The adoption of the MiCA Regulation in Poland does not follow any predictable pattern. In this article, I will outline the current status of MiCA adoption in Poland and when it will actually be possible to apply for a CASP license. I will also provide an update on when we can expect the Polish Act on the Crypto-Assets Market to be passed, what the transitional period will look like, and how political turbulence is influencing MiCA adoption in Poland. Things are getting genuinely interesting.
Status of MiCA Adoption in Poland
Since my last update on MiCA adoption in Poland, practically nothing has changed from a legal standpoint. The draft Crypto-Asset Market Act, published by the Ministry of Finance in May 2025, was officially approved by the Council of Ministers. On 26 June 2025, the bill was submitted to the Sejm (the lower house of the Polish Parliament). On 23 July 2025, the first reading of the bill took place.
First reading refers to the initial parliamentary stage at which the bill’s general principles are debated; legislators discuss the framework, may raise key objections, and then decide whether to send the bill to a relevant committee for detailed review.
The debate turned out to be quite heated. Opposition MPs raised several pointed objections, including:
- Concerns that the bill would grant excessive supervisory powers to the Polish Financial Supervision Authority (KNF), a body often viewed with scepticism by the crypto sector;
- Criticism of a proposed 0.4% revenue-based fee on Polish crypto exchanges—not required by MiCA—which was seen as unfair and potentially stifling for smaller domestic players;
- Arguments that the proposed regulation overlooks or dismisses feedback from the crypto industry, rather than integrating practical suggestions.
Following the first reading, the bill was referred to the Standing Committee on Public Finance for further work. This committee stage marks the next critical step in the legislative process, during which detailed scrutiny, amendments, and stakeholder input are expected.
Why the supervisory fee for CASPs is so controversial
The annual supervisory fee has quickly become the central axis of political and industry dispute. On paper, the mechanism looks straightforward: CASPs should contribute to the costs of supervision in proportion to their revenues. In practice, however, the proposed 0.4% (cannot fall below EUR 500) cap raises several issues.
Regulators say the money covers the costs of market oversight. Industry voices disagree. They warn the fee creates an entry barrier and will slow down market growth. Smaller CASPs may struggle the most. This provision has become one of the hottest points in the MiCA adoption debate.
Hope in Poland’s new President
Poland elected a new president in August 2025. His advisors wasted no time in addressing MiCA and the supervision of CASPs. The president himself cannot write laws, but his role in the adoption of MiCA matters. Karol Nawrocki holds the power to veto and to slow down the process. He also influences parliament through his political weight. His nationalist image is mixed with signals of openness to new technology. This balance means he could support changes to the 0.4% CASP supervision fee. For the sector, it is a chance to start dialogue not only with parliament but also with the presidency. Clear, practical proposals may find a better reception here.
Transitional period under new draft
Since my last article, nothing has materially changed regarding the transitional arrangements in the Polish draft law. The provisions I described in MiCA in Poland – New Draft Act Published remain in place under the current draft.
Here are the key points:
- VASPs already listed in the national VASP register, as of the moment the draft law enters into force, will have 4-month grace period during which they may continue operations under existing national rules.
- That period can extend to 9 months, but only if two conditions are met:
- Polish VASP submits a complete CASP license application within 3 months from the law’s effective date; and
- The application is confirmed by KNF to be complete under the MiCA rules.
When will CASP licensing finally start in Poland?
Most legal and political signals point to the adoption of the Polish Crypto Asset Market Act in late 2025 or early 2026. If this schedule holds, the act should enter into force in the first quarter of 2026.
From that moment, the KNF will be able to start the licensing process for CASPs. Companies already registered as VASPs will enjoy a transitional period. They should have until mid-2026 to secure full authorization.
For Polish VASPs, the time to prepare is now. Governance, AML frameworks, and the organizational structure must be in place before adoption. Acting today may be the last opportunity to secure a smooth CASP licensing process.
