POLAND Law and Practice Contributed by: Michał Wołoszański, Łukasz Kudela and Marta Solarska-Kaleńczuk, Wołoszański & Partners
Wołoszański & Partners Spektrum Tower, 19th floor 18 Twarda Street, 00-105 Warsaw (Warszawa) Poland
Tel: +48 22 295 0890 Email: wlaw@wlaw.pl Web: wlaw.pl
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain Market Practices and Recent Developments Blockchain has had a meaningful presence in Poland for over a decade, principally through cryptocurrency trading and exchange services. Business activity in virtual currencies has been a regulated activity since October 2021, when amendments implementing the 5th Anti-Money Laundering Directive (AMLD5) intro- duced the obligation to be entered in the Register of Activity in the Field of Virtual Currencies kept by the Director of the Tax Administration Chamber in Kato- wice. Until the EU Markets in Crypto-Assets Regula- tion (MiCA) became fully applicable on 30 Decem- ber 2024, no dedicated financial-services framework applied to crypto-assets – there were no prudential rules, no conduct-of-business standards and no spe- cific consumer-protection regime. The past 12 months have been defined by a strik- ing regulatory mismatch. MiCA applies directly in Poland, but the national implementing act designat- ing the competent authority has not yet entered into force. Three versions of the bill have been vetoed by the President; the last one was passed by the lower chamber of the Polish Parliament ( Sejm ) on 15 May 2026. On 21 May 2026, the Senate presented its position and did not introduce any amendments. As a result, on 22 May 2026, the bill was submitted to the President for signature. Following a review of the bill adopted by the Sejm and the Senate, on 11 June 2026 the President once again exercised his veto and refused to sign the legislation into law. Therefore, the
final shape of the Polish implementing legislation, and the timing of its entry into force, remain uncer- tain. The MiCA transitional window expires on 1 July 2026. There is market evidence of Polish operators pursuing MiCA authorisation through subsidiaries in other member states. Current Use Cases Commercial activity is concentrated in centralised crypto-asset trading, brokerage and exchange ser- vices, custodial wallets, and stablecoin-based pay- ment products. Tokenisation of investment products and selected real-world assets is gaining traction, often through special-purpose vehicles, and the Central Securities Depository of Poland ( Krajowy Depozyt Papierów Wartościowych or KDPW) has been engaging market participants on distributed ledger technology (DLT)-based post-trade solutions. Distributed-ledger technology is also being deployed in supply-chain, energy-trading and public-procure- ment contexts. Non-fungible tokens have been used by cultural institutions, but commercial NFT activity The dominant issue is timing – whether the imple- menting act enters into force in time to allow Polish operators to apply for MiCA authorisations domesti- cally. Three other strands also call for attention: the operational implementation of the “travel rule” under Regulation (EU) 2023/1113, the digital operational resilience requirements under DORA (applicable from 17 January 2025), and the new tax-transparency framework under the eighth Directive on Adminis- trative Cooperation (DAC8), with data collection by has materially slowed. Issues on the Horizon
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