Every other EU member state has a functioning MiCA regime by now. Poland doesn’t. As of September 2026, more than two months after MiCA’s transitional period closed across the Union, Poland is the only EU country without a national authority empowered to license crypto-asset service providers — and it isn’t drift or bureaucratic delay that put it there. It’s a genuine, three-round policy fight between the government and President Karol Nawrocki over what a Polish MiCA law should actually require, fought line by line over fees, website-blocking powers, and the length of the bill itself, and it has now outlasted the EU deadline it was supposed to meet.
Understanding why takes more than noting that a veto happened. Nawrocki has vetoed three separate versions of the same underlying law, each time citing specific, largely consistent objections to specific provisions — not simply political opposition to regulating crypto at all. The government has revised the bill twice in response and still hasn’t satisfied him. That’s a genuinely unusual outcome for EU-mandated implementing legislation, and the substance of the disagreement is worth walking through in detail, because it tells you exactly where Polish crypto regulation is likely to land whenever this finally resolves.
What the Blocked Bill Actually Does
Strip away the politics and the Crypto-Asset Market Act is a fairly conventional MiCA implementing statute. It designates the Polish Financial Supervision Authority, the KNF, as the national competent authority responsible for authorizing and supervising CASPs, ART and EMT issuers, and other crypto-asset offerors. Most of what MiCA left for member states to fill in — how a CASP applies, how the KNF handles passporting notifications arriving from other EU countries, how whitepaper approvals under Article 17 actually get processed — shows up here too.
Fees turned out to be one of the harder points of contention. Under the version that reached the president’s desk, a CASP authorization is capped by statute at the PLN equivalent of €4,500, under Article 77(1)(1)(a), and the same number shows up repeatedly elsewhere in the bill: €4,500 to authorize an asset-referenced token offering, €4,500 for a CASP authorization or scope extension, another €4,500 for KNF review of a passporting notification. On top of those one-off fees, CASPs owe an annual supervisory charge of up to 0.5% of their average crypto-asset service revenue over the preceding three financial years, with a floor of the PLN equivalent of €750 regardless of revenue. Capital requirements track MiCA’s own three-tier structure directly — from €50,000 for advisory and order-transmission services up to €150,000 for operating a trading platform.
Two other pieces of the bill turned out to matter more than the numbers. First, the whitepaper liability regime: anyone who prepares or participates in preparing a crypto-asset whitepaper is jointly and severally liable for its content, a liability that can’t be limited or excluded toward third parties, though the parties involved can privately agree how to allocate the cost between themselves. Second, and by far the most contentious provision in the entire law: a register of domains linked to unlawful crypto activity, paired with an obligation on telecommunications providers to block access to those domains once they’re listed . That single mechanism is what has now sunk the bill three times.
Round One: «A Real Threat to the Freedoms of Poles»
Nawrocki refused to sign the first version of the Act on 1 December 2025. His chancellery’s public statement was unusually direct for a piece of financial-services legislation: the bill, it said, «posed a real threat to the freedoms of Poles, their property and the stability of the state». The specific target was the domain-blocking mechanism. The president’s office argued the government would be able to «disable the websites of cryptocurrency companies with a single click,» calling the blocking regime «opaque and potentially open to abuse,» and more aggressive than equivalent provisions in other countries.
The veto statement went further than the blocking powers alone. Nawrocki’s office described the bill — reportedly around 100 pages — as excessively long and complex compared with the MiCA implementing laws passed in the Czech Republic, Slovakia, and Hungary, arguing that complexity itself reduces transparency and produces «overregulation». He framed the consequence in blunt competitive terms: «Overregulation is an easy way to drive companies to the Czech Republic, Lithuania, or Malta instead of creating conditions for them to operate and pay taxes in Poland» . The fee structure drew a separate objection. Nawrocki argued that high supervisory fees would suppress startup activity while leaving larger, often foreign, corporations and banks comparatively unaffected — «a perversion of logic,» in his words, «the killing of a competitive market, and a serious threat to innovation».
The government’s response was immediate and dismissive. Tusk’s cabinet resubmitted a revised bill within days, and ministers publicly accused the president of manufacturing chaos in the market by blocking a law the EU required Poland to pass.
Round Two, and Nothing Really Changes
A revised version went back to the Sejm, passed, and reached Nawrocki’s desk again. He vetoed it a second time on 13 February 2026, and this time the reasoning barely differed from December: the measures were still «too onerous,» still lacked transparency, still posed the same «real threat to the freedoms of Poles» his office had described two months earlier. Whatever the government had actually changed in the intervening weeks clearly hadn’t touched the parts he cared about — domain blocking and the fee structure were still there, still drawing the same objections.
A second veto on nearly identical grounds tells you something the first one didn’t. Either the government hadn’t substantially revised the disputed provisions, or no revision short of scrapping domain blocking entirely was ever going to satisfy the president’s office. Both readings point to the same structural problem: the two sides weren’t negotiating toward a compromise so much as talking past each other from fixed positions.
Round Three: «Ignored Objections»
The Sejm tried once more, passing a further revised version on 15 May 2026 and transmitting it to the president on 22 May, under Sejm print 2363. Nawrocki vetoed that version too, in June 2026 — his third rejection of the same underlying law, and coverage at the time characterized his justification as citing objections from the earlier rounds that the government had simply failed to incorporate. By this point the dispute had less to do with any single new provision and more to do with an accumulating pattern: three drafts, three vetoes, and by the president’s own account, the same unresolved complaints carried forward each time.
The Deadline Arrives Anyway
MiCA’s own transitional period didn’t wait for Warsaw to sort this out. Article 143(3) set an EU-wide deadline of 1 July 2026 for the old, pre-MiCA national VASP registrations to lose their legal effect, regardless of whether any given member state had finished its own implementing legislation . The KNF flagged the coming collision explicitly in a position paper published on 10 February 2026 — right in the window between the second and third vetoes — warning that without a functioning Polish crypto-asset act, there would be no domestic authority capable of accepting CASP applications, and that Polish entities on the old register would lose their right to provide crypto-asset services once the transitional period closed, however early or thoroughly they’d prepared.
That’s exactly what happened on 1 July. An entry in Poland’s old virtual-currency register stopped conferring any authorization to provide crypto-asset services, in Poland or anywhere else in the EU. Meanwhile, CASPs licensed anywhere else in the EU retained full passporting rights into Poland, because that right flows from MiCA itself and doesn’t depend on Poland having a working domestic regulator . The result is a lopsided market: foreign-licensed exchanges can serve Polish customers without friction, while Polish firms have no domestic path to a license at all.
A Fraud Scandal Changes the Political Weather
The standoff’s political dynamics shifted sharply in August 2026, when Zondacrypto, a Polish exchange, became the subject of an investigation into the alleged embezzlement of roughly $94 million in client funds . Prime Minister Donald Tusk publicly called for the Crypto-Asset Market Act to be revised and passed in response, framing the scandal as a direct illustration of exactly the supervisory vacuum his government had been warning about since December.
The scandal reframed the argument in a way that was harder for the president’s position to absorb cleanly. His objections up to that point had centered on protecting Polish businesses and citizens from overregulation and government overreach. A homegrown exchange allegedly losing $94 million in client funds, in a market with no domestic regulator empowered to have prevented it, cut directly against that framing — every month the law stayed blocked was now also a month with no KNF oversight standing between Polish crypto customers and firms like Zondacrypto .
The Override Vote That Fell 25 Votes Short
That pressure fed into an override attempt on 4 September 2026. Overriding a presidential veto in Poland requires a three-fifths majority of members present in the Sejm — 266 votes, given 442 lawmakers in the chamber that day. The motion secured 241 votes in favor, 198 against, and three abstentions, falling 25 votes short. The veto stood. The Crypto-Asset Market Act, in its third form, is now legally dead, and nothing in Polish procedure compels the government to move faster on a fourth attempt than it did on the first three.
An Industry Already Relocating
Polish crypto firms have converged on a straightforward response to the deadlock that doesn’t depend on Warsaw resolving anything: relocate the licensing entity to a member state with a working MiCA regime, then serve Polish and EU customers through passporting from there. Slovakia, Latvia, Lithuania, and Cyprus have all been recommended specifically because they have functioning national authorities and established CASP authorization pipelines. The guidance from at least one Polish law firm has been blunt: if a business plan depended on the transitional period that closed on 1 July 2026, the moment to build a fallback jurisdiction plan was well before that date, not after.
There’s a genuine irony sitting underneath that advice. Nawrocki’s original objection was that an overly burdensome Polish law would push companies to relocate to the Czech Republic, Slovakia, or Malta. The absence of any Polish law at all is producing precisely that relocation, just for the inverse reason — not because Polish rules are too strict, but because there currently are none to license under. Firms aren’t fleeing tough regulation. They’re fleeing a regulatory vacuum that leaves them with no legal way to operate at home at all.
Where This Leaves Poland
Poland hasn’t opted out of MiCA, and it can’t. The regulation applies there exactly as it applies everywhere else in the Union, and Polish consumers get the same MiCA protections as customers of any properly authorized CASP, wherever that CASP happens to be licensed. What Poland lacks is the domestic infrastructure MiCA assumed every member state would build in time: a functioning KNF authorization pipeline, a national sanctions and enforcement regime, a Polish CASP register, and the supervisory capacity that comes with all of it.
The dispute blocking that infrastructure isn’t manufactured or symbolic. It’s a real disagreement about specific tradeoffs — how aggressively the state should be able to block websites, how fee structures should be weighted between startups and larger institutions, how long and complex a compliance statute needs to be before complexity itself becomes a problem — and neither side has shown much sign of shifting position after three full rounds. Until a fourth version either survives a presidential signature or the Sejm manages to find those missing 25 votes, Polish crypto businesses are left choosing between waiting out a stalemate with no fixed end date or doing what a growing number already have: taking their license application to a country where the argument has already been settled.
SOURCES
Official Legislative Record
-
Sejm of the Republic of Poland — Bill text, Sejm print 2363 (full PDF)
-
Polish Ministry of Finance (gov.pl) — «Sejm przyjął ustawę o rynku kryptoaktywów»
-
Poland’s Fintech portal (fintech.gov.pl) — «Polish Act on Crypto-Assets Market adopted by the Sejm»
KNF (Polish Financial Supervision Authority)
EU Legal Text
