New draft of Polish Act on Cryptoassets Market

Poland is taking decisive steps to implement a comprehensive regulatory framework for the cryptoasset market. After several months of government consultations, on May 14th, 2025 a new version of draft of Act on Cryptoassets Market has been published. Work on the bill is gaining pace – on May 22, 2025, the draft will be discussed at a meeting of the Standing Committee of the Council of Ministers.

Therefore, there is a chance that the bill will be submitted to the Polish Parliament soon. This information is important for all entities that will apply for a license to provide cryptoasset services (“CASPs”) under MiCA.

Key Changes in the Draft Act (comparing to previous):

• [transitional period]: the Companies actively registered in VASP register (register of virtual currency activities) or entities that were providing crypto-related services on 29.12.2024 will be entitled to continue providing its services for additional:
  • 4 months from the date of entry into force of the Act, or
  • 9 months from the date of entry into force of the draft Act under the condition they will submit a complete application for a CASP license and receive notification of the completeness of the application from the Polish Financial Supervision Authority (KNF) within 3 months of the date of entry into force of the Act,[VASP register]: VASP register will be liquidated after 9 months from the date of entry into force of the Act,
• [providing loans in cryptocurrency]: the initial ban on providing cryptocurrency loans has been waived,
• [lower supervisory fee for CASPs]: the amount of the supervisory fee due for a given year from a crypto asset service provider will be determined on the basis of the average total revenue for the last three financial years preceding the year for which the payment is due, in an amount not exceeding 0.4% of that average, but not less than the equivalent in PLN of EUR 500. The previous version of the draft Act assumed 0.5% supervisory fee,
• [online currency exchange platforms]: draft Act introduces a requirement to hold the status of a payment service provider in order to provide cashless currency exchange services. The period to adjust to new regulations has been extended from 3 to 6 months from the date of entry into force of the draft Act.

Along with the draft Act on Cryptoassets Market, the government also published supplementary draft regulations. The following will be particularly important for preparing a CASP license application:

• draft regulation on the procedure and conditions for the crypto-asset service provider, as well as detailed technical and organizational conditions for the crypto-asset service provider (art. 14),
• draft regulation on specific requirements for individuals providing advice or information on crypto services on behalf of a crypto service provider, and the policy on training and confirmation of their knowledge and competence (art. 4),
• draft regulation on the procedure and conditions of crypto-asset service provider for securing receivables on crypto-assets (art. 12).

When the Act will come into force in Poland?

There is no specific date yet for the Act to come into force. According to government websites, the planned date for the adoption of the draft by the Council of Ministers is the second quarter of 2025.

Considering the current campaign period and presidential elections, as well as the upcoming summer recess in the Parliament, it seems unlikely that the Act will enter into force before Q3 2025. Regardless of when the Act comes into force, we encourage you to start working on adapting your business to MiCA requirements as soon as possible.