New MiCA Standards for Asset-Referenced Tokens: What Polish Businesses Need to Know

The European Commission has introduced new Regulatory Technical Standards (RTS) under the EU’s Markets in Crypto-Assets Regulation (MiCA), aimed specifically at asset-referenced tokens (ARTs).

ARTs are a class of stablecoins designed to maintain a stable value by referencing one or more assets (such as fiat currencies, commodities, or crypto-assets).

On June 5, 2025, the Commission adopted a Delegated Regulation that spells out exactly what information companies must provide when applying for authorisation to offer ARTs to the public or have them admitted to trading. In practical terms, this means any business in Poland intending to issue a stablecoin of this kind will face a clear but rigorous checklist of requirements.

This article explains what the new RTS requires and why it matters, how it will affect companies operating in Poland, and how our law firm supports clients through these changes.

What Do the New RTS Require?

Under MiCA, issuers of asset-referenced tokens must obtain prior authorisation from a competent authority (in Poland, this will be the Polish Financial Supervision Authority, KNF).

The new RTS provide a detailed roadmap of what an application for such authorisation must contain. In essence, the application demands a full portrait of the would-be issuer and its stablecoin project, covering several key areas:

• Identity and Structure of the Issuer
• Programme of Operations (Business Plan)
• Governance and Organisational Structure
• Liquidity Management, Reserves and Redemption Rights
• Fit and Proper Management

Beyond management, regulators also look at who owns or controls the issuer. If there are shareholders or members with qualifying holdings (typically meaning those who own above a certain threshold of the company, such as 10%), the RTS require evidence of their sufficiently good repute.

By following this structured list of requirements, the RTS ensures that any application for an ART authorisation is thorough and standardized across the EU. From a company’s perspective, preparing such an application is a substantial effort – it means pulling together corporate documents, drafting detailed plans and policies, and sometimes improving internal structures before even launching the token.

However, this up-front rigor serves an important purpose: it forces issuers to have a solid foundation and credible plan, which in turn gives regulators and future token holders confidence in the project.

What It Means in Practice for Companies in Poland?

For companies operating in Poland, these new requirements have very concrete implications.

Poland, as an EU member, is directly subject to MiCA and all its technical standards – no separate Polish legislation is needed for these rules to apply. This implies that any Polish issuer of asset-referenced tokens – whether a startup, fintech, or financial institution – must prepare for a licensing process substantially more demanding than the registration procedures previously applicable to virtual asset service providers in Poland.

Until now, the Polish crypto sector was only lightly regulated (for instance, cryptocurrency exchanges and wallet providers needed to register as Virtual Asset Service Providers, a relatively simple process). There was no dedicated regime for stablecoin issuers in Poland. With MiCA’s ART authorisation requirement in effect, this is a game-changer.

A company in Poland can no longer simply develop a stablecoin and start offering it on the market. Instead, it must apply to the KNF for authorisation, presenting all the information outlined above.

The KNF will scrutinise the application thoroughly, likely engaging in an iterative process – asking questions, requesting additional details, and imposing conditions – similar to how it would license a bank or an e-money institution.

Regulatory Timelines and Compliance Risks

In essence, for a Polish business, launching an ART now resembles launching a regulated financial product. The timeline for going to market will include obtaining the KNF’s authorization, which could take months.

Companies should factor this into their plans: a rush to issue tokens without authorization could lead to legal penalties and enforcement actions under MiCA.

It’s worth noting that MiCA allows authorities to impose fines or even stop offerings that violate the rules, so non-compliance is not an option if the business aims to operate legitimately across the EU.

On the positive side, once authorised, a Polish issuer of an ART gains a passport to operate across the entire EU. Authorisation in one member state (Poland) means the company can offer its stablecoin in all other EU countries without separate licenses. This EU-wide market access is a major advantage of the MiCA framework.

It means that the effort put into compliance and obtaining the license can pay off with a much larger potential user base. Polish fintech companies that successfully navigate this process could position themselves as trustworthy players in the European crypto market, potentially gaining a competitive edge over unregulated projects.

Considering an ART issuance under MiCA?

Our Fintech team supports clients throughout the entire authorisation process – from strategic planning to documentation and communication with the KNF. Contact us and ensure your project meets MiCA standards and is ready for EU-wide rollout.