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Poland - the only EU state with no CASP regime

Poland is the only EU state without a functioning MiCA CASP licensing regime, because President Karol Nawrocki repeatedly refused to sign the national law. Thousands of VASP companies (~1,298 registered, ~1,500 seeking solutions) cannot legally provide crypto services after 1 July and cannot even apply in Poland. We look at why the law is stuck, the companies options and what it means for EU customers.

Toms Ābeltiņš

5 July 20268 min read

Poland - the only EU state with no CASP regime

Since 1 July 2026 the MiCA transition has ended, but Poland is the only EU member state without a functioning national CASP licensing regime. The reason is a political deadlock: President Karol Nawrocki refused to sign the Crypto-Asset Market Act - vetoed in December 2025 and February 2026, with a third attempt in May 2026 also left unsigned. Without the implementing law the KNF cannot process CASP applications, so no Polish company can get a licence even at home. The ~1,298 companies in the VASP register (frozen since 30 Dec 2024) cannot legally operate after 1 July; sanctions can reach 12.5% of turnover. A fact-based review of the deadlock, the companies options and the impact on EU customers.

What happened

Since 1 July 2026, the MiCA transition period has ended across the EU, and providing crypto-asset services without a CASP licence breaches directly applicable EU law. Poland is the exception in this picture: it is the only EU member state without a functioning national CASP licensing regime. As a result, thousands of Polish crypto companies that operated under the old VASP registration have ended up in a regulatory deadlock.

The core paradox: Polish companies cannot even apply for a CASP licence in their home country, because the national implementing law has not been passed.

Why Poland has no MiCA / CASP regime

MiCA is a directly applicable EU regulation, but each member state must pass a national implementing law that designates the competent supervisor and the procedures. In Poland, this law (Ustawa o rynku kryptoaktywów - the Crypto-Asset Market Act) is stuck in a political deadlock.

President Karol Nawrocki repeatedly refused to sign it: the law was vetoed in December 2025 and February 2026, and the third version passed by parliament in May 2026 was also left unsigned. In effect, this is a triple blockage between the government and the president.

The practical consequence is direct: the Polish Financial Supervision Authority (KNF) was intended to be the CASP supervisor, but without the implementing law it cannot process CASP licence applications. That means no Polish company can obtain a Polish CASP licence. The KNF stated plainly back in February 2026 that services could be provided without authorisation only until 1 July.

What the old VASP register means

Until MiCA, Poland relied on a national VASP register (Rejestr działalności w zakresie walut wirtualnych), maintained by the Katowice tax administration. As of January 2026 it held around 1,298 actively registered companies, and new entries have been frozen since 30 December 2024. Latvian and other sources cite around 1,500 Polish crypto companies seeking solutions, while broader estimates go as high as ~2,000 firms.

Crucially, VASP registration is not equivalent to a MiCA CASP licence. It does not grant EU passporting rights and, after 1 July, no longer confers the right to legally provide regulated crypto services.

Can VASP companies still operate?

The short answer: no - not as regulated crypto-asset service providers. After 1 July 2026, providing crypto-asset services without CASP authorisation is a breach of directly applicable EU law. No member state may extend the transition period.

Moreover, the consequences are not symbolic: for breaching the authorisation requirement, sanctions under the MiCA framework can reach up to 12.5% of total annual turnover. So for most Polish VASP companies, carrying on "business as usual" is not a realistic option.

What the ~1,500 companies plan

Polish VASP companies have three practical paths:

1. Relocate to another EU state and passport back to Poland (MiCA Article 65). The company obtains a CASP licence in another member state and, through cross-border notification, serves Poland too. The most popular destinations:

Czechia - 3-6 months, fast-track for former VASPs;
Lithuania - 4-7 months, fast-track;
Cyprus - 6-12 months;
Latvia is also actively recruiting Polish companies.

Important: this is not a formality trick. The actual head office must move, a local compliance officer is required, and there must be real presence in the licensing country - "letterbox" solutions do not survive regulatory scrutiny.

2. An orderly wind-down. For most small VASPs this will be the real outcome. Any company that had not submitted a full licence application elsewhere by around April 2026 could not realistically obtain a licence by 30 June.

3. Wait for the Polish law. But in the meantime regulated services cannot be provided, and the first KNF-issued licences are realistically expected only in late 2026 or early 2027 - and only if the law is finally passed.

What happens to EU and Polish customers

During this transition, Polish (and other EU) customers can be legally served only by CASPs licensed elsewhere in the EU. In practice, this means that Polish users who relied on a local VASP platform must expect service interruptions and move to a platform with a valid MiCA licence.

The advice for users is the same as in the Binance and Goobit cases:

Follow the platform's official announcements about service availability;
Do not stay with an unlicensed provider - move to a MiCA-licensed CASP while access to funds is open;
Keep your transaction history for tax purposes.

Importantly, a company losing authorisation is not in itself a freezing of customer funds, but it creates a real risk to service continuity if the company chooses to wind down.

The Baltic and Latvian angle

Poland's situation is a direct opportunity for the Baltic states. Latvia is actively recruiting Polish crypto companies - Labs of Latvia and others are running presentations on the options for obtaining a MiCA licence in Latvia, and Latvijas Banka has already issued nine MiCA CASP licences. Lithuania, with its fast-track procedure, is one of the most popular relocation destinations.

For the region, this means a potential influx of new licence applications, expertise and jobs - if Baltic regulators can offer a predictable and fast process. At the same time, it raises competition between jurisdictions over which will become the EU home for Poland's crypto business.

The bigger picture

Poland's case highlights the uneven implementation of MiCA. Although the regulation is uniform, its practical application depends on national political will - and in Poland it is stuck. Together with Binance's withdrawal from the EU market and Goobit's rejection in Sweden, the Polish deadlock is another signal that the MiCA transition is driving real consolidation and relocation, not just an administrative formality.

In the long run, Poland will most likely pass the law and the KNF will start issuing licences, but until then the Polish crypto industry is forced either to relocate or to stop.

What comes next

Poland's legislative process - whether and when the Crypto-Asset Market Act is passed;
KNF readiness - how quickly real licensing begins once the law is in place;
The relocation flow - how many Polish companies choose Lithuania, Czechia, Cyprus or Latvia;
The stance of ESMA and the Commission - whether EU-level pressure is applied to Poland.

Norriwire Briefing