In previous updates, I provided a detailed overview of the ongoing legislative efforts to adopt the MiCA, Regulation (EU) 2023/1114 in Poland. We have now entered May 2025, and the situation remains unresolved. The legislation adapting MiCA — the “Polish Act on the Crypto-Assets Market” — to national law is still being finalized. Many companies planning to apply for a CASP license in Poland are now carefully assessing what this means for their next steps.
Status as of May 2025
In my previous article from March 2025, based on press sources, I noted that a change to the transitional period was being considered.
To recap, under the initial draft of the act from early 2024, the transitional period was expected to last until the end of 2025. In a subsequent draft, this period was shortened to 30 June 2025.
Since then, the Polish Ministry of Finance has acknowledged that the deadline may be premature. Notably, there have been indications that a four-month transitional period, starting from the date the law comes into force, will be introduced. This provision would allow existing VASP in Poland to continue operating while adapting to the new regulatory requirements.
Unfortunately, these developments have not yet been reflected in the official draft of the act. On the government website tracking the legislative progress of the Polish law implementing MiCA, the outdated version of the draft is still the one currently published.
As a result, the assumptions I presented in the article MiCA in Poland – Update March 2025 remain valid. No new developments have emerged in this regard.
When will the Polish Act on Crypto Assets Market be adopted?
The lack of progress may result from the ongoing presidential campaign in Poland. The presidential election will conclude in May, and in my opinion, a new draft of the act may finally be published in June. I would also expect the legislative vote to take place in June or July. However, it is also possible that the act will not be adopted until after the summer season.
Taking all of this into account, it seems likely that the transitional period for Polish VASPs will remain until the end of 2025. However, I must emphasize that this is not yet certain — much can still change, including the possibility of extending the transitional period until July 2026.
I will continue to provide timely updates on this blog as the situation evolves.
What should VASPs in Poland do now?
Even though it is not yet possible to formally apply for a CASP license in Poland, now is the time to prepare. The earlier Polish companies start working on their application documents, adjusting internal structures, and meeting capital and governance requirements, the better positioned they will be once the licensing window officially opens. Taking proactive steps now can significantly streamline the process later and help avoid the last-minute rush when the legal framework is finalized.
