POLAND Trends and Developments Contributed by: Michał Wołoszański, Łukasz Kudela and Marta Solarska-Kaleńczuk, Wołoszański & Partners
A Member State Out of Step More than 16 months after the Markets in Crypto- Assets Regulation (MiCA) became fully applicable across the European Union on 30 December 2024, Poland remains one of the very few member states in which the national implementing legislation needed to put the regulation into operational effect has not yet entered into force. The Polish bill on the market in crypto-assets has been before Parliament since the autumn of 2025 in three successive iterations. It has been passed by the Sejm (the lower chamber of the Polish Parliament) and three times returned unsigned by the President of the Republic, on 1 December 2025,again on 12 February 2026 and on 11 June 2026. The last attempt took place as of mid-May 2026, when the third version of the bill was once again passed by the Sejm . On 21 May 2026, the Senate presented its position and approved the bill without amendments, thereby endorsing it in its entirety. The next step in the legislative process was to be the President’s signa- ture. However, following a review of the bill adopted by the Sejm and the Senate, on 11 June 2026 the Presi- dent once again exercised his veto and refused to sign the legislation into law. The reasons cited largely reiterated those advanced during the previous unsuc- cessful legislative attempts. In particular, the President objected to the significant costs associated with the proposed supervisory framework, the supervisory authority’s power to block internet domains used for the provision of crypto-asset services, and its author- ity to freeze crypto-asset accounts. According to the President, these measures constituted a dispropor- tionate interference with the constitutionally protect- ed rights and freedoms of individuals and imposed excessively intrusive restrictions on the freedom to conduct business by entities operating in the crypto- asset market In this context it should be borne in mind that the MiCA transitional period for legacy crypto-asset ser- vice providers is due to expire on 1 July 2026. This state of legislative limbo is the defining theme of the Polish crypto-asset market in 2026. For prac- titioners advising Polish-licensed firms, foreign cryp- to-asset service providers (CASPs) passporting into Poland, and the country’s substantial retail-investor base, the unresolved question of when – and in what
final form – the Polish Financial Supervision Authority ( Komisja Nadzoru Finansowego or KNF) will become the designated competent authority under MiCA dominates almost every strategic conversation. The country’s largest crypto exchange has, in the mean- time, collapsed under circumstances that have inten- sified the political stakes of the implementing legisla- tion. The interaction of these threads – constitutional, political, supervisory and commercial – gives Poland in 2026 a distinctive profile within the EU. This article maps the trends shaping the Polish market through that lens. It examines the substantive points of contention between the executive and the head of state on the implementing bill, the consequences of the Zondacrypto failure for the policy debate, the operational realities of doing crypto-asset business in a transitional regime, and the practical compliance pathways available to firms intending to remain on the Polish market once the legislative process resolves. The Presidential Vetoes: A Battle Over Supervisory Design The President’s principal objections The fundamental tension that has shaped the Polish implementing process is not whether MiCA should be implemented – there is no serious dispute on that – but how the supervisory architecture should be calibrated. From the President’s perspective, the successive bills submitted for signature have demonstrated elements of regulatory overreach in relation to MiCA itself. The objective of MiCA is to harmonise the crypto-asset market across the European Union and enhance the security of users of virtual assets, while simultane- ously supporting the development of an innovative market and ensuring fair competition. The President’s veto statements have framed the legislation as dis- proportionately expanding the sanctions regime and the costs of supervising the cryptocurrency market beyond what MiCA itself contemplates. Three substantive areas have been at the centre of the disagreement. The first concerns the proposed man- datory supervisory fee, which would be calculated by reference to the average annual revenue of super- vised entities. The precise cap has varied between iterations of the bill, but in each version it has been framed by the President as disproportionate to the
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