Chapter | Chambers | 2026
We wrote for Chambers and Partners about crypto-asset regulation in Poland: from MiCA (the EU Markets in Crypto-Assets Regulation) and CASP licensing, through AML, to stablecoins, tokenisation, DeFi and tax.
Chambers Global Practice Guides are legal guides published by Chambers and Partners, in which law firms from each jurisdiction describe local law under a common structure. The Blockchain & Crypto-Assets 2026 guide lets you compare how blockchain and crypto-assets are regulated across jurisdictions.
The Poland chapter was written by Michał Wołoszański, Łukasz Kudela and Marta Solarska-Kaleńczuk of Wołoszański & Partners. It consists of a Law and Practice section in seven parts (from blockchain and crypto-assets, through regulation, licensing, cross-border services and DeFi, to payments, stablecoins and tokenisation) and a Trends and Developments article on MiCA implementation in Poland. The publisher gives 11 June 2026 as the date of the last update.
Crypto-asset regulation in Poland has three layers: the EU Markets in Crypto-Assets Regulation (MiCA), fully applicable since 30 December 2024, anti-money laundering (AML) rules and financial instruments law. Where a token is a financial instrument, MiCA does not apply and capital markets law does.
MiCA divides crypto-assets into asset-referenced tokens (ARTs), e-money tokens (EMTs) and other crypto-assets, including most utility tokens. The Polish Financial Supervision Authority (KNF) is expected to become the MiCA competent authority once the implementing act is in force. AML supervision sits with the General Inspector of Financial Information (GIIF), and the Register of Activity in the Field of Virtual Currencies is kept by the Director of the Tax Administration Chamber in Katowice. No business model is banned outright: what is prohibited is operating without the required authorisation, notification, white paper or registration.
As of 11 June 2026, as described in the Chambers chapter, a CASP licence could not be obtained in Poland: without the act implementing MiCA, the KNF cannot authorise a crypto-asset service provider (CASP). The President vetoed three successive versions of the act: on 1 December 2025, 12 February 2026 and 11 June 2026.
The transitional period for existing operators ended on 1 July 2026. Polish firms in the virtual currency register (VASPs) cannot use the EU passport, and no new register entries have been possible since 30 December 2024. The practical route is therefore authorisation in another EU Member State, with real substance: a registered office and effective management in the EU and at least one EU-resident director.
Minimum capital is EUR 50,000 (including advice, portfolio management, reception, transmission and execution of orders, and transfer services), EUR 125,000 (custody and exchange) or EUR 150,000 (operating a trading platform), unless one quarter of the previous year's fixed overheads is higher. The authority has 25 working days to assess completeness and 40 working days to assess a complete application. We explain how to prepare an application on our digital assets and CASP licensing page.
Since October 2021, following the implementation of the fifth AML Directive (AMLD5), virtual currency businesses in Poland must be entered in the register, and they are obliged institutions under AML law. AML obligations also apply to CASPs once authorised.
Crypto-asset transfers are subject to the travel rule under Regulation (EU) 2023/1113, which requires sender and recipient data to accompany each transfer. DORA, the EU Digital Operational Resilience Act, has also applied since 17 January 2025. The chapter highlights banking barriers: some banks refuse or terminate relationships with crypto clients, and a 2022 KNF communication called for a risk-based approach.
A public offer of crypto-assets and admission to trading require a white paper. An asset-referenced token (ART) white paper must be approved by the regulator; for other crypto-assets, notification is enough. Exemptions (other than for ARTs and EMTs) include offers to fewer than 150 persons per Member State, offers only to qualified investors and offers below EUR 1 million in total over 12 months.
MiCA does not use the term stablecoin. A token referencing a single official currency is an e-money token (EMT), which only credit institutions and e-money institutions may issue, and holders can redeem it at par at any time. Issuers and CASPs may not pay interest or grant any other benefit for simply holding such tokens, so yield products need careful structuring.
Asset tokenisation in Poland is assessed by the nature of the underlying asset, not the technology. A token equivalent to a financial instrument falls under capital markets law, while other tokens may be crypto-assets under MiCA. Poland has no comprehensive tokenisation regime. The Act of 16 August 2023 on the development of the financial market introduced the DLT account for tokenised financial instruments.
Decentralised finance (DeFi) is not prohibited in Poland. Fully decentralised services with no intermediary fall outside MiCA (Recital 22), but partly decentralised ones may be caught. A decentralised autonomous organisation (DAO) has no legal personality under Polish law, so projects that need one use a company or foundation, in Poland or abroad.
A paid disposal of virtual currency, meaning its exchange for money, goods, services or other property rights, is subject to a flat 19% income tax in Poland. Exchanging one cryptocurrency for another is tax-neutral. Tax law uses the AML concept of virtual currency rather than MiCA's crypto-assets, so the status of NFTs, utility tokens and tokenised assets is uncertain. Staking, lending, yield farming, airdrops and hard forks also remain unclear.
Since 1 January 2026, CASPs have been collecting data for DAC8 (Council Directive (EU) 2023/2226 on the exchange of tax information on crypto-assets), with the first exchanges between Member States in 2027.
The chapter sets out what to do whatever happens to the Polish act: MiCA-compliant policies (governance, safekeeping of client assets, conflicts of interest, complaints, outsourcing), documented safeguarding and capital calculations, AML procedures with an appointed AML officer, travel rule arrangements and an orderly wind-down plan. Supervisors will expect operational reality, not paperwork. Reverse solicitation, serving clients only at their own initiative, is not a way into the EU market.
Legal position: as described in the chapter last updated by the publisher on 11 June 2026. The rules may have changed since then, so check the current position with us before you decide.
Chapter published in: Chambers Global Practice Guides - Blockchain & Crypto-Assets 2026, Poland (opens in a new tab) (Chambers and Partners).
According to the chapter last updated on 11 June 2026, no: the President vetoed three successive versions of the act, most recently on 11 June 2026.
The chapter reports that a group of MPs submitted a revised bill to the Sejm on 18 June 2026, addressing the President's objections. The dispute centred on a supervisory fee based on revenue, the KNF's power to block domains and the power to block accounts. MiCA applies directly in Poland, so operating without CASP authorisation after 1 July 2026 remains a real risk whatever happens to the act. Check the current position with us.
Between EUR 50,000 and EUR 150,000 depending on the services, or one quarter of the previous year's fixed overheads if that is higher.
EUR 50,000 applies to services such as advice, portfolio management, reception, transmission and execution of orders, placing and transfer services. EUR 125,000 applies to custody and exchange services, and EUR 150,000 to operating a trading platform. The safeguard can take the form of own funds, insurance, a comparable guarantee or a combination.
No: a crypto-to-crypto exchange is tax-neutral in Poland.
Tax at 19% arises on a paid disposal of virtual currency, meaning its exchange for money, goods, services or other property rights. Deductible costs are generally limited to documented acquisition and transaction costs. Staking, lending, airdrops and NFTs remain uncertain.
Yes: a CASP authorised in another EU Member State can provide services in Poland under the EU passport.
The passport covers only the authorised services and requires a notification to the home-state authority. Services can start once transmission of the notification is confirmed, or at the latest 15 calendar days after it was filed. Polish general rules still apply, including consumer, advertising, tax, data protection and language rules.
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We advise crypto businesses, fintechs and funds on CASP licensing, the move from the VASP register, and MiCA and AML compliance.
