In the past few years, Poland was a country that many crypto projects easily considered when entering Europe. But by August 2026, this logic has fundamentally changed.

Written by: Shao Jiadian

Let’s start with the conclusion: If a project considers Poland only because of "low costs and easy registration," the answer for 2026 is now negative; if a project genuinely needs the Polish market, a more realistic path might be to first obtain MiCA CASP authorization in other EU member states and then enter Poland through passporting.

In the past few years, Poland was a country that many crypto projects easily considered when entering Europe.

The reasons are not complicated. The old VASP registration system was relatively lightweight, and the costs of setting up and operating a company were attractive. For teams hoping to first obtain a European regulatory identity and then gradually validate their business, Poland seemed to have the dual advantages of "cost" and "EU market." Our early global crypto payment compliance map once considered Poland as one of the potential low-cost paths for EU CASP based on the legislative progress at that time.

But by August 2026, this logic has fundamentally changed.

The issue is not just that "CASP applications have become stricter," but rather that Poland has developed a situation that is even more unique compared to other EU member states:

The old VASP has become invalid, MiCA has been fully applicable, but the accompanying MiCA legislation in Poland has not yet been stabilised.

After July 1, 2026, the old VASP in Poland will officially lose its significance

To understand the current situation in Poland, it's imperative to clarify two timepoints.

The main rules of MiCA regarding CASP will be fully applicable starting December 30, 2024, but for virtual asset service providers that were operating under the old regulations of the member states, MiCA allows member states to set a transition period. Poland used a relatively lengthy transition arrangement, allowing the original VASP to continue operation until around July 1, 2026.

However, this window has now closed.

On June 30, 2026, the Katowice Tax Administration published an announcement on the Polish government website, clearly reminding market participants that after the transition period ends on July 1, 2026, the previous registration of virtual currency activities no longer constitutes authorization for providing crypto asset services under MiCA.

The regulatory agency even further reminded that if an institution does not obtain MiCA authorization granted by an EU member state by July 1, it should be regarded as a higher-risk service provider; the original registration authority itself also no longer has the power to issue MiCA CASP authorization.

Therefore, for project parties, purchasing, registering, or promoting so-called "Polish VASP" today can no longer resolve the actual EU market access issue.

An even more unique issue: Poland's own MiCA legislation is still in flux

If it were simply a matter of upgrading from VASP to CASP, Poland and Lithuania would not be fundamentally different.

What makes Poland special is the progress of its domestic supporting legislation.

MiCA, as an EU regulation, is directly applicable, but member states still need to clarify the authorization, oversight, penalties, fees, and specific procedures of the responsible authorities through domestic legislation. On June 23, 2026, the KNF publicly stated that, as Poland's domestic law implementing MiCA had not yet come into effect, Polish public administration entities, including the KNF, had not yet been formally designated as the competent authority for MiCA supervision, except for the regulation of electronic money token issuers. Meanwhile, the KNF also indicated that it had made the appropriate preparations to assume MiCA regulatory responsibilities.

The KNF itself publicly stated in May 2026 that it was ready to assume regulatory responsibilities for the crypto asset market, indicating that CASP licensing would involve management knowledge and experience, capital, and other stricter reviews.

The problem is that domestic legislation has not been successfully finalized.

On May 15, 2026, the Polish parliament passed a new version of the "Crypto Asset Market Law"; on June 11, the president refused to sign the bill. The presidential office stated publicly that it supports establishing a regulatory framework for the crypto asset market but believes the text passed at that time still has issues that need to be adjusted.

Thus, according to currently available official information from Poland, the country has ended the old VASP transition period, but its MiCA implementation system is still in the legal adjustment process.

This creates a very real issue:

Projects should not consider "registering a company in Poland and then directly applying for a Poland CASP" as a process that is highly standardized like Lithuania or Malta.

Therefore, the statement "Poland CASP is low cost" is no longer sufficient

In the past, projects chose Poland based on a few numbers: company registration costs, local employee wages, office expenses, legal fees, and VASP registration cycles.

These factors still exist today, but their importance has diminished.

After the implementation of MiCA, regardless of where the home country is chosen, CAS will not revert CASP to the "light licensing" era of old VASP.

More importantly, if a jurisdiction currently has significant uncertainties in its domestic licensing procedures, then for a company trying to save some operational costs, assuming risks related to application windows, regulatory processes, and subsequent arrangements that cannot be accurately predicted may not be a cost-effective deal.

Therefore, today’s assessment of Poland should shift the question from:

Old question

Where can CASP be obtained most cheaply?

To:

The real question

Where can a project more reliably obtain CASP and long-term service the Polish and other EU markets?

Wanting to enter the Polish market does not necessarily mean needing a CASP in Poland

This is precisely one of the most important changes in the MiCA unified licensing system.

The CASP authorization under MiCA does not have to serve only the country where the license is obtained. A formally authorized CASP can provide approved crypto asset services in other EU member states after notifying them according to cross-border service rules. ESMA has also distinctly differentiated between "old system transitional operations" and "official MiCA authorization": old VASP does not enjoy EU passporting rights, only after obtaining formal MiCA authorization can they enter the unified cross-border mechanism.

Therefore, a project clearly seeking to serve Polish clients does not necessarily need to make Poland its CASP home country.

For instance, companies can first compare Lithuania, Malta, France, Germany, or other member states that have established stable CASP authorization mechanisms, determining the home country based on team, client, banking, and regulatory communication; after obtaining CASP authorization, they can cover Poland through the MiCA cross-border notification mechanism.

This logic differs entirely from the old VASP era.

Previously: To enter Poland → Register Polish VASP.

Now it might be: To enter the entire EU → Choose the most suitable CASP home country → Then passporting to Poland.

So is Poland completely unworthy of consideration?

Not entirely.

Poland remains an important market in the EU, and the KNF has clearly expressed its readiness and regulatory capability to undertake MiCA regulatory responsibilities. (knf.gov.pl)

If a project has core teams, technical personnel, client resources, or long-term operational plans in Poland, waiting for the local regulatory framework to stabilize further and positioning Poland as a future CASP home country may still have commercial rationality. Particularly when a company genuinely wishes to place its main management, office, compliance team, and customer operations in Poland, the local CASP entity can form a more natural match with actual operations.

However, if a project only considers "Poland is low cost," plans to register a shell company there, and the main team is still in Asia, clients cover all of Europe, and banking and payment channels are not in Poland, then there is no need to insist on "Poland CASP" now.

For such projects, it is typically more realistic to prioritize comparisons with EU jurisdictions that can currently stabilize the processing of MiCA applications.

Simple assessments can consider three questions:

First, is Poland your core market?

If not, and if you are only looking to enter the EU through Poland, then you should reconsider the home country for CASP.

Second, are you prepared to establish real operations in Poland?

If there are no local management, personnel, or long-term operational plans, the significance of cost advantages will significantly decrease.

Third, do you currently need "low cost" more, or "certainty"?

For projects that plan to collaborate with banks, institutional clients, and large payment channels, regulatory path certainty is often more important than saving some initial costs.

How we typically support such projects

For projects originally intending to pursue the Polish VASP or Poland CASP paths, the first step is usually not to directly continue with the application but to reassess Poland's position in the overall European framework.

If a project simply needs to enter the Polish client market, it should compare CASP authorizations and passporting pathways in other EU member states; if Poland is indeed the main operating center, it will need to continue tracking local legislation, competent authorities, and formal application mechanisms, and prepare teams and materials according to MiCA standards in advance.

In specific projects, we usually first complete an "EU CASP Jurisdiction Comparison" and "Business Functions and MiCA Service Scope Analysis," breaking down client regions, wallet control, stablecoin conversion, asset transfers, and fiat payments, then determining in which member state to establish a CASP entity.

For teams that already hold a Poland old VASP registration, it is also necessary to separately review existing clients, contracts, website promotions, and funding paths to avoid continuing to treat the old registration as the basis for MiCA market access. The Polish authorities have already made it clear that the old VASP registration will no longer confer the qualification to provide MiCA crypto asset services after July 1, 2026.

If the final choice is another EU member state as a home country, it will also require simultaneous design of passporting notifications for the Polish market, local marketing, client agreements, bank and payment partnerships, and the service and responsibility boundaries between different entities in the group.

Conclusion: Is Poland still a low-cost option?

If the so-called "low-cost option" refers to quickly obtaining a European regulatory identity through relatively lightweight registration like in the old VASP era, then the answer is very clear: that path has ended.

Since July 2026, the old Polish VASP can no longer support MiCA crypto asset services; concurrently, Poland's domestic MiCA supporting system is still undergoing legislative adjustments. For a new project now preparing to enter Europe, simply prioritizing Poland as a CASP home country because of lower company and personnel costs can no longer be considered a truly "efficient" choice. (Gov.pl)

However, if a project genuinely requires the Polish market, MiCA actually offers another answer.

Companies do not have to bind "clients in Poland" and "license must be in Poland" together. Establishing a CASP in an EU member state with a more mature regulatory pathway and better alignment with teams and business, then service Poland through passporting, can be a more worthwhile plan for comparison at this current stage. (European Securities and Markets Authority)

Poland has not lost its market value; what has been lost is the old narrative of "registering a cheap license to enter Europe."