MiCA Poland After 1 July 2026: VASP & CASP Status

The MiCA transitional period ended across the European Union on 1 July 2026. From that date, a Polish registration in the Register of Virtual Currency Activities no longer authorises an undertaking to provide crypto-asset services as a VASP or a CASP in Poland or elsewhere in the EU.

For most standalone crypto-asset businesses, continued provision of services to EU clients now requires an authorisation under the Markets in Crypto-Assets Regulation — commonly referred to as a CASP licence — or another route expressly permitted by MiCA for an eligible regulated financial institution.

Current position in Poland — updated 3 August 2026

the Polish VASP transitional period ended on 1 July 2026,
a VASP registration no longer provides a legal basis for crypto-asset services,
an unauthorised provider cannot continue business-as-usual services for EU clients,
Poland has not yet established an operational national route for submitting CASP authorisation applications,
a CASP authorised in another EU Member State may provide services in Poland through the MiCA cross-border notification procedure.

What changed on 1 July 2026?

Article 143 of MiCA allowed providers operating under certain national regimes before 30 December 2024 to continue temporarily while preparing for the new EU framework. The maximum transitional period expired on 1 July 2026.

The end of the transitional period applies irrespective of whether a Member State has completed all domestic implementing measures. A provider cannot rely on the absence of Polish implementing legislation to continue offering regulated crypto-asset services without the required MiCA status.

Does a Polish VASP registration still permit operations?

No. The Polish Ministry of Finance has confirmed that an entry in the Register of Virtual Currency Activities no longer authorises the undertaking to operate as a VASP or a CASP, either in Poland or abroad.

The previous registration was an AML-focused national registration. It was not equivalent to the wider prudential, organisational, governance and conduct authorisation required under MiCA.

Can a CASP application currently be submitted in Poland?

As at 3 August 2026, official Polish materials indicate that there is no national authority empowered to process applications for authorisation as a crypto-asset service provider. The latest Polish legislation intended to implement the national supervisory framework was vetoed on 11 June 2026.

A business may continue preparing its governance, AML framework, operational model and application documentation, but this should not be presented as an application that can currently be submitted to the KNF. The appropriate regulatory route must be reassessed when the Polish legislative position changes.

What must an unauthorised provider do?

ESMA expects unauthorised providers to take immediate steps to wind down their EU activities in an orderly manner while protecting clients. Depending on the business model and circumstances, this includes:

stopping the onboarding of new EU clients,
ceasing marketing and active solicitation in the EU,
limiting services to activities necessary for an orderly exit, transfer or closure,
communicating clearly with clients about relevant deadlines and available options,
supporting the transfer of assets to an authorised CASP or a self-hosted wallet where appropriate,
maintaining effective CDD, transaction monitoring, sanctions screening, reporting and record-keeping throughout the wind-down,
documenting management decisions, client treatment and completion of the exit plan.

Wind-down is not business as usual

Continuing to service existing customers without a documented and time-limited exit plan should not be treated as a continuation of the former VASP regime. Only activities genuinely necessary to protect clients and complete an orderly exit should continue.

Can an EU-authorised CASP serve clients in Poland?

Yes. A CASP authorised in another EU Member State may provide services in Poland through the cross-border notification procedure under Article 65 of MiCA.

The CASP submits the relevant information to the competent authority in its home Member State. It may begin providing the notified services after confirmation that the information has been communicated or, at the latest, from the fifteenth calendar day after submitting the required information.

Choosing an EU authorisation route

Selecting a home Member State is not simply a matter of finding the fastest or least expensive regulator. A CASP authorised under MiCA must have a registered office in an EU Member State and conduct substantive business activities there.

A credible regulatory-route assessment should consider:

where management and key decision-makers are located,
where the business will conduct substantive operations,
the services to be included in the authorisation,
the target markets and intended passporting strategy,
governance and control-function arrangements,
local substance and staffing requirements,
AML/CFT, Travel Rule and sanctions controls,
ICT, outsourcing and operational-resilience arrangements,
prudential safeguards and protection of client assets.

What should a MiCA readiness project include?

Regulatory route and governance

Services mapping, home-state analysis, programme of operations, management responsibilities, control functions, conflicts of interest and outsourcing.

AML and customer controls

Business and customer risk assessments, KYC, KYB, EDD, sanctions and PEP screening, transaction monitoring, reporting and Travel Rule controls.

Operations and evidence

Client-asset safeguards, complaints, record keeping, ICT and DORA readiness, business continuity, testing, management approval and evidence of implementation.

How APOG supports MiCA and CASP readiness

APOG supports crypto-asset businesses with practical preparation for a legally and operationally credible MiCA route. The scope may include:

regulatory-route and operating-model assessment,
MiCA and CASP authorisation-readiness reviews,
governance, AML, KYC/KYB and Travel Rule implementation,
documentation aligned with the selected EU home-state route,
cross-border passporting readiness,
remediation of identified framework or operational gaps,
wind-down and client-migration planning for unauthorised providers.

Assess your MiCA route before preparing the application package

The intended services, management location, operational substance and target markets should determine the regulatory route. Documentation should follow that assessment — not the other way around.

Explore APOG’s MiCA & CASP readiness support

Official sources

This article reflects the regulatory position identified from official sources as at 3 August 2026 and is provided for general information only. It does not constitute legal advice. The Polish legislative position and the availability of national application routes may change.