Polish Crypto Asset Market Act Vetoed by President: What’s Next?
The Polish Crypto Asset Market Act has undergone a major shift.
As introduced in CryptoLicense’s October blog, the Act had secured approval from the lower house of parliament and was widely regarded as a significant step toward aligning Poland with the EU’s stricter MiCA-based regulatory framework.
However, on December 1, the Polish president issued a formal veto of the Act. According to the President’s Office, several provisions exceeded MiCA requirements and could create unnecessary regulatory burdens, hinder market freedom, and negatively affect the country’s business environment. As a result, the president declined to sign the bill.
The veto introduces fresh uncertainty into Poland’s MiCA rollout. Because the legislative process must now restart, Poland is unlikely to complete full MiCA alignment by the end of 2025 as previously planned, leaving the pathway toward CASP licensing in a state of uncertainty.
This article summarizes the bill’s key provisions, analyzes the core reasons behind the veto, and assesses the potential direction of Poland’s regulatory landscape. What will Poland’s approach toward MiCA implementation and crypto regulation look like after the veto?
The Crypto Asset Market Act was designed to provide Poland with the operational rules needed to implement MiCA. Spanning roughly 104 pages, it laid out the authorization process, supervisory powers of the Financial Supervision Authority (KNF), regulatory fees, penalties, transitional arrangements, and other supporting details.
(CryptoLicense provided a detailed overview in our earlier post: Poland’s New Crypto Rules: Stricter Oversight Signals, and Why Acting Early Matters)
In the version approved by the Sejm in September, industry attention largely centered on two key elements:
1. Regulatory Fee of 0.4%
The Act required crypto asset service providers to pay a 0.4% annual regulatory fee based on revenue. This sparked criticism across the industry:
- For smaller VASPs and exchanges operating on thin margins, the fee could impose significant financial pressure.
- Compared with lower regulatory fees in other EU jurisdictions, the proposal risked weakening Poland’s competitive position.
2. Website-blocking Powers
The bill allowed the KNF to block unlicensed websites and platforms, including the creation of a “banned domain list.”
Although intended to protect consumers, industry stakeholders raised concerns that:
- Administrative authority could be overextended.
- Broad blocking powers might disrupt legitimate operations and restrict online access.
The President’s Office emphasized that the president supports regulating digital assets—but only through clear, moderate measures that remain aligned with MiCA and avoid excessive state intervention. The veto was primarily driven by three concerns:
1. Risks of Overregulation
Unlike countries such as the Czech Republic, Slovakia, or Hungary—where MiCA alignment was achieved through brief, technical amendments—Poland’s 100+ page bill was far more extensive.
The president argued that this density of rules could raise operational costs, encourage firms to relocate to other jurisdictions, and ultimately harm Poland’s competitiveness.
2. Potential Abuse of Domain-Blocking Powers
The Act allowed regulators to block CASP websites through a single administrative decision.
The president highlighted the lack of transparency and the possibility of overreach, noting that such actions could even prevent users from accessing their digital assets.
By contrast, many EU member states rely on simple “warning lists” rather than domain-level blocking.
3. Regulatory Fee Could Distort Market Competition
The proposed 0.4% fee was viewed as disproportionately high.
It could burden smaller domestic firms while being easier for large foreign companies to absorb, potentially undermining balanced competition and stifling innovation.
Possible Paths Forward for Polish Crypto Regulatory Framework
The veto does not signal a rejection of MiCA itself, but rather the need to revise the draft. Based on currently available information, several scenarios are possible:
1. A New “MiCA +0” Bill
Industry observers expect Poland may draft a new bill that fully mirrors MiCA without adding national-level requirements—often described as a “MiCA +0” model.
Such an approach would avoid expanding supervisory authority beyond EU standards and could make Poland one of the most competitive jurisdictions for obtaining a CASP license.
2. Legislative Delay and Restart
Another possibility is that lawmakers amend the existing draft and restart the legislative debate.
If the process is prolonged, Poland’s MiCA adaptation could be pushed into mid-2026 or later.
During discussions, some have floated the idea of creating a dedicated regulatory agency for CASPs.
However, the cost and time required make this unlikely. The more realistic option is for KNF to remain the primary authority—potentially with a dedicated internal division for crypto oversight.
Stay Ahead with Flexible Compliance: CryptoLicense Is Here to Help
Following the presidential veto, Poland will temporarily maintain its existing VASP registration framework.
Nevertheless, MiCA—an EU-wide regulation—remains on track, meaning Poland must eventually develop its own aligned implementing rules.
CryptoLicense expects the revised Polish bill to emphasize streamlined provisions, minimal national add-ons, and closer alignment with MiCA to balance regulatory clarity with market development.
If you’d like to understand more about Poland’s licensing landscape, MiCA adaptation strategies, or evaluate your own compliance pathway within the EU, our CryptoLicense advisory team is ready to assist. We provide timely, professional guidance and actionable solutions tailored to your business needs.