POLAND Trends and Developments Contributed by: Michał Wołoszański, Łukasz Kudela and Marta Solarska-Kaleńczuk, Wołoszański & Partners
costs imposed on other participants in the financial market, and as therefore undermining the principle of equal treatment of entrepreneurs in economic activity. The second area concerns the proposed authority of the KNF to maintain a register of internet domains used for activity in breach of MiCA, and to direct that such domains be blocked. In the President’s view, the relevant provisions are insufficiently precise and could allow excessive interference in the activities of busi- nesses. The third concerns the proposed power to block crypto-asset accounts and payment accounts, which the President has characterised as excessive in light of the parallel mechanisms already available under anti-money-laundering and counter-terrorist- The third version of the bill, which was passed by the Sejm on 15 May 2026, retained the substantive supervisory architecture of its predecessors. Public commentary on the bill suggests that it is, in its core provisions, broadly similar to the earlier versions. As is now known, however, it once again failed to meet the President’s expectations. The final form of the leg- islation, including the calibration of the supervisory fee, the scope of the domain-blocking register and the parameters of the account-blocking power, remains subject to the outcome of the ongoing legislative pro- cess. financing legislation. Status of the third bill What is clear is that the political question has not yet been settled. The repeated nature of the disagreement between the legislature and the head of state suggests that resolution will require a constructive process of dialogue and possible amendment, rather than a sim- ple re-tabling of the same text. As one of our authors observed in March 2026, the legal issues identified by the President are not, in themselves, insurmount - able; they are matters of calibration, susceptible to reasoned adjustment rather than wholesale rejection of the underlying regulatory concept. Importantly, in response to the continuing legislative deadlock, a group of members of parliament from the governing coalition studied their own bill. The pro- posal is based on the government’s draft legislation but has been revised to address the President’s objec-
tions. The bill was submitted to the Sejm on 18 June 2026. However, the Sejm has not yet commenced its consideration. The authors of the bill have announced that they will seek to have it considered under an expedited legislative procedure The Zondacrypto Affair and Its Aftermath In April 2026, Zondacrypto, one of the most active crypto-asset exchanges operating in the Polish mar- ket, became the subject of serious public allegations concerning delays in processing withdrawals, wal- let balances and control over reserve assets. Polish press reports referred to on-chain analysis raising questions about the level of bitcoin (BTC) visible in wallets attributed to the exchange. The company’s CEO subsequently referred in a public statement to a cold-storage address which, according to him, held approximately 4,500 BTC, while also indicating that access to the relevant private keys was not under the company’s current control. Polish prosecutors have reportedly opened an inves- tigation concerning suspected fraud and money-laun- dering offences connected with the exchange. At the time of writing, no final findings have been made and the allegations remain subject to criminal proceed- ings. Policy consequences The Zondacrypto affair has reframed the political debate around the implementing legislation in impor- tant respects. Before April 2026, the public conver- sation centred on the President’s objections to per- ceived over-regulation, the cost burden on supervised entities and the proper limits of the KNF’s intervention- ary powers. After April, the conversation has been at least equally about the question of how to prevent a recurrence. The two narratives are not always easy to reconcile: the same provisions that one camp charac- terises as overreach are, from the other perspective, precisely the supervisory tools that might have permit- ted earlier intervention. It is fair to note that the conduct under discussion straddled the transition to MiCA. Before 30 Decem- ber 2024, the domestic regulatory gateway for virtual- currency businesses was essentially AML registration rather than prudential CASP supervision. After that
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