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🇵🇱 Poland

No functioning MiCA CASP regime, enabling law vetoed three times, KNF unable to authorise anyone as of July 2026

Crypto (CASP / VASP) E-money (EMI)
Last verified 2026-08-15 Next review 2026-08-29

Data verified: oldest cell 46 days ago (verified 2026-07-02). Individual cells show their own verification date below.

Capital requirement Capital requirement is included with access. Included with access Timeline to authorisation Timeline to authorisation is included with access. Included with access Application cost Application cost is included with access. Included with access Passporting Passporting is included with access. Included with access

Licence type

MiCA CASP authorisation is legally required (MiCA is directly applicable EU law) but Poland has NO functioning domestic legal basis to grant it: the Crypto-Assets Market Act, which would designate KNF as competent authority and set out the licensing procedure, has been vetoed by the President three times (1 December 2025, 12 February 2026, and again in June 2026 per later reporting). Three competing draft bills (government, Poland 2050, Konfederacja) remain stuck in the legislative process.

Verified 6 weeks agoSource: Wozniak Legal: https://wozniaklegal.com/en/news-and-insight/500/polands-mica-deadline-looms-no-casp-law-no-licenses-after-1-july-2026.html

Regulator

KNF (Komisja Nadzoru Finansowego / Polish Financial Supervision Authority) is the intended competent authority under the stalled Crypto-Assets Market Act, but KNF currently has NO statutory power to accept or process CASP applications because no law has designated it as the Article 3(1)(35)(a) MiCA competent authority. This is a genuine regulatory vacuum, not merely a slow regulator.

Verified 6 weeks agoSource: Adam Smith law firm: https://adamsmith.lt/en/implementation-of-mica-in-poland-why-it-has-still-not-been-achieved/

Recent changes Disputed

Why is this figure disputed?

Sources disagree on this figure. The verified detail below sets out the conflicting counts or interpretations and which we treat as most authoritative; treat it as contested until it settles.

The enabling law (Crypto-Assets Market Act) remains blocked: the Sejm adopted a third draft on 15 May 2026, the Senate passed it unamended on 22 May 2026, and the President vetoed it for a third time on 11 Jun 2026 (earlier vetoes 1 Dec 2025 and 12 Feb 2026; an override attempt failed 17 Apr 2026). With the EU transitional period over on 1 Jul 2026, the KNF confirmed on the record that no Polish authority is designated for MiCA except for e-money token issuers; roughly 2,000 Polish VASPs are affected, with EEA passporting the working route into Poland.

Verified 5 weeks agoSource: CoinDesk, on-record KNF statement (1 Jul 2026): https://www.coindesk.com/policy/2026/07/01/why-poland-is-the-only-eu-country-where-crypto-firms-can-t-get-a-mica-license ; Reuters (11 Jun 2026): https://www.reuters.com/business/finance/polish-president-vetoes-crypto-regulation-third-time-2026-06-11/

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Not legal advice. Entries marked placeholder or awaiting verification shouldn't be relied on. Verify with Poland's regulator and qualified local counsel before acting.