KYB for Poland under MiCA & AMLR — what teams need before 1 July 2026

Poland has the sharpest near-term compliance catalyst in the EU. This guide walks through the regulatory stack, who it affects, and how to verify Polish counterparties — KRS registry, NIP and sanctions — through one API before the deadline.

The deadline

1 July 2026 is the MiCA CASP authorisation cut-off. Poland's national implementing law was vetoed, leaving roughly 1,300 registered VASPs with no domestic licensing route. From 2 July, a Polish VASP without a MiCA authorisation (domestic or passported) must cease operating or redomicile — triggering fresh KYB on new structures and re-screening of counterparties.

The regulatory stack

How to verify a Polish counterparty

Two calls cover the company leg: a registry-resolution search against the KRS register (returning NIP, REGON, legal form, PKD, address and capital), and a sanctions screen against the EU, UN, OFAC and UK OFSI lists with scored fuzzy matching. One Bearer key also covers Spain, France, the UK, Ireland and Norway.

Honest scope

KRS company registry is live (~732K active entities). KRZ insolvency and CRBR beneficial-ownership are not yet included; collect UBO by self-declaration. Sole traders (CEIDG) are a separate register and not covered.

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Frequently asked questions

What happens to Polish crypto firms on 1 July 2026?
Under MiCA, crypto-asset service providers (CASPs) need an authorisation to operate in the EU. Poland has not enacted its national MiCA implementing law (the bill was vetoed), so Polish VASPs have no domestic authorisation route. From 1 July 2026 a Polish VASP without a MiCA authorisation — domestic or passported from another member state — must cease operating or redomicile. This triggers fresh KYB on newly incorporated structures and re-screening of counterparties.
Are EU/UK firms affected by the Polish MiCA situation?
Yes — any PSP, EMI or CASP that onboards or transacts with Polish crypto/payment counterparties must verify the entity, screen it against sanctions lists, and re-assess as those counterparties passport, redomicile or wind down. The EBA sanctions-screening guidelines (in force 30 December 2025) make programmatic screening of the entity, its directors and owners a baseline expectation.
When does the EU AML Regulation (AMLR) apply in Poland?
The EU AML Regulation (Regulation (EU) 2024/1624) applies from 10 July 2027, with AMLA technical standards arriving through 2026. Because procurement and tooling decisions run 12–18 months ahead of the deadline, Polish obliged entities are selecting KYB/CDD vendors now.