Poland's MiCA Deadline Looms: No CASP Law, No Licenses After 1 July 2026

As of March 2026, Poland still does not have a national MiCA‑implementing act in force, and the Crypto‑Assets Market Act remains stalled.

The transition period ends on 30 June. From 1 July 2026, all market participants will be required to hold a Polish CASP licence unless they obtain CASP licenses from other EU member states with operational regimes (e.g., Lithuania, Estonia) and passport services into Poland via MiCA.
 
What is the current legislative status?

Poland still lacks a national act implementing the EU MiCA Regulation (Markets in Crypto-Assets). The Crypto-Assets Market Act, intended to enable CASP (Crypto-Asset Service Provider) licensing by the Polish Financial Supervision Authority (KNF), was vetoed by the President for the second time on 12 February 2026, leaving it stalled.​
MiCA (Regulation (EU) 2023/1114) applies directly in Poland from 30 December 2024, but Poland has not yet designated KNF as the MiCA competent authority via stable national legislation.
 
Transitional Period

MiCA's Article 143(3) allows entities registered in Poland's RDWW (Virtual Currency Activity Register) before 30 December 2024, to operate until 1 July 2026, or until obtaining a CASP authorization.
 
Post-July 2026: No Polish CASP licenses without Crypto-Assets Act

Without the Crypto-Assets Market Act, the KNF cannot process CASP license applications, leaving VASPs unable to obtain Polish authorization. They lose the right to provide services domestically after 1 July 2026, as VASP status expires and MiCA requires CASP licensing unless they obtain CASP licenses from other EU member states with operational regimes (e.g., Lithuania, Estonia) and passport services into Poland via MiCA Regulation.
In its latest communication, the KNF made four critical points:
 

• If by 1 July 2026 Poland still has no designated MiCA authority, entities operating under the Polish transitional regime will lose the right to provide crypto-asset services until they obtain MiCA authorisation.
• This deadline cannot be extended by Polish law or KNF decision - it is fixed by MiCA Regulation.
• Authorisation proceedings in Poland can only begin once a competent authority is designated by the Polish law. Until then, there is no domestic licensing pathway.
• CASPs authorised in other EU Member States will continue to serve Polish clients via MiCA passporting.

 
Non-compliance may cause administrative sanctions under MiCA Regulation and website blocking by KNF.

Woźniak Legal has the expertise to make you succeed in crypto assets. Our team guides you through every step of the way - from company setup and licensing to acquiring a licensed business.

Please contact us on office@woznialegal.com.

You can also email me directly on grzegorz.wozniak@wozniaklegal.com.