for CASP licenses cannot formally accept applications without a special Polish act. This means that the VASP registry continues to operate, although the market is aware that this is a temporary and transitional solution to the full MiCA regime.
Transition period: how long does VASP “live”?
The draft Polish law on the implementation of MiCA provides for a transitional period for existing VASP companies: they will be able to continue their activities for a certain period after the new act enters into force, provided that they submit a complete application for a CASP license within the established period. Various analytical reviews indicate a 4-9 month transitional period, with a longer period available only to those who manage to submit a full package of documents and receive confirmation of the completeness of the application.
At the same time, market experts agree that Poland is moving towards a shortened transitional period (about half a year) and a full transition to the MiCA-only regime in late 2026 – early 2027. For new players, this means: registering as a VASP is no longer a long-term strategy, but remains a tool for temporary legalization of the business until obtaining a CASP license or exiting through another MiCA jurisdiction.
Why is VASP cheaper than MiCA now?
Obtaining VASP status in Poland has historically required significantly less costs than full licensing under MiCA standards: lower capital requirements, simpler documentation, shorter processing times. Against the backdrop of the upcoming MiCA regime, the cost of preparing, complying with, and maintaining a CASP license is increasing significantly, which is especially noticeable for startups and small crypto services.
Due to the closure of the possibility of registering new VASPs, many companies are switching to the model of purchasing ready-made Polish VASP structures with already valid registration. Such a solution is usually cheaper and faster than building a MiCA project “from scratch” while waiting for the Polish CASP regime, especially if the business needs a quick start with basic legalization.
Buying a ready-made VASP company as a working strategy
In a situation where the VASP register is actually closed for new registrations, but is still valid for already registered companies, the key tool for entering the Polish market is the purchase of a ready-made VASP structure. Such transactions require thorough due diligence: checking the history of transactions, AML procedures, the absence of sanctions or claims, as well as confirming correct notifications to the Polish financial monitoring.
A properly structured transaction for the purchase of a VASP allows a business to quickly start operating in Poland, and at the same time prepare for MiCA licensing or choose another EU country as a “home” MiCA jurisdiction with subsequent passporting to the Polish market. For entrepreneurs, this provides a combination of three factors: a legally formalized presence today, control over costs and strategic readiness for the transition to MiCA tomorrow.
The Prikhodko & Partners team helps clients quickly and safely enter the Polish crypto market both through the purchase of ready-made VASP companies and through preparation for obtaining a CASP MiCA license when the Polish regime is fully operational. We support the full cycle: search and verification of VASP assets, legal due diligence, execution of a purchase and sale agreement, change of management and shareholder structure, as well as preparation of documents for notifications to the regulator and compliance with AML requirements. We also provide strategic advice on the choice between a temporary VASP model and a full-fledged MiCA project, taking into account your business volume, risks and plans for international scaling.
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