MiCA Poland: KNF confirms upcoming legal block for Polish crypto companies in July 2026
In our previous analysis, we covered the evolution of the situation in Poland regarding the Crypto Asset Market Act. Now, the Polish Financial Supervision Authority (KNF) has issued an official position paper clarifying the rules of engagement during this legal vacuum. The message is clear: existing companies have a safety net, but it comes with a hard, non-negotiable deadline.
While the draft law names the KNF (Poland’s Financial Supervisory Authority) for this role, the law has not yet been passed.
To address the confusion, the KNF has published a critical position paper (1) outlining exactly what Polish Virtual Asset Service Providers (VASPs) can and cannot do until the government gets its act together.
Here is LegalBison’s breakdown of the KNF’s official stance and the critical scenario facing our clients.
The current VASP grandfathering period in Poland
The KNF has confirmed that the transitional period is active and valid, despite the lack of new legislation.
If your company was entered into the register of virtual currency activities (managed by the Chamber of Tax Administration in Katowice) before December 30, 2024, you are currently safe. You may continue to operate under the existing Polish national rules (the AML/CFT framework) rather than the full MiCA regime.
This safety net remains in place until July 1, 2026, or until you obtain (or are refused) a CASP license under MiCA, whichever comes first.
The July 2026 MiCA deadline in Poland
This is the most urgent takeaway for all crypto businesses currently operating in Poland. The KNF has explicitly defined the worst-case scenario.
If the Polish government fails to designate a Competent Authority and enact the necessary laws by the end of the transitional period, the consequences will be severe. According to the KNF’s position paper:
In the absence of the designation of a competent authority in Poland… after July 1, 2026, domestic entities will lose the possibility of providing crypto-asset services […] until a relevant authorization is obtained.
Crucially, the KNF highlights that this deadline stems directly from EU Regulation. It cannot be extended by national law or a decision of the KNF.
If the legislative delay drags on until mid-2026, registered Polish VASPs will legally have to cease operations overnight. There will be no further extensions.
The paradox: foreigners welcome, locals trapped
The current legal vacuum has created a significant asymmetry in the Polish market:
Foreign entities can enter: Crypto companies that obtain a MiCA license in other EU countries can already notify their intent to operate in Poland. The KNF confirmed that even though they haven’t been formally appointed, they will accept notifications from foreign regulators allowing these companies to service Polish clients.
Polish entities are stuck: Conversely, because there is no “Competent Authority” designated in Poland, domestic companies cannot currently submit an application for a MiCA license. Furthermore, Polish entities operating under the “grandfathering” clause cannot passport their services to other EU countries yet. They are confined to the Polish market until they are fully licensed.
What should Polish VASPs do?
While the KNF waits for the parliament to pass the Crypto Asset Market Act, the clock is ticking toward the 2026 deadline.
At LegalBison, we advise our clients to take a proactive stance:
Do not wait for the law: The requirements for MiCA (governance, capital, IT security) are known. Prepare your documentation and infrastructure now so you can file for authorization the moment the KNF is empowered to receive it. LegalBison can assist you;
Monitor the timeline: If the legislation is not passed well before 2026, the risk of a “service gap” increases. The licensing process itself can take months. We have solutions in mind, already at play with long-standing clients;
Consider jurisdictional diversification: Since foreign MiCA-licensed entities can already passport into Poland, but Polish entities are currently in limbo, larger enterprises might consider securing a MiCA license in a jurisdiction that is already fully operational to ensure business continuity.
The legal landscape in Poland is shifting. Contact LegalBison today to ensure your transition to MiCA is secure before the grandfathering period expires.
In November this year, LegalBison’s lawyer, Krystian Lapka, reported on the current progression of the MiCA application in Poland. The bill was approved by the local government on November 7 and was waiting for further approval from the president, Karol Nawrocki. However, on Monday, December 1, the president officially vetoed the bill. How will this decision influence the existing Polish VASPs and the entrepreneurs seeking to register in the country?
An update on the situation in Poland, regarding the enforcement of the MiCA regulation and the settling of the Crypto-Assets Service Providers registration process. LegalBison lawyer Krystian Lapka provides us with a regulatory insight.
