On-shore VASP in Poland

Poland's pre-MiCA regime is the register of virtual-currency activity under Arts 129m–129z of the AML Act of 1 March 2018, kept for the Minister of Finance by the Director of IAS Katowice (not GIIF); it has accepted no new entries since 30 December 2024, and since 1 July 2026 an entry confers no right to provide crypto-asset services.

Virtual-currency activity under the AML Act of 1 March 2018 may be carried on by a natural person, a legal person or an organisational unit without legal personality (Art 129n(1)); a Polish company is not required, although the register has accepted no new entries since 30 December 2024.

At least one individual from the management board of the Polish legal entity must have their residence in Poland or possess a Polish citizenship.

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The AML Act (Art 129n) requires that a natural person running virtual-currency activity, or the partners, representatives and management of a legal entity, its managers and beneficial owner, have no final conviction for listed intentional offences — including against economic trading, money and securities, property, documents, for profit — or an intentional fiscal offence.

The AML Act of 1 March 2018 sets no minimum capital requirement for entry in the virtual-currency register: Arts 129n–129o require only a clean criminal record and knowledge or experience; the register has accepted no new entries since 30 December 2024.

Future MiCA Impact: MiCA will introduce capital requirements for Crypto-Asset Service Providers (CASPs), ranging from €50,000 to €150,000 depending on the type of services provided.

Internal AML/CTF Procedures: Develop and implement robust internal anti-money laundering and counter-terrorist financing procedures, including a risk assessment specific to the business and its clients.

AML Officer: Appoint a designated individual responsible for AML/CTF compliance (AML Officer or Compliance Officer).

Customer Due Diligence (CDD): Implement procedures for identifying and verifying the identity of clients, including beneficial owners, and understanding the purpose and nature of business relationships. This involves collecting identity documents, verifying data, and screening against sanctions lists.

Ongoing Monitoring: Conduct ongoing monitoring of client relationships and transactions to detect suspicious activities.

Transaction Monitoring: Implement systems to monitor transactions for unusual patterns or thresholds.

Reporting: Report suspicious transactions and activities to GIIF.

Record-keeping: Maintain records of client identification data and transactions for at least 5 years.

Training: Provide regular AML/CTF training for relevant employees.

The competent organ for Poland's register of virtual-currency activity is the minister responsible for public finance (AML Act Art 129p), who by ordinance of 25 October 2021 (Dz.U. 2021 poz. 1964) designated the Director of the Revenue Administration Regional Office (IAS) in Katowice to keep the register.

Under Art 129o of Poland's AML Act (consolidated Dz.U. 2025 poz. 644), natural persons carrying on virtual-currency activity must have knowledge or experience in it, deemed met by completing a training course on its legal or practical aspects or by at least one year of documented work in that activity.

Poland's AML Act of 1 March 2018 (consolidated Dz.U. 2025 poz. 644) contains no client-asset segregation rule for virtual-currency custodians; segregation is required of crypto-asset service providers by MiCA Art 75(7), applicable since 30 December 2024, but no CASP is authorised in Poland (ESMA interim register, last update 31 Aug 2026), so the rule reaches Polish clients only through CASPs authorised in other member states.

Requirement: Under MiCA, entities wishing to provide custody and administration of crypto-assets will need to obtain an authorization from their competent national authority (likely the Polish Financial Supervision Authority – KNF). This authorization will be passportable across the EU.

Conditions for Authorization: CASPs will need to meet stringent organizational, operational, and prudential requirements, including:

Requirement: MiCA explicitly mandates the segregation of client crypto-assets and funds. Article 67 specifies that CASPs providing custody services must:

Exchanging one virtual currency for another is not a taxable event in Poland: Art 17(1f) of the PIT Act defines a paid disposal as an exchange for legal tender, goods, services or property rights other than virtual currency, and expenses linked to a crypto-to-crypto exchange are not deductible costs (Art 23(1) pkt 38d).

Income of Polish individuals from the paid disposal of virtual currency is taxed at a flat 19% (PIT Act Art 30b(1a)); the income is the difference between that year's disposal revenue and the costs determined under Art 22(14)–(16) (Art 30b(1b)).