MiCA: What’s Going to Happen with VASP Registration Holders in Poland?

The introduction of MiCA (Markets in Crypto-Assets Regulation) is one of the most important regulatory changes for businesses providing crypto-asset services in Europe. In Poland, this means that existing VASP (Virtual Asset Service Provider) registration holders will need to transition into the new CASP (Crypto-Asset Service Provider) licensing regime if they want to keep their business contuinuty.

Over the past months, many VASP registration holders have asked how long they can continue operating under their current registration — and what changes to expect. Here’s what you need to know.

MiCA Law in Poland: Still Pending

The Polish Cryptoasset Act, which will serve as the country’s implementation of MiCA, has not yet been finalized. The process is still ongoing in the Polish Parliament:

• The government has approved the draft text and forwarded it to Sejm (the lower chamber).

• Sejm has reviewed it and referred it to the Public Finance Committee.

• It must still undergo a second and third reading, after which it will move to the Senate and finally require the President’s signature.

At this stage, the Act is expected to be adopted around December 2025 or January 2026. However, this timeline could easily shift further into 2026.

How Long Can VASPs in Poland Operate?

The current draft of the law sets out transitional arrangements, often referred to as the “grandfathering period.”

• VASPs that apply for a CASP license within 3 months of the law’s entry into force, and whose applications are confirmed as complete, may continue operating while their application is under review — for up to 9 months after the law takes effect.
  
• VASPs that do not apply must stop operating 4 months after the law takes effect.

Example

If the law enters into force on 1 January 2026:

• VASPs would have until 1 April 2026 to submit their CASP application.
  

• If confirmed complete, they could continue operating until 30 September 2026 (or until the CASP license is granted or rejected, whichever comes first).
  

These dates are only illustrative. The actual deadlines depend entirely on when the law enters into force. If adoption is delayed, the transition periods will move forward accordingly.

The takeaway is simple: VASPs will not lose their right to operate immediately — there will be a grace period to adjust and apply.

 

What This Means for Your Business

For VASP registration holders in Poland, this means, you can continue your business operations. Even though the law is still pending, businesses will have time to prepare. However, waiting until the last moment could lead to risks:

• Licensing delays if many companies submit applications at once.
• Regulatory scrutiny if compliance systems aren’t ready for MiCA.
• Operational uncertainty if internal processes aren’t aligned with the new framework.

Preparing in advance is the safest approach.

 

What You Can Do Now

There is no immediate action required, but we recommend that businesses use this period wisely. Steps to take now include:

• Start preparing application documents — don’t wait until the law is passed.
• Review AML/CFT frameworks — MiCA will raise the bar for anti-money laundering and reporting obligations.
• Monitor the legislative process — deadlines will shift depending on when the Act enters into force.

How Complium Can Help

At Complium, we work with crypto and fintech companies across Europe, guiding them through licensing and compliance. In Poland, we can help VASPs prepare for the transition to CASP licensing by providing:

• Application readiness support — ensuring documents and filings are complete and regulator-ready.
• AML and compliance assistance — upgrading your frameworks to MiCA standards.
• Monitoring and updates — keeping you informed on every stage of the law’s adoption.

The Polish MiCA law is not yet final, but planning ahead will help avoid unnecessary stress when the transition begins. Contact us today and schedule a meeting to start preparing your CASP application with confidence.