Lithuania vs Poland: CASP authorisation compared

Every Member State must designate, in its own national law, the authority responsible for the functions MiCA gives it. Poland has not completed that step for crypto-asset service providers. The Urząd Komisji Nadzoru Finansowego said so in its own words, first in a formal position in February 2026 and again in a communication in June 2026.

What is identical, because MiCA harmonises it

In principle, all of this applies equally in Poland. In practice none of it can be exercised there yet, because there is no authority to exercise it.

• The list of crypto-asset services that require authorisation (MiCA Article 3 and Annex IV)
• Minimum capital of EUR 50,000 / EUR 125,000 / EUR 150,000 by class (Annex IV)
• The fixed-overheads test: prudential safeguards at the higher of the Annex IV floor and a quarter of fixed overheads (Article 67)
• Application contents (Article 62(2)), and the RTS and ITS that specify their form
• Establishment conditions: registered office, effective management in the Union, at least one Union-resident director (Article 59)
• Governance and fit-and-proper requirements (Article 68)
• The mandatory refusal grounds (Article 63(10))
• EU passporting by notification, with the 15-calendar-day backstop (Article 65)

What actually differs

The transitional period ended anyway, and cannot be extended

MiCA Article 143(3) let firms carry on under existing national law until 1 July 2026, or until they obtained or were refused an authorisation, whichever came first. That date passed. UKNF is explicit that the deadline cannot be extended by statute or by a decision of KNF.

So Polish firms reached a deadline they could not meet, through a route that did not exist. UKNF states the consequence plainly: after 1 July 2026, absent a designated authority, domestic entities lose the ability to provide crypto-asset services under Article 143(3) until they obtain an authorisation, and that procedure can only begin once an authority is designated by statute.

The old Polish register was never a financial licence

The firms affected are mainly those entered in the register of virtual currency activity kept by the Tax Administration Chamber in Katowice: a tax administration body, not a financial supervisor. On 19 June 2026 its Director stated that an entry in that register is not an authorisation for activity regulated by MiCA, and that after 1 July it would not entitle the holder to operate either in Poland or abroad.

If anyone offers you a Polish crypto company on the strength of a register entry, that is the sentence to put in front of them.

Passporting did not work in the other direction either

One detail that catches people out: during the transitional period, entities operating under national law were outside MiCA, so the MiCA rules on cross-border provision did not apply to them. A Polish register entry never conferred a passport. It was a domestic permission, and it has now lapsed.

Who Lithuania suits better

Anyone who needs an authorisation. That is the whole comparison at present.

More usefully: a firm whose market is Poland is not blocked. UKNF confirms that cross-border provision into Poland under MiCA remains possible, exactly as before 1 July. An authorisation from the Bank of Lithuania, notified to Poland under Article 65, lets you serve Polish clients with no Polish entity, office or licence, and Article 59(7) removes any requirement for a physical presence in the host state. How the notification runs.

Who Poland suits better

Nobody seeking authorisation today. There is a reasonable case for waiting if you are a Polish business with Polish management, Polish counsel and a domestic client base, and the act is close to passing, but that is a bet on a legislative timetable, and the cost of being wrong is being unable to operate at all in the meantime.

The full cost of entry, not the capital figure

There is no Polish fee to compare, because there is no procedure to charge for. The real cost of choosing Poland right now is time: the period between the lapse of the old regime and whenever an authority is designated, during which a domestic firm cannot lawfully provide services and cannot apply to fix that.

Risks and uncertainties in this comparison

• This is the most time-sensitive page on the site. The position is as stated by KNF on 23 June 2026. We checked KNF's eight most recent communications on 14 September 2026 and found nothing superseding it, but the absence of an announcement is not proof that the act has not passed. Check KNF's communications before relying on this.
• If the act enters into force, everything on this page changes at once: an authority appears, applications open, and fees and procedure become comparable for the first time.
• Nothing here bears on KNF's role for e-money token issuers, which is unaffected.

Primary sources

• Read 2026-09-11 Bank of Lithuania: transitional period ends 31 December 2025
• Read 2026-09-11 Bank of Lithuania: fourth CASP authorisation granted
• Read 2026-09-14 UKNF position on the absence of a designated competent authority for the crypto-asset market (PDF, 10 February 2026)
• Read 2026-09-14 KNF: information on the end of the transitional period for crypto-asset service providers (23 June 2026)

Questions

Can I get a CASP licence in Poland?

Not at present. The Urząd Komisji Nadzoru Finansowego stated that no Polish public authority has been designated as the competent authority for crypto-asset service providers under MiCA, because the implementing act has not entered into force. It also stated that an authorisation procedure can only be initiated once a competent authority is designated by statute.

Is KNF the regulator for crypto in Poland?

Only in part. KNF is the competent authority for issuers of e-money tokens. For crypto-asset service providers, for issuers of asset-referenced tokens, and for offerors of other crypto-assets, no Polish authority has been designated. KNF appears on ESMA’s list of competent authorities with a note recording that it has not been formally designated.

Is a Polish virtual currency register entry a MiCA licence?

No. On 19 June 2026 the Director of the Tax Administration Chamber in Katowice stated that an entry in the Polish register of virtual currency activity is not an authorisation for activity regulated by MiCA, and that after 1 July it would not entitle the holder to carry out virtual currency activity either in Poland or abroad.

Can I still serve Polish clients?

Yes, from another Member State. UKNF confirmed that cross-border provision of crypto-asset services in Poland under MiCA remains possible after 1 July 2026. A provider authorised by the Bank of Lithuania can notify Poland under Article 65 and serve Polish clients without any Polish entity, office or licence.