The Sejm has passed a new law on crypto-assets in Poland.

Introduction

The situation regarding Polish Virtual Asset Service Providers (“VASPs”) is becoming increasingly tense. Until recently, Poland was one of the most popular jurisdictions in the European Union (“EU”) for the crypto industry, but today, despite the fact that the transition period under the Markets in Crypto-Assets (“MiCA”) ends on 30 June 2026, as of May 2026, Poland still lacks a national act implementing the MiCA.

The importance of implementing the MICA into Polish national law

In a statement dated 10 February 2026, the Polish Financial Supervision Authority (“KNF”) stated that companies wishing to carry out activities falling within the scope of MiCA in Poland will only be able to do so on the basis of licenses obtained in other EU countries, as there is no competent authority for the crypto-asset market in Poland, which makes the licensing process in Poland impossible.

The KNF also emphasized that the transition period established by MiCA cannot be altered by either national legislation or a KNF decision. It follows that, should a national law on crypto-assets not be enacted, Polish VASPs will effectively be unable to operate legally without a license obtained in another EU Member State under the passporting mechanism.

When might the law take effect?

Although the Bill has already been passed by the Sejm, the process is still ongoing. If the Senate adopts the Bill without amendments, it will be submitted to President Karol Nawrocki in a version that differs only marginally from the one he had previously vetoed.

This leaves open the question of whether the President will sign the bill or exercise a veto for the third time. During the second reading in the Sejm, Minister Zbigniew Bogucki suggested that the rejection of 15 presidential amendments could lead to another presidential veto, particularly since those amendments were rejected at every stage of parliamentary consideration.

Is there any chance of obtaining a crypto license in Poland before the end of the transition period?

As noted earlier, the transitional period under MiCA expires on 30 June 2026. Even if the third Bill is adopted without delay, the minimum formal timeframe for obtaining a Crypto-Asset Service Provider (“CASP”) license under MiCA is 65 working days, assuming the application is complete, and regulators do not issue substantial follow-up requests. In practice, however, the licensing process is likely to take longer.

As a result, Poland is unlikely to issue CASP licenses before the end of the transition period, leaving Polish crypto companies unable to continue operating under the new regime from 1 July 2026.

Therefore, businesses that were planning to obtain a license in Poland should consider selecting another jurisdiction without delay, and the legal team at Manimama Law Firm can assist with this process.

At Manimama Law Firm

At Manimama Law Firm, we assist businesses in navigating this regulatory environment. We support documentation, manage application processes, and develop long-term compliance strategies for crypto-related businesses.