New Draft Law on Crypto-Assets in Poland – Implications for CASP and MICA

On 16 April, a group of MPs from the Law and Justice (PiS) party submitted a parliamentary draft act on the crypto-assets market.

The draft partially builds upon the previous version of the bill, while also introducing amendments advocated by PiS, including in particular:

1. Maximum supervisory fee cap of EUR 10,000
   Prospective crypto-asset service providers (CASPs) will be required to pay supervisory fees up to a maximum amount of EUR 10,000.

The method of calculating the fee remains unchanged and is based on 0.4% of the average total revenue generated over the last three financial years preceding the year for which the payment is due.

However, the introduction of a cap should be viewed as a step towards enhancing the competitiveness of the Polish market.

1. New grounds for blocking internet domains
   Under the previous version of the draft, the supervisory authority was empowered to block domains where such action was necessary to prevent serious harm to clients or crypto-asset holders.

The revised draft introduces a more specific prerequisite, namely the prevention of a criminal offence.

This formulation imposes an obligation on the Polish Financial Supervision Authority (KNF) to demonstrate a likelihood that a specific prohibited act may be committed by a CASP.

1. Establishment of the Crypto-Assets Council
   The creation of the Council represents an attempt to limit the decision-making monopoly of the KNF and to implement the presidential proposal aimed at strengthening oversight of the supervisory authority.

The Council would be responsible for examining appeals against KNF decisions as well as complaints regarding inactivity or undue delay.

MiCA draft in Poland – status and impact

On 17 April 2026, the Sejm failed to override the veto of the President of the Republic of Poland concerning the previous version of the bill. Consequently, the current parliamentary draft constitutes another attempt to introduce national provisions clarifying the application of MiCA in Poland.

Implications for domestic entities operating in the crypto-assets sector

The current regulatory landscape entails, in particular:

• the need to align operations with MiCA despite the lack of full national implementation, including in particular the preparation of CASP licence applications,
• an increased importance of regulatory risk assessment,
• the necessity of adopting a flexible operating model enabling potential business relocation or rapid adjustment to new requirements, should the act not be adopted before 1 July 2026,
• the growing role of ongoing legal advisory and compliance functions.

Crypto regulations and the importance of compliance

Stay ahead of regulatory developments in the crypto-assets sector by adopting a proactive, forward-looking compliance strategy. Early preparation is key to managing legal and operational risk, ensuring smooth adaptation to new requirements, and maintaining strong market credibility.

Contact us to discuss how we can support your compliance strategy and help you navigate the evolving regulatory landscape.