On 26 September 2025, the lower house of the Polish Parliament finally adopted the long-awaited Act on Crypto-Assets Market.
Does this mean the legislative process is over and the full adoption of MiCA in Poland is complete?
Definitely not — in fact, quite the opposite may be true.
My article provides the latest update on MiCA in Poland, as of October 2025.
Legislative background
Although MiCA as an EU regulation applies directly in all Member States, each country must still supplement it with national legislation — especially regarding the designation of supervisory authorities, CASP licensing procedures, and sanctions.
Poland is implementing these obligations through the Act on the Crypto-Assets Market, which has become one of the most comprehensive MiCA implementations across the European Union.
The Polish bill contains 104 pages and sets out, among other:
- the role and powers of the Polish Financial Supervision Authority (KNF),
- the part of procedural provisions for obtaining a CASP license in Poland,
- a catalogue of administrative and criminal sanctions.
On 26 September 2025, the Polish Sejm adopted the Act on Crypto-Assets Market.
The latest version of the bill is available on the Sejm’s website:
https://www.sejm.gov.pl/sejm10.nsf/PrzebiegProc.xsp?nr=1424
Supervisory fee of 0.4% – the key controversy
Although the supervisory fee is not a tax in the formal sense, its fiscal nature is evident.
Set at 0.4% of annual revenue, it has become one of the most controversial aspects of the entire act.
This level of fee represents a heavy burden for many crypto-asset service providers — including small exchanges, brokers, and platforms.
For companies operating with low margins, a 0.4% charge on revenue could effectively erase profitability.
The measure also raises competitive concerns. Entities based in Poland will struggle to compete with firms from other EU jurisdictions where such fees are lower.
Calls to introduce a cap or link the fee to profit margins were reasonable but ignored during the legislative process.
Controversial “blacklist” of banned domains
Another highly debated provision is the creation of a register of banned domains, which would allow the KNF to block access to websites operated by entities without the required CASP authorization.
While the stated goal is investor protection, the measure could in practice lead to:
- arbitrary administrative decisions,
- blocking of legitimate businesses,
- and restrictions on investors’ ability to contact service providers or pursue claims.
Key change – a new transitional period
Under the newly adopted Act on the Crypto-Assets Market:
Art. 162(1):
During the period from the date of entry into force of this Act until obtaining the authorization referred to in Article 59(1)(a) of Regulation (EU) 2023/1114, or refusal thereof, an entity entered in the register of virtual currency activities on the date of entry into force of this Act may continue its business consisting of providing the services referred to in Article 2(1)(12) of the amended Act, under the existing rules, but no longer than until 1 July 2026, unless removed earlier from the register.
Earlier drafts of the law required submitting a CASP license application within a short deadline to continue operations. That condition has now been completely removed.
Earlier version (Art. 163 draft) | Adopted version (Art. 162 of the Act, 26 Sept 2025) |
4 months – basic transition period | VASP activity permitted until 1 July 2026. |
9 months – possible extension only if a complete CASP license application was submitted within 3 months and acknowledged by KNF. | No obligation to file a CASP license application to continue operations. |
The previous draft offered a very limited transitional period — a guaranteed 4 months, extendable to 9 only with a quick CASP application.
In practice, many Polish VASPs would not have had enough time to prepare full licensing documentation and would have been forced to suspend operations.
The final version is far more pragmatic. It allows VASPs to operate until 1 July 2026 without filing a CASP application. This provides the market with a genuine transitional period — a realistic timeframe to adapt business models, compliance frameworks, and documentation to the requirements of MiCA in Poland.
What happens next?
On 29 September 2025, the Act was submitted to the President and the Speaker of the Senate.However, it is almost certain that the law in its current form will not remain unchanged.The team of President Karol Nawrocki has already signaled a likely presidential veto.
Within the next one to two months, we should learn what the future holds for the Polish MiCA adoption and for entities seeking a CASP license in Poland.
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
