In recent months, there has been an intensified debate in Poland about our national interpretation of the EU MiCA regulation. As a reminder, Poland is one of the last countries in the European Union that has not yet introduced its version of the act on the crypto-assets market. Things gained momentum this year, as a result of which, among other things, consultations were held in the Sejm. Unfortunately, despite substantive talks, the openness of some of the political environment and arguments brought by industry practitioners, on September 26, the Sejm voted on a draft law that harms the interests of companies and investors operating on this market.
In the next step, the act went to the Senate, where it was stuck in amendment mode. It will then be forwarded to the desk of President Karol Nawrocki. This is where the industry sees a chance to block new regulations, which are among the most restrictive in the entire European Union. As Bitcoin.pl, we joined the list of companies that signed the appeal to veto the bill. We hope that the industry’s arguments will be heard and the cryptocurrency market in Poland will finally gain a favorable environment for development.
We publish here the full, original content of the appeal prepared by representatives of the Polish cryptocurrency industry, also published on the website of the Polish Bitcoin Association, in the social media of market entities and other media interested in the matter.
Appeal to the President of the Republic of Poland
to veto the Act on the Crypto-Asset Market of September 26, 2025 (the Act implementing Regulation (EU) 2023/1114 – MiCA and Regulation (EU) 2023/1113 – the so-called “travel rule”)
Dear Mr. President,
We, representatives of Polish companies operating on the crypto-asset market, appeal to veto the act adopted by the Sejm on September 26, 2025, regulating this sector.
Although the Act formally implements the EU MiCA regulation, in practice it goes far beyond its framework. Instead of ensuring transparent and proportionate rules consistent with European law, it introduces hundreds of pages of additional regulations, criminal sanctions and numerous administrative obligations, making the Polish implementation one of the most restrictive in the entire European Union.
It’s not just a regulatory issue, it’s an economic issue. The adoption of this act in its current form means that Polish capital will be pushed out of its own market and opportunities for foreign expansion will be lost. In practice, this means that companies operating in Poland today – financed from domestic funds, employing Polish specialists and paying taxes in the country – will be replaced by foreign entities, often from outside the European Union. These, in turn, will be able to offer their services in Poland without incurring either economic risk or liability towards Polish institutions.
The Polish cryptoasset market is of real importance for the economy
The latest Kraken stock exchange study, described in Forbes Polska magazine (October 2025; source), shows that 30.9% of Poles invest in cryptocurrencies – this is more than those who invest in shares (21.5%) or bonds (19%). Additionally, 71.3% of respondents transact at least several times a month, and 65.6% used digital assets as a means of payment.
These are just a few data that show that the cryptoasset market is not a niche, but an important part of the everyday financial decisions of millions of Poles and a real branch of the digital economy (as shown in the TEP report, TOG 31/2025). Poland has the potential to become one of the most important centers for the development of blockchain technology in Europe – as long as the regulatory framework is proportionate and favorable to innovation.
It is worth recalling that just a few years ago Poland was a leader in the world of cryptocurrencies – it was in our country that one of the first cryptocurrency exchanges and blockchain projects in Central and Eastern Europe was established, attracting international capital and users. Unfortunately, this leadership was lost due to excessively restrictive policies and unfriendly actions of the Polish Financial Supervision Authority, including blocking bank accounts and unjustified delays in permit granting processes. Today’s bill threatens to perpetuate this situation and completely push the Polish crypto sector out of the European market.
Key threats arising from the Act
1. Overregulation (so-called goldplating)
While many member states have limited the implementation of MiCA to a few or a dozen pages of technical changes, the Polish act contains several hundred articles and provides for additional regulations. It introduces, among others: a ban on marketing activities regarding basic cryptocurrencies or the possibility of blocking websites by administrative decision, without the right to appeal to court. Such solutions are not justified in MiCA and put Polish companies in a worse competitive position compared to entities operating in other EU countries.
2. Disproportionate requirements
The process of obtaining permits in Poland has been subject to additional requirements, including: the need for staff to have knowledge and competences in the financial market – although MiCA only requires knowledge of cryptoassets. The short deadline for obtaining permits (June 30, 2026) at the current pace of administrative work may result in many Polish companies not having time to complete the process.
This means not only the loss of jobs and investments in Poland, but also a real risk that the entire market will be taken over by foreign entities that will obtain permits in other EU countries and will operate in Poland in a cross-border model – without any actual presence, taxes or contribution to the Polish economy.
3. Transfer of supervision to the Polish Financial Supervision Authority
The act entrusts supervision over the crypto-assets market to the Polish Financial Supervision Authority – an institution that has been hindering the development of the industry in Poland for years. These included social dissuasive campaigns, as well as the practice of refusing to open bank accounts and many years of delays in permit processes. There are serious concerns that the Polish Financial Supervision Authority will not provide independent and proportionate supervision over the new market. If the regulations are to operate effectively, it is necessary to consider entrusting this task to an independent and specialized institution, and not to an authority that has consistently fought against the development of the sector in the past.
Experience from other areas of the financial market shows that the Polish Financial Supervision Authority is one of the most restrictive and least flexible regulators in the EU:
- over the last 10 years, the Polish Financial Supervision Authority issued only 2 permits for brokerage houses, while the German BaFin – over 100,
- at the same time, the Polish Financial Supervision Authority granted only 1 permit for electronic money institutions (EMI), while over 100 were issued in Lithuania.
In practice, this means that obtaining a permit in Poland may prove to be very difficult, and entrepreneurs will be forced to transfer their activities to other EU countries, from where they will still provide services to Polish clients, but without national control and without creating jobs in Poland.
Additionally, the act provides for high fees related to the permit process and constant supervision. For many smaller, local companies, these costs will be prohibitive.
Our position
We do not expect the state to promote cryptocurrencies. We expect fair, proportionate and predictable regulations, consistent with the EU MiCA regulation. Regulations that will ensure user protection and at the same time allow Poland to use the potential of innovative technologies and maintain the competitiveness of the digital economy.
The Act in its current form:
- does not protect investors, but blocks the development of enterprises,
- does not support innovation but creates barriers,
- does not strengthen Polish competitiveness, but gives the market to foreign entities,
- does not increase user safety, but pushes some activities to the gray zone,
- does not provide a stable and predictable legal framework, but leaves entrepreneurs in regulatory uncertainty.
Our request
We are asking the President to veto the act and refer it to re-development, so that the implementation of MiCA takes place in accordance with its assumptions and creates conditions conducive to the development of the Polish digital economy.
As representatives of the industry, we declare our readiness for dialogue and participation in the legislative process. We believe that based on the knowledge of practitioners and open cooperation, a legal framework can be created that will ensure the safety of citizens and, at the same time, make Poland an attractive place for innovative investments and technology development.
