The European market is operating in a transitional period, taking into account the evolving regulatory environment associated with MiCA.

Crypto companies must continue to comply with existing laws while simultaneously preparing for the full implementation of MiCA. The Polish financial supervisor has been developing its expertise in financial innovation for many years. The experience gained from licensing small and national payment institutions (MIP/KIP) has become a natural reference point for the new regulatory framework governing the crypto-asset market. With the entry into force of the EU-wide MiCA framework and national provisions assigning KNF supervisory responsibility over crypto-asset service providers (CASPs), it is now possible to compare these two supervisory approaches.

What Do the Supervision of MIP/KIP and the Crypto Market Have in Common?

For many years, KNF has required payment institutions to maintain transparent governance structures, appoint competent individuals responsible for key functions, and ensure genuine decision-making processes. A similar approach is embedded in crypto-asset regulation: token issuers and CASPs must demonstrate that their activities are organized in a structured manner with a clear allocation of responsibilities.

Within the supervision of MIP/KIP, one of the core elements is the safeguarding of users’ funds — through segregation mechanisms, guarantees, and appropriate AML procedures. A comparable emphasis is present in MiCA: issuers of asset-referenced tokens and service providers must ensure the protection of client funds and the minimization of abuse risks.

KNF has repeatedly stressed that payment institutions must possess a real operational infrastructure — staff, systems, procedures, and technological capabilities. The same requirement applies to the crypto-asset market: firms cannot rely on declarations alone; they must demonstrate their actual ability to provide services in compliance with regulatory requirements. Well-drafted procedures are necessary to obtain a licence, but they must reflect the company’s actual operations.

Where Will Crypto-Asset Supervision Require a Different Approach?

Payment institutions operate primarily within national or EU regulatory frameworks. By contrast, the crypto-asset market is inherently global, cross-border, and built on decentralized technologies. This requires KNF to develop new competencies, engage in international cooperation, and monitor phenomena that do not arise in traditional payment services.

In the case of payment institutions, cybersecurity is important; in the crypto space, it becomes critical. Smart contract exploits, protocol vulnerabilities, risks associated with private key custody, and susceptibility to market manipulation all require supervisors to deploy fundamentally new tools and expertise.

MiCA, in particular, introduces an obligation to publish so-called white papers — documents describing a token, its functions, risks, and operating model. This represents a fundamentally new approach, absent from MIP/KIP supervision, where documentation is primarily operational and regulatory in nature. In crypto-asset markets, transparency towards users is key, as they often make investment decisions based on information provided by issuers.

Poland was one of the first countries in the region to introduce clear licensing procedures for MIP and KIP. As a result, the supervisor developed a practical approach to assessing innovative business models, analyzing technological risks, and verifying the substance of organizational structures. Today, this experience is highly valuable in shaping supervision of the crypto-asset market, which in Poland is only now entering a more advanced regulatory phase.

At the same time, new rules — both at the EU and national levels — present KNF with challenges that did not exist in traditional payment services. The crypto market requires greater flexibility, a solid understanding of blockchain technology, and continuous monitoring of global trends and risks.

Poland has a strong supervisory foundation thanks to many years of work with payment fintechs. Many principles — such as governance, client protection, and the requirement for genuine operational substance — transfer naturally to the crypto market. At the same time, the specific nature of crypto-assets necessitates a new approach: greater emphasis on technology, cybersecurity, and information transparency.

It is precisely this combination of accumulated experience and new challenges that creates the conditions for crypto-asset supervision in Poland to develop in a stable and predictable manner — for the benefit of the entire financial market.

 

Crypto-asset supervision: key takeaways

  • KNF’s years of payment-fintech oversight transfer directly to crypto-asset supervision: governance, safeguarding of client funds, and real operational substance.
  • Crypto-asset supervision also demands new competencies — cross-border reach, cybersecurity, and MiCA white-paper review.
  • Poland’s mature supervisory foundation positions crypto-asset supervision to develop in a stable, predictable way.

See the Polish Financial Supervision Authority (KNF) and Regulation (EU) 2023/1114 (MiCA). Our services: CASP / MiCA licensing.