POLAND Trends and Developments Contributed by: Michał Wołoszański, Łukasz Kudela and Marta Solarska-Kaleńczuk, Wołoszański & Partners
Outlook By the time the next edition of this guide is published, the Polish implementing legislation will, in all probabil- ity, be in force. The questions that will then dominate are different ones: • how quickly the KNF builds the institutional capac- ity to process CASP authorisation applications at scale; • how the courts approach the first generation of crypto-asset-related criminal and civil cases under the new regime; • how the Zondacrypto prosecution shapes broader expectations of supervisory behaviour; and • how Polish-led firms balance the choice between domestic authorisation and authorisation else- where in the EU.
For the moment, Poland in 2026 is a study in legisla- tive friction. It hosts a large and active retail market, a sophisticated developer community, a respected supervisor in the KNF and a central securities deposi- tory (KDPW) that is genuinely engaged with the under- lying technology. It is also, at the time of writing, the principal MiCA implementation case study for what happens when a comprehensive European framework collides with a politically contested national legislative process and an industry crisis that crystallises in real time. The shape of the resolution will define the Polish market for the next several years.
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