MiCA Transition in Poland: From VASP Registration to KNF CASP Licence

MiCA Transition in Poland: From VASP Registration to KNF CASP Licence
August 2025

Understand how MiCA changes crypto regulation in Poland. Learn about VASP vs CASP, KNF authorisation, transitional periods, and how AP Outsourcing Group supports firms with MiCA compliance and licence applications.

Introduction
The introduction of the Markets in Crypto-Assets Regulation (MiCA) in the EU marks a turning point for all crypto-asset service providers (CASPs). In Poland, this shift means that firms registered as VASPs under the AML Act must now prepare for KNF CASP authorisation.

In this article, we explain:
- The difference between VASP registration and a CASP licence.
- Key obligations under MiCA and Polish law.
- The transitional rules and current legal gap.
- How to prepare for the KNF application process.
 
VASP vs CASP – What’s the Difference
VASP registration (Polish AML Act): focuses on AML duties (KYC, GIIF reporting, AML officer).
CASP licence (KNF, MiCA): a full regulatory authorisation, covering prudential capital, governance, safeguarding, disclosures, ICT resilience, and AML/Travel Rule.
A CASP licence is the only passportable licence across the EU.

Transitional Periods in Poland
As per the EU Default Rule, MiCA allowed VASPs to operate until 1 July 2026, unless shortened by Member States.
Poland’s Decision:
- 4 months automatic continuation after the Act starts,
- Up to 9 months if a complete KNF application is filed within 3 months,
- After this period, only CASP licence holders may operate.
 
The Current Legal Gap (July 2025 → Entry of Act)
At present, Poland is in a grey zone:
- EU transitional has ended (30 June 2025).
- Polish Act not yet in force.
- This means firms cannot rely on VASP registration alone. Preparing a MiCA-ready application now is critical to avoid interruption.

Key MiCA & AML Obligations to Consider Now
- AML / Travel Rule (fully applicable since 30 Dec 2024).
- MiCA conduct standards (disclosures, safeguarding, governance).
- GIIF reporting under the Polish AML Act.
 
What Firms Should Do
- Prepare the CASP application pack now (governance, AML, ICT/DORA, prudential).
- File within 3 months of the Act to secure the full 9-month transitional period.
- Operate to MiCA standards already to avoid reputational and supervisory risks.
 
How AP Outsourcing Group Helps
At AP Outsourcing Group, we support crypto businesses in Poland and across the EU with:
- KNF CASP licence applications – complete preparation and submission of all required documentation.
- AML outsourcing and advisory – KYC, GIIF reporting, Travel Rule, internal AML programs.
- Ongoing compliance support – monitoring MiCA, DORA, AML requirements.

Conclusion
The Polish transition to MiCA is complex: the EU transitional period has ended, and the Polish Act is still pending. Businesses should act now to prepare for KNF authorisation to ensure business continuity.

AP Outsourcing Group stands ready to help firms bridge this gap with regulatory expertise and practical execution.

Learn more about our CASP KNF licence application service and AML outsourcing solutions.