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Crypto License in Poland

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Crypto Exchange & Wallet License (CASP) in Poland

Crypto License in PolandPoland offers a regulated legal environment for virtual asset service (VASP) and crypto-asset service provider (CASP) companies, with VASP regulations in place since November 2021. Our on-site Web3 specialised lawyers and AML compliance professionals provide structured services for licensing and on-going AML compliance solutions (e.g. MLRO and CCO outsourcing) support.

As of January 2025 the Polish legislator has not yet passed the MiCA regulation. Therefore it is still possible to structure the corporate setup as a VASP, to then transition into the MiCA CASP regime – taking advantage of the longer operational time. Comparing to neighbouring crypto licensing destinations, current Polish regulations can be viewed as more flexible in terms of the setup process and come at lower on-going cost. We are at your service if you prefer to work with professionals with extensive experience in licensing and AML compliance solutions since the inception of crypto legislation in the European Union.

Quick Summary:

Exchange + Wallet License
Remote setup from 2 weeks
Price from 30.000 EUR
Min. 1 person structure
Local substance recommended
Pricing »
Contact us »

Poland has 4 types of crypto authorisations for VASP companies operating with virtual currencies:

Providers of a service of exchanging A) crypto against fiat and vice versa; B) crypto against crypto; C) brokerage services for the former
Official activity authorisation covering services for exchanging fiat to crypto and crypto to fiat and crypto to crypto. Such activity registration enables to operate a crypto exchange in a regulated manner.

Providers of a virtual (crypto) currency wallet service
The virtual currency wallet service means a service in the framework of which keys are generated for customers or customers’ encrypted keys are kept, which can be used for the purpose of keeping, storing and transferring virtual currencies.

One VASP company can hold all 4 crypto activity registrations. Our lawyers assist in applying for the crypto registration in Poland for providing crypto exchange and/or wallet services by preparing all required legal documentation and managing the process on your behalf fully remotely without travel needed. It is important to note that even though the word license is widely used to describe the underlying capabilities of the VASP regulation, then per regulatory framework Poland provides an activity registration to operate as a regulated VASP and not a financial license per se. The regulator application review time is on average 2-4 weeks, but the preparations for a successful application should be considered to take a similar amount of time.

Key points for Poland VASP Crypto License Company structure

Poland crypto licenseTo obtain the Polish crypto license to provide cryptocurrency exchange and/or wallet services a limited liability company (Sp. z o.o.) has to first be set up in Poland. The minimum share capital requirement is 5000 PLN (approx. 1200 EUR). The company setup can be carried out fully remotely with no visit required, it usually takes about 10 business days from the point we receive all required original documentation. The first step we take in the service engagement is analyzing the target shareholding and management structures, which enables us to provide the list of required documentation.

The minimum company structure requirement is currently 1 person who can act as the shareholder, chairman of the management board and AML compliance officer all in one. It is important to note that the management board member(s) of the company must have experience in the area of virtual currencies operations for a minimum of one year; or alternatively it is possible to take an online course to qualify for the regulator. We recommend out-sourcing a 3rd party service provider to fulfil AML compliance and associated reporting requirements, e.g. for roles of Money Laundering Reporting Officer (MLRO) and a Chief Compliance Officer (CCO). Subject to project review we can provide on-going support with local substance and AML compliance outsourcing services such as qualified Polish resident professional background MLRO and CCO positions to take care of the reporting requirements.

It is also important to consider that a company holding the crypto license in Poland has to keep a detailed and up-to-date overview of all clients and transactions according to the AML/KYC regulations. The regulator may make enquiries about the activities of the company, especially in regards to following the predefined AML/KYC policies. Further notices have to be made to the regulator in case certain transaction thresholds are exceeded. Our lawyers and AML compliance professionals may support in compiling the full set of legal and compliance documentation as the regulator may request to check and monitor the internal procedures.

General VASP requirements

  • At least 1 shareholder (natural person or corporate entity). No restrictions to citizenship or residence. For optimal setup structure please consult our legal team.
  • At least 1 management board member (can be same as the shareholder, but only a natural person). Foreign residents are allowed, there are no restrictions to citizenship or residence. Professional experience requirement in the field of virtual currencies. PESEL and Trusted Profile requirement (we can support).
  • Virtual office address accepted as company location. Beneficial owners’ details are disclosed to the authorities.

Taxation

  • Virtual currencies (e.g. Bitcoin and altcoins) exchange services are not subject to VAT.
  • Services invoiced (e.g. sales invoices) in virtual currencies are subject to regular VAT rules.
  • Corporate profits are taxed at 19% (CIT=19%) and withholding tax (WHT) 19% is charged on gross dividends.

Banking

Most VASP companies working in the crypto sphere, whether licensed in Poland or in another EU jurisdiction, take advantage of crypto friendly fintech banks working under the EMI license. We work with well known financial institutions to ensure the opening of a business bank account for your Polish crypto licensed company. The speed and result will depend on your business model, background and co-operation during the KYC process.

Per our optional banking advisory service, after the company is set up, our banking team maps your needs (eg. SEPA, SWIFT, Instant SEPA etc.), volumes and financials etc. and reaches out to approx. 15-20 financial institutions supporting crypto and we inform you about soft pre-approvals available that could work for your needs. The service covers advisory, our know-how and work, the fees for opening accounts/KYC/etc will be paid directly to the banks. Most of our clients have been able to open an operational account in a few weeks. Please contact our consultants for a banking advisory quotation.

It is also important to note that currently traditional Polish banks do not wish to work with crypto companies, thus mostly Lithuanian based financial institutions whom are crypto-friendly can be used, further we can suggest alternative banking options in Europe (Malta, Switzerland, Cyprus etc.). Please also note that for crypto companies higher level of AML/KYC principles are applied. We can support with appropriate banking solution consideration after we have an overview of the planned activities, shareholding structure and the company  financial forecasts to consider the best path forward.

PESEL/Trusted Profile

The PESEL number is an eleven-digit numerical symbol that allows Polish authorities to easily identify the natural person, for example it is given to every citizen of Poland after their birth. In every official correspondence with Polish Authorities natural persons should indicate their PESEL number. In certain conditions PESEL may also be obtained by a non-resident even if the person does not have residency in Poland. Our lawyers can support to obtain the PESEL number even if the applicant is not a resident of Poland, further it is possible to complete the setup by remote service (no visit needed), it usually takes about 1 week.

After the PESEL registration is issued then it is possible to apply for a Polish Trusted Profile (ePuap, eGo), which is a tool to prove your identity digitally (electronic signature). In simple terms it enables Polish citizens and foreigners to contact with authorities, to electronically sign documents and is necessary to perform certain operations whilst administering your company. Upon issuance it is valid for 3 years. The application is filled online, but in order to activate it the identity of the person must be verified and this can be done only by visiting in person a confirmation point, which is a Polish Consulate or Polish Embassy in your country.

Company formation

Our lawyers support whether with a new company incorporation or we provide an already prepared shelf company for a faster setup and license application submission. In our packages the company setup is already included. We also have availability for Polish shelf companies with older registration dates and active VAT registrations. We can provide you with a turnkey solution with all the support services. Usually the most time and cost efficient approach to register a company in Poland is to purchase a new shelf company, because the founding process can be a challenge to non-residents due to some requirements (e.g. share capital deposit). Mostly non-residents opt for a new tailor-made shelf company to avoid bureaucracy as we have already taken care of all requirements. However, we do assist with new incorporations on request. We will help you to choose the best approach according to your objectives. For more information regarding the specifics of company formation in Poland please refer to the Company Formation in Poland page »

Pricing for Crypto License in Poland

We can support to obtain the VASP crypto license in Poland in order to provide crypto exchange and wallet services. The setup can be completed remotely without travel. Setting up a Polish limited liability company (Sp. z o.o.) and applying for a VASP crypto activity license that is monitored by the Poland General Inspector of Financial Information (GIFI) is made simple as our lawyers take care of the full legal procedures on your behalf and also provide on-going consultations per requirements. We also have availability for new and fully licensed shelf companies for swift setup. For more information please contact us for a tailor-made offer for your project »

  • New LLC company in Poland
  • Remote setup without travel
  • Timeframe to start activities
  • Type of setup package
  • Your company name
  • Registered share capital
  • Official crypto license type
  • All government and licensing fees
  • AML/KYC legal package
  • PESEL+Trusted Profile application
  • Virtual registered address 1 year
  • Compliance services consultation
  • Bank account opened
  • VASP GOLD PACKAGE New LLC shelf company package with new license application; for non-residents
  • discontinued
  • 2 months
  • New license application
  • 5000 PLN (pre-registered; 0 balance)
  • Crypto Exchange+Wallet (4)
  • SEND ENQUIRY
  • VASP PLATINUM PACKAGE Activated VASP license shelf company transfer for swift setup inc. bank account, no trading history
  • € 30.000
  • 2 weeks EXPRESS
  • Activated license company transfer
  • 5000 PLN (pre-registered; 0 balance)
  • Crypto Exchange+Wallet (4)
  •  
  • SEND ENQUIRY
  • CASP DIAMOND FULL MiCA LLC company incorporation package with new MiCA license application; conditions apply
  • per quote
  • 4-6 months
  • New application
  • € 150.000 (capital injection required)
  • MiCA CASP CLASS 3 
  • SEND ENQUIRY

* All orders are subject to our review and subject to our final confirmation; conditions may apply; recurring monthly service fees may apply in some cases. Notice: all pricing is indicative and is subject to our final confirmation upon receiving order details; indicative packages for one natural person participant. Prices shown excluding VAT, which is added; in some cases no VAT added. Discounts may be applied. We reserve the right to change our individual and package prices at any time without notice. Additional fees may apply in case of additional participants, corporate shareholder, translation services, legal analysis/opinion services, certified documents orders and more. Please contact us for a detailed offer specific to your project.

Legal Framework and Requirements for VASPs in Poland

The legal framework for VASPs is governed by the Act of March 2018 for Counteracting Money Laundering and Financing of Terrorism Prevention Act. From November 2021 new AML regulations came into force, according to which virtual currencies became a regulated activity and the Virtual Currency Activity Register in Poland was activated. We can prepare all policy documentation according to the legal framework and manage the process with the Chamber of Tax Administration Office in Katowice (holder of the Virtual Currency Activity Register) and General Inspector of Financial Information GIFI as a supervisory authority, which is supported in realization of the statutory tasks by the Department of Financial Information of the Ministry of Finance, which acts as the Polish Financial Intelligence Unit (FIU).

Documentation

For review and preparation of the licensing project we will ask for the following documentation:

  • Valid copy of passport from each country of citizenship
  • Power of Attorney (PoA)
  • Description of planned business model and licensed activities
  • Resume (CV) listing employment and education background for all participants
  • Website address where services will be offered 
  • Non-criminal certificate from the registry of convictions (not older than 3 months) for shareholder(s), board member(s), ultimate beneficiary owner(s)  *

All listed documentation has to be certified by notary public and confirmed with an apostille, in English (or sworn English translation). In the first stage we will gather all information and provide step by step process overview according to your case.

Procedures

Our compliance team will prepare the full internal procedures documentation for the company to meet with the Anti Money Laundering (AML) and Know Your Customer (KYC) criteria established in the legal framework. Some parts of this include, for example:

Internal security measures
  • assessment and management of the risk of money laundering and terrorist financing;
  • collection and keeping of records;
  • performance of the notification obligation and notification of the management;
  • internal control rules for checking adherence thereto.
Rules of procedure
  • describing transactions of a lower risk level and establishing the appropriate requirements and procedure for carrying out such transactions;
  • describing transactions of a higher risk level, including risks arising from means of communication, computer network and other technological development, and establishing the appropriate requirements and procedures for carrying out and monitoring such transactions;
  • set out the rules of taking the due diligence measures;
  • set out the requirements and procedure for keeping the documents and records;
  • set out the requirements and procedure for application;
Instructions and guidelines
How to effectively identify whether or not the person is:
  • a politically exposed person;
  • a person whose place of residence is in a country where no sufficient measures for prevention of money laundering and terrorist financing have been taken;
  • a person whose activities there is prior suspicion that the person may be involved in money laundering or terrorist financing;
  • a person with regard to whom international sanctions are imposed;
  • a person with whom a transaction is carried out using telecommunications.

The Polish AML law (03.11.2021) can be viewed here.
The English translation (not up to date with latest changes) can be viewed here.

Compliance officer

According to the Polish AML act the senior management board member is designated as the company compliance reporting officer, who is responsible for implementing the duties set out in the legislation. Taking into consideration Articles 129n and 129o of the Polish AML Act, the condition of experience or knowledge in the field of virtual currencies applies to all members of the management board.

We can provide several options for a successful solution, we can further support with professional AML compliance officer appointment to take care of the company reporting requirements. The standard duties of a Compliance Officer (CO) include, inter alia:

  • organisation of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the obliged entity;
  • reporting to the GIFI in the event of suspicion of money laundering or terrorist financing;
  • periodic submission of written statements on compliance with the requirements;
  • performance of other duties and obligations related to compliance with the requirements.

The overall requirements for a Compliance Officer (CO) include:

  • the person must have the education, professional suitability, the abilities, and experience required for performance of the duties;
  • the company must organize specialized training on money laundering and/or terrorist financing prevention measures for their employees, especially those who work directly with customers and their transactions.

More information about our AML compliance solutions can be found here: AML Compliance Solutions

Revocation

The Article 129w of the Polish AML law covers that the authority competent for the register of activities in the field of virtual currencies shall remove the entity performing activities in the field of virtual currencies from the register in the following cases:

  1. At the request of the entity submitted in electronic form;
  2. After obtaining information on the removal of the entity from the Central Register and Information on Economic Activity or the National Court Register;
  3. If it is found:
    – 3a. the entity’s failure to meet the conditions required by law to perform activities in the field of virtual currencies;
    – 3b. that the entity submitted the declaration (declaration that company meets all requirements) inconsistent with the facts.

Contact us for more information

We will provide a step by step overview with detailed timeframes and cost break-down after gathering the preliminary project information. Our track-record in setting up the crypto license in Poland for our clients is 100% as we follow a thorough checklist to confirm that all legal requirements are met. Please contact our legal department through the contact form below and we will get back to you with further information shortly.

    Contact details

    Please contact us to schedule a meeting with our crypto projects manager.

    Call our head office at +372.50.43.245

    E-mail us at poland@maxcorp.eu

    Wspólna 70, 00-687 Warsaw, Poland