Poland’s Crypto Regulation Delayed: What the Presidential Veto Means for CASPs

On 1 December 2025, the President of Poland, Karol Nawrocki, vetoed the Act of 7 November 2025 on the Crypto-Assets Market. The act was intended to implement the MiCA Regulation (Markets in Crypto-Assets) into the Polish legal system and establish a national supervisory framework for crypto-asset service providers (CASPs).

As a result of the veto, the new regulatory regime will not enter into force in 2025, and the Polish CASP licensing process is suspended until a new legislative proposal is adopted.

What were the three main reasons that prompted the president to exercise his veto?

1. provisions allowing administrative blocking of domain names belonging to crypto-asset businesses, arguing that the criteria were vague, insufficiently transparent and could be used abusively — potentially enabling arbitrary shutdowns of websites and cutting users off from access to their funds,
2. excessive length and complexity of the act, describing it as over-regulation. A document exceeding one hundred pages, he argued, would not streamline the market but rather push domestic companies towards foreign jurisdictions where MiCA has been implemented through far simpler national laws,
3. the structure and level of supervisory fees, warning that they were set so high that smaller entities and start-ups would effectively be excluded from the market, while large financial institutions and banks would be placed at a competitive advantage.

What’s next for the crypto market?

Although MiCA, as an EU regulation, applies directly in all Member States, the functioning of the licensing framework for CASPs in each jurisdiction requires national implementing legislation, including the designation of the competent authority, the procedural rules, the fee structure and document requirements. The President’s veto means that no such framework will be established in Poland at this stage. Consequently, it is currently not possible to submit a CASP licence application to a Polish authority.

The situation is different, however, for entities already operating under Polish law and registered in the national register of virtual-currency activity. Under MiCA’s transitional provisions, crypto-asset service providers that were lawfully operating before the regulation becomes fully applicable may continue their activities until 1 July 2026.

In practice, this means that entities holding a valid entry in the Polish Register of Virtual Currency Activity (RDWW) may keep operating under that entry and under the AML Act, despite the vetoed legislation. The date of 1 July 2026 therefore becomes a critical deadline, especially given that the entire legislative process must now begin again.

MiCA readiness: What should virtual currency service providers do?

In this regulatory environment, it is particularly important for VASPs to ensure full and continuous compliance with existing obligations, especially those under AML regulations.

This includes:

• maintaining an accurate and up-to-date RDWW registration and staying in active, substantive contact with the National Revenue Administration,
• responding promptly and thoroughly to any notices of inspection, requests for explanation or demands for information,
• submitting all required reports to the GIIF on time, updating their risk assessment and internal procedures, and ensuring effective ongoing monitoring of transactions and business relationships, supported by appropriate financial-security measures.

At the same time, businesses should begin preparing strategically for the future CASP licensing process. This may involve assessing possible licensing scenarios, reviewing product documentation, terms and conditions, internal policies and customer communications for MiCA compliance, and strengthening internal functions such as compliance, AML, risk management and IT, so that once a new act is passed, a complete application can be prepared without delay.

CASP procedure in 2026 at the earliest.

The further fate of the legislation depends on parliamentary developments. The Sejm may attempt to override the veto with a three-fifths majority, an outcome that currently appears unlikely, or it may begin work on a new draft act implementing MiCA, addressing concerns related to domain-blocking powers, regulatory complexity and supervisory fees.

Indications are that the next proposal will have to be more business-friendly and more proportionate to the needs of the market. Regardless of the final legislative form, it is already clear that the realistic timeline for launching the CASP licensing procedure in Poland shifts to 2026.

Secure the future of your business in the crypto market today

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