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MiCA in Poland – update February 2026

MICA in Poland update February 2026 - second Presidential VETO

On 12 February 2026, the President of Poland once again vetoed the Act on the Crypto-Assets Market.

This is the second veto concerning the same legislative initiative intended to establish a national legal framework for adopting MiCA in Poland and enabling a fully operational supervisory regime for the crypto-asset market.

While MiCA, as an EU Regulation, applies directly across all Member States, the absence of a domestic adopting act means that Poland still does not have a fully operational system for granting a CASP license in Poland or supervising crypto-asset service providers (CASPs) at the national level.

Below, I explain what has happened since the first veto in December 2025, what the latest decision means for MiCA in Poland, and what practical implications it may have for businesses planning to obtain a CASP license in Poland.

Second attempt to adopt the MiCA in Poland

Following the first veto, the government did not withdraw the bill. As early as 10 December 2025, only a few days after the President’s decision, the draft was reintroduced into the parliamentary process.

The move was made quickly. The draft, Sejm print no. 2064, constituted a continuation of the previously adopted act. No material changes were made to the regulatory structure or to the supervisory model set out in the bill. The core framework remained essentially identical to the version that had already been vetoed.

After being adopted again by the Parliament, the act was submitted to the President on 26 January 2026. This initiated the constitutional deadline for signing the bill or exercising the right of veto.

From a legislative standpoint, it was reasonable to question whether re-adopting the act in largely unchanged form would lead to a different outcome. The decision of 12 February 2026 confirmed that this strategy did not address the concerns previously raised.

Second veto of the President concerning the Crypto-Assets Market Act

On 12 February 2026, President Karol Nawrocki once again refused to sign the Polish Act on the Crypto-Assets Market. As a result, the legislative process has been halted for the second time at the stage of presidential review.

In a statement published on X, starting at minute 3:51 of the recording, the President indicated that the bill submitted for signature was essentially identical to the version previously vetoed.

“I received for the second time a draft that is practically identical to the one I had already vetoed. One detail was changed, but the fundamental errors were not removed.”

He also addressed the decision to re-adopt the bill in largely unchanged form in particularly firm terms.

“I will not sign bad law simply because it has been passed again by a parliamentary majority. Bad law passed even a hundred times remains bad law.”

The President further stated that if the government had genuinely expected his signature, it should have taken into account the concerns previously raised.

“If the government truly cared about obtaining the President’s signature, it should have addressed the objections that had already been expressed. That did not happen.”

The decision was framed within a broader context of legislative responsibility and the future development of the market.

“In matters of such importance, responsibility is required, not a legislative tug-of-war.”

“Poland should attract innovation, not push it away.”

At the same time, the President invited the government to cooperate on preparing a new draft.

“I invite the government to engage in substantive cooperation on a new act that will ensure security of transactions, tax clarity, and proper conditions for the development of modern technologies.”

“We can begin as early as tomorrow and complete the work quickly.”

In conclusion, he emphasised that his decision was based on responsibility rather than political considerations.

“My decisions are not directed against anyone. They are taken in the name of responsibility for the state.”

The second veto means that the bill once again returns to the Polish Parliament. Parliament may attempt to override the veto with a three-fifths majority or decide to continue work on a revised version of the act. Given the current parliamentary arithmetic, an attempt to override the veto appears unlikely and may not even be initiated.

KNF statement issued shortly before the second veto

Two days before the President’s decision, on 10 February 2026, the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) published its position on the legal situation of the crypto-asset market.

The full text of the KNF statement is available here:
https://www.knf.gov.pl/aktualnosci?articleId=96997&p_id=18

The statement addressed the consequences of Poland’s failure to designate a competent authority within the meaning of the MiCA Regulation, as well as the implications of the prolonged legislative process.

Although the KNF statement did not refer directly to the anticipated presidential decision, its publication immediately preceded the second veto and became an important part of the regulatory context.

KNF emphasised that until national implementing provisions are formally adopted, Poland remains in a transitional situation. MiCA applies, but there is no fully operational supervisory infrastructure enabling the granting of authorisations to crypto-asset service providers, including entities seeking a CASP license in Poland.

At the same time, KNF clearly identified 1 July 2026 as a key date resulting from the transitional provisions of MiCA. Until that date, certain activities may continue within defined limits. After that point, the position of domestic entities that have not obtained authorisation may change significantly.

From a market perspective, this creates a potential risk of competitive asymmetry. Entities authorised under MiCA in other EU Member States may provide services in Poland on a cross-border basis, while domestic operators remain in a state of regulatory uncertainty pending the adoption of a national implementing act.

What’s next for a CASP license in Poland?

The second veto means that the national act implementing MiCA will not enter into force in its current form. The draft returns to the Polish Parliament and will either be amended once again or replaced with a new legislative initiative.

The repeated veto makes it clear that maintaining the current regulatory concept will not lead to the President’s signature. Without material structural changes, the bill has no realistic prospect of being enacted.

MiCA, as an EU Regulation, applies directly. The issue lies in the absence of national implementing infrastructure, including the designation of a competent authority, a formal authorisation procedure, and operational supervisory rules for CASPs.

The KNF statement of 10 February 2026 confirms that the situation has practical implications. 1 July 2026 remains a key date under the MiCA transitional regime. Entities planning to operate as crypto-asset service providers should take this timeline into account when making structural and operational decisions.

For the market, the conclusion is straightforward. The legislative process may be prolonged, but the core MiCA requirements relating to governance, AML and CFT compliance, risk management, and capital adequacy remain unchanged. The adoption of a national act will affect the authorisation procedure, but it will not alter the regulatory fundamentals.

Entities seeking to obtain a CASP license in Poland should use the current period to finalise documentation, refine their business model, and strengthen their compliance framework. When the national authorisation regime becomes operational, those who are prepared will be in a significantly stronger position.

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