New Draft Legislation Implementing MiCAR Published

Last week, the President of the Republic of Poland, Karol Nawrocki, vetoed the Crypto-Asset Market Act, citing a number of substantive drawbacks. Almost immediately thereafter, the government announced its intention to resubmit a revised bill to Parliament.

On 10 December 2025, the Sejm’s website published a new government draft of the Crypto-Asset Market Act.

Key features of the government proposal

The newly released draft largely reproduces the previous version of the act. In essence, the government did not address the concerns raised by the President and refrained from introducing additional amendments. The principal regulatory architecture therefore remains unchanged and is consistent with the assumptions we described several months ago.

Parliamentary alternative: the Poland 2050 proposal

On 9 December 2025, MPs from the Polska 2050 Parliamentary Club (a component of the governing coalition) submitted an alternative draft act. This proposal is intended to operate as a compromise between the government’s concept and the expectations articulated by the President.

In contrast to the government’s proposal, the Poland 2050 draft introduces several material modifications. First, the draft eliminates the regulatory framework governing online currency-exchange platforms. It also reduces supervisory fees for issuers of asset-referenced tokens and e-money tokens from 0.5% to 0.1% of financial liabilities arising from issued tokens, reflecting the President’s demands.

It is worth emphasising that the draft does not amend the fee structure applicable to crypto-asset service providers (CASPs), who- according to the Polish regulator- are expected to constitute approximately 70% of the domestic market.

The parliamentary proposal also maintains, without modification, the highly debated mechanism for blocking internet domains. Under this regime, the Polish Financial Supervision Authority, as the future supervisory authority, would be empowered to block access to websites offering crypto-asset services in breach of MiCAR, without prior notice.

Timeline for CASP authorisation applications

The swift submission of both drafts demonstrates the government’s determination to adopt legislation enabling the filing of CASP authorisation applications.

Nevertheless, taking into account the legislative process, it is reasonable to assume that parliamentary voting will occur in the second quarter of 2026, most likely before the expiration of the MiCAR transition period on 1 July 2026. Given the number of open variables, it remains difficult to forecast the precise date on which the new Polish implementing legislation will enter into force and, consequently, when the licensing window will formally open.

Significant changes await the Polish crypto asset market

Learn about the key differences and see how they may affect your business.
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