The Veto
On December 1, 2025, President Karol Nawrocki vetoed the Crypto-Assets Market Act (Bill 1424), Poland's legislation intended to implement the EU's MiCA Regulation. The President stated the law posed "a real threat to the freedoms of Poles, their property and the stability of the state."
The bill had been approved by the Sejm in September 2025 after government work since February 2024. It would have designated the Polish Financial Supervision Authority (KNF) as the competent authority for crypto-asset market supervision.
Why Was It Vetoed?
- Overregulation concerns — critics argued the bill went beyond MiCA requirements, granting KNF powers including website blocking and fines up to PLN 10 million
- Account freezing powers — the KNF could freeze crypto accounts for 96 hours, extendable to 6 months, without prior judicial oversight
- High compliance costs — particularly burdensome for smaller firms
- Political dynamics — the President is aligned with the opposition and has vetoed multiple government bills
What Happens Next?
The Sejm attempted to override the veto on December 5, 2025, but fell short of the required 3/5 majority (243 votes for, 192 against; 261 needed). On December 8, the ruling coalition introduced a new bill (Bill 2050), described as "improved" but largely identical. The Sejm passed it on December 22 by 241-183 and sent it to the Senate.
Impact on the Market
- No domestic CASP licensing — KNF cannot process authorization applications without the national act
- Foreign competitors have an advantage — MiCA-licensed entities from other EU states (Cyprus, Lithuania, France) can already serve Polish clients via passporting
- Transitional period ticking — entities registered in the RDWW can operate until July 1, 2026, but time for preparation is shrinking
- ESMA guidance — ESMA's December 2025 statement warns entities to prepare orderly wind-down plans
Strategic Options for Polish Crypto Firms
- Apply for a CASP license in another EU jurisdiction — Cyprus, Lithuania, and Czechia are popular choices. Processing time: 3-6 months.
- Prepare MiCA documentation now — regardless of when the Polish act passes, the substantive requirements are the same
- Monitor legislative developments — the new bill may pass in early 2026, but faces another potential presidential veto
- Develop a wind-down contingency — per ESMA guidance, have a plan if authorization is not obtained by July 1, 2026
Affected by the MiCA situation in Poland? Contact us for a strategic assessment.