The Act on the Crypto-Assets Market Vetoed Again. Will Poland Be Ready with CASP Licences Before 1 July 2026?

On 12 February 2026, the President of Poland vetoed the Crypto-Assets Market Act for the second time. The legislation was intended to implement the EU MiCA Regulation (Markets in Crypto-Assets) and establish a national licensing framework for crypto-asset service providers (CASPs).

As a result, the process of building Poland’s domestic supervisory and licensing regime has once again been suspended, leaving market participants facing increasing regulatory and operational uncertainty.

Second Veto of the Crypto-Assets Market Act – Key Objections Raised by the President

As indicated in the official statement, the new bill did not differ significantly from the draft vetoed on December 1, 2025. Apart from a minor adjustment lowering the maximum supervisory fee rate, the text remained largely identical to the original version.

The President maintained his previous legal and systemic objections, pointing primarily to:

• non-transparent provisions regarding the blocking of domain names, which, due to overly broad criteria, could lead to arbitrary cut-offs of users from their funds,
• excessive complexity and volume of the regulations, which in practice could discourage Polish entities from remaining in the country and push them towards other EU jurisdictions where MiCA implementation is more business-friendly.

Regulatory Gap After 1 July 2026 – What Does the Absence of the Crypto-Assets Market Act Mean for CASPs?

Although the MiCA Regulation applies directly in all Member States, the actual launch of the CASP licensing procedure in Poland requires a national act to empower the Polish Financial Supervision Authority (KNF) and set out the procedural rules. The absence of this act means it is still not possible to successfully submit a CASP license application to the Polish supervisory authority.

For entities already operating in the market and registered in the Polish Register of Virtual Currency Activity (RDWW), the situation is becoming increasingly urgent. Under MiCA’s transitional provisions, they may continue their operations under the current rules only until July 1, 2026. 

Failure to enact new legislation before this date could result in a legal vacuum, creating a risk that there will be no legal basis for providing crypto-asset services in Poland after the transitional period expires.

Preparing for a CASP Licence – Key Actions for VASPs and Crypto-Asset Businesses

In light of the prolonged legislative process, it is crucial for crypto businesses to take steps to safeguard their operational continuity:

• Strict Adherence to AML Obligations: It is essential to maintain an up-to-date RDWW registration, regularly report to the GIIF, update risk assessments, and respond promptly to supervisory authorities (KAS). During this transitional period, authorities may pay special attention to compliance in this area.
• Continuing MiCA Readiness Preparations: Regardless of when the Polish Crypto-Assets Market will be enacted, MiCA’s core requirements remain the same. Organizations should proceed with technological audits, and the review of internal policies, terms and conditions, and product documentation.

Do You Need Support in Preparing for MiCA and a CASP Licence?

The Polish crypto-assets market is currently at a stage requiring carefully planned regulatory and strategic decisions. If you operate as a VASP or are preparing to obtain a CASP licence in Poland, it is advisable to proactively secure your operational model and documentation in line with MiCA requirements.

We invite you to contact our team to assess how the current legislative developments may affect your business and to discuss available legal and regulatory strategies ahead of 1 July 2026.