On 7 November 2025, after incorporating amendments proposed by the Senate, the Sejm adopted the Polish Act on the Crypto-Assets Market which brings MiCA into effect in Poland. On 12 November 2025, the Act was transmitted to the President for signature, entering the final stage of the legislative process before official publication. Although the Act has been formally submitted, it is still uncertain when the President will sign the law and allow it to enter into force.
Once the Act is signed, the MiCA framework in Poland will formally replace the current VASP registration system and introduce a full CASP licensing regime. However, the fact that the law has been sent to the President does not mean that a CASP license in Poland will automatically become available in December 2025. At this stage it is still unclear whether the President will sign the Act. This raises a practical question: will CASP licensing in Poland under MiCA begin in December 2025, or is the market still weeks or months away from adaptation?
What happened in November 2025
As I wrote in the previous “MiCA in Poland update”, on 26 September 2025 the Sejm adopted the Polish Act on the Crypto-Assets Market. The bill was then transmitted to the Senate, which could either approve it or introduce amendments. The Senate proposed several changes of a technical and editorial nature — improvements to wording and legal formatting, without modifying the core regulatory approach to MiCA in Poland or the issues flagged by the industry.
After reviewing the amendments, on 7 November 2025 the Sejm adopted the Act and approved the adoption of MiCA in Poland. On 12 November 2025 the law was formally transmitted to the President, which, procedurally, is the final stage before official publication in the Journal of Laws. Until the President signs the Act, the new MiCA-based framework and the ability to apply for a CASP license in Poland cannot yet enter into force.
Procedural timeline – what happens next?
The President has 21 days to take action. The Act was transmitted to President Karol Nawrocki on 12 November. However, the Act of “presentation” is a technical step and does not need to occur on the same day. This means that the earliest possible decision date is 3 December 2025. But if formal presentation occurred a few days after 12 November, the deadline may shift to approximately 8–11 December 2025.
At this stage, the President has three constitutionally available options:
- sign the Act,
- refer it to the Constitutional Tribunal for review,
- veto the Act.
Each scenario leads to a different timeline for the beginning of CASP licensing in Poland under MiCA. In the fastest variant –presidential signature – the regulatory framework could start operating as early as late December.
If the President delays the signature or uses other constitutional tools, the start of the licensing system may shift by weeks or even months. For the market, the key point is that the Act being sent to the President does not automatically mean that CASP licensing in Poland begins next month. Only once the President signs the law and it is published in the Journal of Laws can the new framework formally enter into force and allow the KNF to begin processing licence applications.
Why the President will most likely not sign the Act
Many representatives of the Polish crypto industry have already appealed to the President to veto the Polish Crypto-Assets Market Act. The same position has been taken by the opposition party PiS, from which the President comes. Their goal is to submit an alternative draft prepared by market experts – a proposal that, according to its authors, would implement MiCA in Poland without adding additional national regulatory layers.
The core issue is the plan to grant supervisory powers over the Polish crypto market to the KNF. The President requested that this provision be removed. When this did not happen, the option of a veto became the most likely outcome. In his view, supervision of the new crypto regulatory framework should be entrusted to a different institution created specifically for this sector, rather than the existing financial regulator.
At the same time, I see political circumstances that may push the President to sign the Act despite the controversy. The government has repeatedly pointed out that the President has already vetoed 13 laws in a relatively short period of his term. Signing the Polish Crypto-Assets Market Act could be seen as a move to avoid reinforcing the public perception of excessive use of the veto.
What we know for certain – regardless of the President’s decision
Even though the exact date of entry into force of the Polish Crypto-Assets Market Act is still uncertain, one element is already guaranteed: the transitional period. Under the current wording of the Act, every entity entered in the Polish VASP Register on the day the new law takes effect will be allowed to continue operating until 1 July 2026, even without submitting application to obtain CASP license in Poland. In practice, it means that VASPs in Poland will not be forced to suspend business immediately once MiCA in Poland becomes binding and that they will have a window for full regulatory adaptation.
VASPs in Poland cannot afford to wait. Whether the Act is signed in December or later, the work on CASP license documentation needs to start now. If the Act is signed within the 21-day deadline, the KNF could start accepting CASP applications as early as late December. For VASP in Poland that already have documentation ready, this creates a chance to be among the first applicants in the market.
If the President does not sign immediately and the process takes longer, the delay does not change the practical reality. Preparing a complete application for a CASP license in Poland requires time. Companies must draft internal procedures, governance documentation, AML frameworks, business models, ICT descriptions, outsourcing rules and demonstrate compliance with prudential capital safeguards. For most VASPs in Poland, this work takes several weeks to several months.
My opinion on the current situation
Many market participants argue that Poland has already missed its chance to remain a crypto hub in Europe. An 11-month delay in adopting MiCA in Poland is often cited as proof that major players have already shifted business and licensing activities to other EU jurisdictions. In my view, it is too early to draw that conclusion.
A presidential veto could in fact open the door to conditions that are more favourable for the industry. One scenario being discussed is a “MiCA +0” model. By this I mean a regulatory approach that adopts the European MiCA framework in Poland without adding extra national requirements beyond what the EU regulation already prescribes. If such an approach is ultimately adopted, Poland could become one of the most competitive places in the EU for obtaining a CASP license.
Another possible outcome could be the creation of a new supervisory authority dedicated exclusively to the crypto-assets market. A fresh institution – rather than the existing KNF – could mean a different regulatory mindset: more sector-specific expertise, more openness to market dialogue and a better understanding of how the crypto industry actually operates. For companies thinking long term, this could become a significant competitive advantage if Poland decides to position itself not only as a jurisdiction complying with MiCA, but as one actively supporting development of the digital assets sector.
MiCA in Poland updates
MiCA in Poland – new crypto regulations
MiCA in Poland – update August 2024
MiCA in Poland – update December 2024
MiCA in Poland – update January 2025
MiCA in Poland – update March 2025
MiCA in Poland – update May 2025
MiCA in Poland – New act published (May 2025)
MiCA in Poland – update September 2025
MiCA in Poland – update October 2025
MiCA in Poland – update November 2025
It’s good to see the Polish legislative process for MiCA reaching the final stage with transmission to the President. I was looking into this earlier, and the timeline seems to align with my predictions about adoption of MiCA in Poland. Hope CASP licensing will start soon