Recent developments about MiCA in Poland
Since our latest regulatory update in March 2025, the Polish lawmakers have been working and debating extensively. The Polish Draft Act (for the enforcement of MiCA), presented by them, has been highly criticized inside and outside the country. A new version of the text has then been presented to the Polish Parliament on September 26th of 2025.
The Act was adopted by the Polish Parliament on November 7. However, for it to enter into force, it must be signed by the President, who received it on November 12. The President has 21 days to either sign or veto the Act, which sets the deadline at December 3.
Poland changed its President since the last Act was drafted
As Poland elected a new President in May, this changes the tendency previously observed. Considering given information from the newly elected President, Karol Nawrocki, and his political alignment, it is almost certain that he will not sign the present Act.
Nawrocki showed open skepticism toward the previous draft of the Act during the presidential campaign. He declared that “tyrannical regulations that will restrict your freedom will not come into force”.
The Presidential political environment has, additionally, openly criticized the Act. It was stated in the media and in Parliament, as well as according to unofficial sources, that:
- The Act is more complicated and restrictive than MiCA;
- The Act contains an excessive number of potential sanctions for possible breaches;
- The fees are too high;
- The Komisja Narodu Finansego (KNF), the Polish financial supervision authority supposed to become the crypto regulating authority, is not suitable due to its general skepticism and restrictive approach toward crypto. Meaning that a new, dedicated regulatory body should be created. The new body shall be focused on warning and preventing, instead of fining and banning, as intended by the KNF.
The latest Polish Draft Act brought few, but significant changes to the proposed future law
The updated Act, however, gives some indications on the final form of the MiCA implementation in Poland. We outlined four key changes since the previous version of the Polish Draft Act:
- The grandfather period has been extended to June 2026 for existing, operating entities under a Virtual Assets Services Providers (VASP) license;
- The application cost has been brought to 4,500 EUR, plus an additional identical sum for foreign EU entities willing to obtain an authorization in Poland;
- The annual fee applicable from the second year has been reduced from 0,5% to 0,4% of average revenue derived from the provision of crypto asset services over a 3-year average. This fee has a minimum of 500 EUR, therefore applicable to companies whose average annual turnover would be 125,000 EUR or less;
- The most controversial aspect of the previous draft, the article implementing a ban on lending activities, has been removed.
Note that this does not definitively determine what the final law will look like, as rewriting is to be expected in the next few months.
The way forward for Poland’s crypto regulation
Though not presently official, the refusal of the current President to sign the latest Act is almost certain. In addition to the statements listed above, the legislation process has likely already been changed.
Polish newspaper Rzeczpospolita published on October 30th, 2025, an interview with university professor Krzysztof Piech. Piech leads a team of independent experts working on a new draft for the implementation of MiCA and European crypto regulations in Poland.
This working group intends to be apolitical, though unofficially endorsed by the President and supported by the crypto industry. Its mission is therefore to find a compromise between what the Polish Parliament has until now deemed necessary and the freedom of business that the President and his environment are advocating for.
The idea of creating a new regulating body with an encouraging approach instead of a dissuasive one emerges from this initiative.
LegalBison lawyer’s analysis of MiCA Poland’s current status
First, we shall briefly synthesize:
- As of November 11th, Polish authorities have still not adopted a local regulatory framework related to the application of MiCA;
- It is currently not possible to apply for a MiCA CASP license in Poland, as no competent authority can process the applications;
- The transition period is still set until July 1st of 2026;
- We expect the current draft Act to be refused, and a more business-friendly version to emerge.
The crypto industry is valuable to Poland, and multiple experts (including LegalBison’s) expressed worry when reading the first Polish Draft Acts.
The latest developments can give a sense of optimism to operating VASPs in Poland and to crypto entrepreneurs awaiting to see if Poland will maintain its position as a major crypto business hub in Europe.
