Serving the Polish crypto market under MiCA

Poland once had one of Europe's largest national registers of virtual asset service providers, maintained under its AML legislation. MiCA has applied directly since 30 December 2024, but a regulation of this kind still needs a national act to designate a competent authority, give it supervisory and sanctioning powers and organise the authorisation procedure. Poland's draft crypto-assets market act, which would have entrusted those roles to the KNF, was passed by parliament and vetoed by the President three times, most recently on 11 June 2026, and the Sejm did not override the veto.

Poland had notified ESMA of a six-month transitional period, and in February 2026 the KNF stated that unauthorised providers could operate only until 1 July 2026 in any event. As a result, a Polish-incorporated firm currently has no domestic body to which it can submit an Article 62 MiCA application, yet providing crypto-asset services without authorisation is a breach of EU law. The President's stated objections concerned the length of the bill, the level of sanctions and KNF powers to block accounts and websites rather than MiCA itself.

In practice the Polish market has not closed: it is being served by CASPs authorised in other Member States and passported into Poland. Polish founders have relocated their regulated entity to another jurisdiction, operated as agents or distributors of an authorised CASP, or restricted their activity to services outside MiCA's scope. Each route has legal, tax and substance consequences that need to be planned carefully.

A further legislative attempt is expected, and commentators anticipate that any new act could take effect no earlier than 2027. Firms that intend to hold a KNF authorisation eventually can use the interval to build a MiCA-grade governance and compliance framework, often first through an authorisation in another state. We review the position continuously and will update this page when a Polish competent authority is designated.