Poland has yet to adopt national legislation transposing the MiCA, Regulation (EU) 2023/1114, but legislative work is gaining momentum. According to information provided by Gazeta Prawna, the government is set to update the draft of Polish Act on Crypto-asset Market in March 2025. What does this mean for CASP license in Poland?
Recent updates on Poland's MiCA adaptation
The latest updates on new Polish Act on Crypto-assets Market come from “Gazeta Prawna”. The “Gazeta Prawna” published a report summarizing key points from a seminar organized by the European Financial Congress and the Polish Financial Supervision Authority (KNF). Deputy Minister of Finance Jurand Drop shared insights on the progress of the legislation and outlined changes to the draft law.
The Ministry of Finance has been collecting feedback from industry participants for months. It received over 700 pages of comments from businesses, regulators, and other stakeholders. Some of these suggestions have shaped the current version of the draft law.
One major change is the removal of a proposed ban on crypto-asset lending, which was requested by the KNF.
Another key modification extends the transition period for Polish VASPs, including those submitting a CASP license application to the KNF.
This new information helps crypto-asset businesses understand upcoming legal requirements and deadlines. Unfortunately, the official website tracking legislative progress, available at https://legislacja.gov.pl/projekt/12382311, does not provide these latest updates. It still features the old version of the draft, which I have already covered in my previous article: MiCA in Poland: update January 2025
As the legislative process moves forward, I hope further details will be published through official government announcements and regulatory updates. As always, whenever I obtain any new information regarding MiCA in Poland, I will promptly publish an article on this blog. I encourage you to visit it frequently or follow me on LinkedIn to stay updated.
Transitional Period for VASPs in Poland
The newest draft law gives Polish VASPs more time to adapt to MiCA regulations. I previously described how the transition period was expected to work in this article.
The latest version changes current provisions and introduces a 4 month transition period starting from the law’s effective date. In other words, according to the latest information, entities currently registered as VASPs will be able to continue operations for 4 months from the law’s enactment, without any other actions. This is a reasonable solution, given that the Polish law was not passed on time and is facing further delays.
Furthermore, according to the new information,
the total transition period for Polish VASPs meeting formal requirements may extend up to 9 months.
Unfortunately, the details provided by Gazeta Prawna are limited and do not clarify how long the transition period will be for entities that apply for a CASP license in Poland.
What is certain, however, is that the previously set date of 30/06/2025 is no longer valid. Instead, the transition period will last for four months from the new law’s effective date, regardless of whether a VASP applies for a CASP license in Poland or not.
For entities that decide to apply for a CASP license, the most important question is how long VASPs have to submit CASP applications. Unfortunately, based on the information available, this date remains unclear. However, what is certain is that the previous deadline of 1/05/2025 is no longer valid. This brings some relief.
The details about the new transition period will be known after the publication of the new draft.
