What’s next for the Crypto-Asset Market Act? First meeting of the Subcommittee on Financial Institutions after the summer break

As a result of the first reading of the draft Crypto-Asset Market Act in the Polish Parliament, which took place on 23 July 2025, the document was referred for further work in the Public Finance Committee, as we wrote here. After the summer break, legislative work was resumed, and on 9 September the first meeting took place, during which each article of the Act was discussed.

Will the draft Act undergo significant changes?

The current shape of the legal act will most likely be significantly modified. At the subcommittee meeting, many amendments were voted on, concerning not only editorial aspects but also issues crucial from the perspective of market practice.

The changes will include:

• the area of fees for market supervision.
• the maintenance of a register of domains offering services in breach of MiCA, the rules for online currency exchange.
• the application of sanctions for non-compliance with the Act.

Transitional period- a new approach

During the debate, it was decided to abandon the solutions currently included in the draft Act, which provided for two transitional periods of 4 or 9 months calculated from the entry into force of the Crypto-Asset Market Act (based on Articles 162–163 of the draft Act, details presented in May).

The members of the parliamentary subcommittee participating in the meeting agreed to change the transitional period by indicating a specific deadline- 1 July 2026 (fully coinciding with the end of the transitional period indicated in Article 143(3) MiCA).

Obligation of confirmation of application completeness by the regulator and the possibility of using the transitional period

At the subcommittee meeting in the Polish Parliament, another problem was raised, important for entities entered in the VASP register (register of activities related to virtual currencies), which intend to make use of the transitional period.

The discussion was triggered by the condition for the effectiveness of benefiting from the 9-month transitional period, consisting of obtaining confirmation of the completeness of the submitted application by the KNF. In short, a VASP will be able to benefit from this period if, within 3 months, the entity submits a complete application for obtaining a CASP authorisation, and the completeness is confirmed by the regulator (ultimately the Polish Financial Supervision Authority).

Critics of the proposed regulation stressed that this requirement is not justified in the content of MiCA, and in addition the term “completeness of the application” has not been defined anywhere, which may lead to a discretionary approach by the regulator to the application submitted for authorisation. The possibility of submitting amendments to the text of the Act was not excluded.

Online currency exchange

Another topic discussed at the committee meeting concerned the proposed solutions significantly changing the conduct of business in the field of online currency exchange, which we wrote about here.

At the parliamentary subcommittee, it was decided to maintain the adopted direction of legislative changes, amounting to the possibility of exchanging currencies only by a payment service provider providing the service of opening and maintaining a payment account (Article 3(1)(1) of the Payment Services Act). At the same time, further clarification of the provisions was announced- currency exchange will be possible exclusively through a payment account previously created for the client for the execution of the currency exchange.

What’s next?

The report of the Public Finance Committee will most likely be presented in parliament later this week. At that time, the entirety of the amendments and the further legislative timetable for the Act will be known, which will make it possible to estimate the date of entry into force of this legislation.

We will continue to monitor the course of the legislative work and provide information on further stages of the process and their practical consequences for participants of the crypto-asset market.

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