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Law · MiCA · AML/KYC

Law and regulatory compliance in the tokenization process

We provide full legal support for Web3 projects – from choosing the jurisdiction to preparing the documents required for a token issuance.

  • MiCA analysis
  • Offering documents
  • AML/KYC

What you gain

  • Choice of jurisdictionAn EU member state or a non-EU jurisdiction – matched to the project.
  • Complete documentationWhitepaper, terms and conditions, disclaimers, agreements.
  • AML/KYCInvestor verification policies and procedures.
  • Legal auditRegulatory due diligence before issuance.

About the service

Advisory and legal

Legal and regulatory compliance

Preparing a tokenization project properly from a legal perspective is the basis of its legality and credibility. In the Web3 world, where regulations change rapidly, you need the support of experts who combine knowledge of blockchain technology with legal practice.

At Tokenuj.pl we offer comprehensive legal support for ICO, IDO and STO projects and for the tokenization of real-world assets. We align the strategy with the applicable regulations – both in Poland and in foreign markets – and help prepare the project for AML and KYC requirements and for regulations such as MiCA, SEC and FINMA.

Our legal services include:

Service scope

What the service covers

  • Project analysis and token classification
    • Assessment of whether the token is a utility, security or hybrid token
    • Verification of potential regulatory risks
    • Selection of the appropriate issuance model (ICO / IDO / STO)
  • Preparation of legal documentation
    • Terms and conditions, privacy policies, AML/KYC policies
    • Investor agreements, token issuance terms (T&Cs)
    • Whitepaper prepared against investor disclosure requirements
  • Support in choosing a jurisdiction
    • Advice on where to locate the company or fund (e.g. UAE, Switzerland, El Salvador, Estonia)
    • Registration and structuring of SPVs, DAOs, funds or token vehicles
    • Oversight of operational compliance with local regulations
  • Regulatory compliance
    • Aligning operations with European (MiCA), US (SEC), Swiss (FINMA) and other regulations
    • Implementation of AML/KYC procedures and investor identification systems
    • Support with audits and filings, including white paper notification in the competent EU member state

MiCA white paper

What exactly you get with a white paper

  • A document on the ESMA template
  • A note explaining the classification
  • An iXBRL file following the ESMA taxonomy
  • Help with LEI and DTI
  • Notification in the competent EU member state
  • Handling the authority's questions
  • A timeline counted back from the listing date (at least 20 working days between notification and publication)

Notification of a white paper is not its approval by the supervisory authority. The scope of requirements depends on the token classification.

See fixed-price products

Legal status

Poland without an act: what it means for the issuer

  1. 30 December 2024MiCA
  2. Three vetoesThe last on 11 June 2026
  3. 1 July 2026End of the CASP transitional period
  4. September 2026The Sejm does not override the veto
  5. No authority

For the issuer

  • MiCA applies directly.
  • No supervisory authority has been designated.
  • According to UKNF, a white paper cannot be filed in Poland, and a token with a white paper from another EU member state may be offered in Poland.

Information only, not legal advice. As of 7 November 2026.

Live Q&A 26 November, 12:00 CET: Tokenization in Poland without an act

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Process

How we work

  1. 01 · Analysis

    We verify the asset, business model and funding goals.

    Deliverable:potential report
  2. 02 · Strategy

    Issuance model, jurisdiction, blockchain network and tokenomics.

    Deliverable:issuance strategy
  3. 03 · Documentation

    Whitepaper, offering documents, AML/KYC, SPV structure.

    Deliverable:complete documents
  4. 04 · Technology

    Audited smart contracts, issuance website, investor dashboard.

    Deliverable:issuance infrastructure
  5. 05 · Issuance

    Technology, communication. The issuer runs the offering.

    Deliverable:technical readiness
  6. 06 · Support & growth

    Listings, investor communication, community growth.

    Deliverable:post-issuance servicing

Knowledge base

Read more

Knowledge baseIn Polish

Regulatory due diligence tokena przed emisją: jak krok po kroku przeprowadzić analizę regulacyjną

Jeśli planujesz emisję tokena, regulatory due diligence pokazuje, jakie wymogi dotyczą projektu, zanim ruszysz z kampanią. W artykule znajdziesz krok po kroku, jak przeprowadzić analizę regulacyjną i ograniczyć ryzyko prawne tokenizacji.

Read the article: Regulatory due diligence tokena przed emisją: jak krok po kroku przeprowadzić analizę regulacyjną

FAQ

Frequently asked questions

  • Yes, tokenization is legal in Poland and throughout the European Union, provided the project is carried out in line with the rules on offering digital assets. At Tokenuj we build models, smart contracts and documents around the requirements that apply to the given token.

  • If the token falls under MiCA, compliance means preparing an issuance or tokenization so that it meets EU requirements on transparency, the way tokens are offered, data retention and investor protection. In practice, it is about designing the documents, the tokenomics and the smart contract itself according to clear rules.

  • Real estate, precious metals, shares in PSA and S.A. companies, company assets, investment products and many other resources that can be valued and divided into units can all be tokenized. Valuation alone does not settle it: whether and how an asset can be tokenized depends on the token's classification and how it is offered.

  • A standard process takes from several weeks to several months, depending on the scope, the type of asset and whether the token falls under MiCA. Most importantly, we run everything step by step, so from the outset you can see the timeline and what is happening at any given moment.

  • Sometimes yes, sometimes no; it all depends on the type of token and how it is offered. That is why we analyse the project at the start and tell you straight away whether a licence is required and, if so, which steps are needed.

  • The A-to-Z model reduces the coordination risk that usually arises when working with several providers at once. You have one team responsible for law, technology, documents and implementation. This does not remove legal or technological risk.

Information only, not legal advice. As of 7 November 2026.

Free consultation

Let's talk about tokenizing your asset

Tell us about your project. Within 24 hours we will come back with a time for a call where we assess the tokenization potential, the issuance model and the next steps.

  • Reply within 24h
  • No obligation
  • Confidential (NDA)
Michał Chodzynski – Founder
You will talk to MichałMichał Chodzynski · Founder

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