Is Poland Still a Low-Cost Gateway to the EU CASP Market?
Is Poland still a low-cost gateway to the EU’s Crypto-Asset Service Provider (CASP) regime? As of mid-2026, the answer has fundamentally changed.
Poland’s previous light-touch VASP registration system, once an attractive EU entry point, is no longer valid for providing MiCA-regulated services after its transition period ended on July 1, 2026. Furthermore, Poland's domestic legislation implementing MiCA is still undergoing final adjustments, creating uncertainty for direct CASP authorization.
This shift means the old logic—choosing Poland primarily for low registration and operational costs—is no longer viable. Under MiCA, a CASP license is no longer a "light" registration, and Poland's current regulatory limbo adds unpredictable delays and risks.
For projects seeking EU market access, a more practical strategy is emerging: obtain a MiCA CASP authorization in another EU member state with a stable regulatory framework (e.g., Lithuania, Malta), then use MiCA's passporting rights to serve the Polish market. This approach prioritizes regulatory certainty and EU-wide access over marginal cost savings.
Poland remains a significant EU market. It is a viable CASP home country only for projects with a genuine, long-term operational presence there. For others, especially those with teams and clients across Europe, starting the CASP process elsewhere in the EU is now the more efficient and reliable path. The era of using a Polish entity as a cheap, quick EU regulatory foothold is over.
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