The Rise of Questionable VASP Sales in Poland

With the implementation of the Markets in Crypto-Assets Regulation (MiCA), the previous national authorizations granted under local cryptocurrency regimes across the EU are gradually being phased out. MiCA introduced a unified authorization framework for crypto-asset service providers (CASPs), replacing the fragmented national regimes that previously governed virtual asset service providers (VASPs).

In most EU jurisdictions, including Poland, Lithuanian and Czech Republic existing VASPs are allowed to continue operating temporarily under their national registrations until they obtain a MiCA authorization - or until the transitional period expires provided that they met certain requirements.

According to Poland’s legislation, VASP entities were expected to transition to the MiCA framework by mid-2025, with final compliance required before July 2026, in line with MiCA’s EU-wide transitional deadline.

As MiCA sets significantly higher entry thresholds - including capital requirements between EUR 50,000 and EUR 150,000, local management and compliance staff, and extensive ongoing obligations, many smaller firms find it financially or operationally unfeasible to continue. This has led some owners of previously registered Polish VASPs to consider selling their companies rather than liquidating them.

In recent months, there has been a noticeable rise in the secondary market for Polish VASP companies, some of which are being marketed to foreign buyers as a “fast-track” way to enter the EU crypto market. While some of these offers may be legitimate, prospective buyers should be extremely cautious:

• A Polish VASP registration does not automatically convert into MiCA authorization.

• Operating without MiCA approval after the transitional period is unlawful.

• Capital, staffing, and compliance requirements under MiCA are far more demanding than under Poland’s previous regime.

• Approval timelines can be lengthy, and authorization is not guaranteed.

In short, anyone considering the purchase of an “already registered” VASP company should conduct thorough due diligence and obtain independent legal advice, as quite often consultants selling these companies do not inform the buyers of the tight deadlines and the requirements to be met under the MICA.

Stay vigilant for offers that sound too good to be true — in the world of regulation, there’s no such thing as an easy shortcut.

If you’d like to verify whether your company is compliant, or if you’re interested in applying for a MiCA authorization in Europe or other jurisdictions, please contact our team at Zitadelle Advisory Group via info@zitadelleag.com