Poland crypto license 2026 — KNF CASP authorisation

Why Poland's CASP regime is still unsettled

Poland is the awkward case in EU crypto licensing. MiCA applies directly, and KNF is the designated competent authority — but the country needs a national implementing act to operationalise the domestic CASP regime, and that act, the Crypto-Assets Market Act, stalled in the legislative process. As of mid-2026 it had not entered into force, which left applicants without a settled local route at exactly the point the EU transitional clock was running down.

That gap matters in practice. A founder used to the Baltic model — file, engage the regulator, get authorised in months — finds no equivalent certainty in Warsaw, because the procedural rulebook the application would run on was still pending. The honest read for 2026 is that Poland is a market to watch, not yet a market to file in blind.

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. Two ranked firms carry Poland on their maps: [Gofaizen & Sherle](/firm/gofaizen-sherle/) sits at #1 across the whole index, and [Bird & Bird](/firm/bird-and-bird/) lands at #8. Neither bought the spot, and neither pretends Poland is a finished market when it plainly isn't.

The most useful published commentary on the stalled Act comes from independent Polish counsel, not from the ranked firms. Katarzyna Szczudlik at Schoenherr in Warsaw follows KNF's posture and the draft legislation closely. 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](/experts/), 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. If you need a licence live before the 1 July 2026 cut-off, most operators don't wait on the Polish act at all — they authorise in a finished EU hub and passport in, keeping a Polish adviser on retainer to move the day the 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 is the authority that will handle CASP authorisation and ongoing supervision under MiCA once the national framework is complete. 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 a comparison against a neighbouring hub, see our [Lithuania vs Poland CASP licence](/knowledge/lithuania-vs-poland-casp-licence-compared/) analysis and the [Poland KNF practitioner guide](/knowledge/poland-knf-casp-practitioner-guide-2026/).

What this means before 1 July 2026

The Article 143 transitional regime ends on 1 July 2026. An operator anchored on Poland has to weigh a real risk: the EU deadline arrives whether or not the national act is in force. Many teams in that position keep Poland as a target market but passport in from a jurisdiction with a finished framework, rather than betting the launch on Warsaw legislation landing on time. The named Polish counsel in this index — practitioners who publish on the stalled act rather than paper over it — are the right people to track that timing with.