Poland crypto licence 2026 — why no CASP route exists

Why there is no Polish CASP licence

Poland is not a slow market. It is a blocked one, and the distinction decides what you do about it. MiCA applies directly, but a member state has to designate the authority that issues authorisations, and Poland has not. Parliament passed a Crypto-Assets Market Act three times — on 7 November 2025, 18 December 2025 and 15 May 2026 — and President Nawrocki refused to sign each one. Each veto needed a three-fifths majority to override and none got there. The last attempt failed on 4 September 2026 by twenty-five votes.

So KNF has no CASP remit to exercise. Its own position paper says no national body has been designated as competent authority, and an earlier statement is blunter about what happens to anyone who files regardless: applications are left without consideration. ESMA marks Poland with an asterisk on its list of competent authorities, the footnote for member states that have not formally designated one. On 7 October 2026 its register held 370 CASPs across the EEA and not one with Poland as its home state.

Which firms and named lawyers handle Polish CASP work

Every firm's own website says it's the best choice for Poland. The Crypto Law Index doesn't take that on faith — it scores the counsel covering Polish crypto work on the CLPAI methodology, an independent editorial ranking rather than paid placement. Every ranked firm that lists Poland on its profile appears in the table below, led by Manimama at #1. None of them bought its place.

The most useful published commentary on the vetoed acts comes from independent Polish counsel, not from the ranked firms. Katarzyna Szczudlik at Schoenherr in Warsaw advises on Polish financial-services regulation. Michał Wołoszański and Łukasz Kudela at WLAW (Wołoszański & Partners) write on where the domestic CASP procedure actually stands right now. We list all three as independent practitioners in the experts directory, because they'll tell you the framework is unfinished rather than paper over it.

So which one you brief comes down to what you're actually solving. If Poland is the decided market and you want someone reading KNF's signals week to week, the independent Warsaw practitioners earn their keep. Since the transitional period ended on 1 July 2026, operators serving Polish clients have had to hold a MiCA authorisation from another member state and passport in, keeping a Polish adviser on retainer to move the day a national procedure opens. The ranking exists to help you tell those two jobs apart, not to crown a single winner.

How KNF fits into the MiCA picture

KNF supervises the broader Polish financial sector and covers e-money token issuers, but it cannot authorise CASPs: no act designating a competent authority is in force, and the only live bill, Sejm print 3173, had no first reading as of October 2026. The prudential floors are not a Polish invention — they come from MiCA Annex IV and Article 67, so the capital expectation (€50,000 to €150,000 by class, or one-quarter of fixed overheads if higher) is the same as anywhere else in the EU.

What is Poland-specific is the wrapper: company formation (typically a spółka z o.o.), local substance, the AML programme under Poland's 2018 AML Act, and the as-yet-unfinished national procedure. For the alternatives, see our Estonia vs Lithuania CASP licence comparison, which also covers Poland.

Where this leaves operators now that the transitional window has closed

The consequence landed on 1 July 2026, and it is the part most guidance still misses. The Article 143(3) transitional period let firms on the old virtual-currency register keep operating while their member state got organised. Poland never did, and the period expired anyway — it cannot be extended by statute or by a KNF decision. Those firms did not move to the back of a queue; they lost the legal basis to provide crypto-asset services at all, in Poland or abroad. Anyone still reading that Poland is waiting on a licence is reading something written before that date.