MiCA implementation begins – what does it mean for the crypto market in Poland?

MiCA and Polish regulations – who are the new regulations aimed at?

The MiCA (Markets in Crypto-Assets Regulation) regulation introduces uniform rules for the crypto-asset market in the European Union. The new regulations cover both the issuance of tokens and the activities of crypto-asset service providers (CASP).
In practice, this means that entities offering crypto assets to the public or operating trading platforms will have to meet certain licensing and transparency requirements.

Who is subject to MiCA?

According to MiCA, a crypto-asset service provider is a legal person or company that professionally provides crypto-asset services to clients. To operate legally, each such entity must obtain a CASP licence, which in Poland will be issued by the Polish Financial Supervision Authority (KNF).

The regulation distinguishes 10 categories of cryptoasset-related services. Cryptoasset services are regulated in Article 3(1)(16) of the MiCA, including:

• providing crypto-asset custody and administration services on behalf of clients;
• operating a trading platform for crypto-assets;
• exchanging crypto-assets for cash;
• exchanging crypto-assets for other crypto-assets;
• executing orders related to crypto-assets on behalf of clients;

placing crypto-assets;

• Placing crypto assets;
• Accepting and forwarding orders related to crypto assets on behalf of clients;
• Advising on crypto assets;
• Managing a crypto asset portfolio;
• Providing crypto asset transfer services on behalf of clients;

Any entity that provides even one of the above services must comply with the new MiCA regulations.

MiCA and the Polish crypto market – key changes

Until now, the Polish cryptocurrency market has operated in the absence of dedicated sectoral regulations. The only requirement was to be entered in the register of activities in the field of virtual currencies and to comply with the AML Act.
After the MiCA comes into force, the situation will change dramatically:

✅ The Polish Financial Supervision Authority (KNF) will gain full supervisory powers over cryptocurrency exchanges, crypto bureaux de change and custody companies,
✅ Obligation to obtain a CASP licence – operating without a licence will become illegal after a transitional period,
✅ Introduction of capital requirements – 50,000 euros or 125,000 euros or 150,000 euros for crypto-asset service providers.
✅ Necessity to implement risk management, audit and compliance systems.

For Polish companies, this means having to comply with strict requirements or ceasing their operations. It is also possible that market consolidation will accelerate, with smaller entities being taken over by larger companies. 

Is Poland ready for MiCA?

The Polish draft law on the crypto-asset market generally reflects the assumptions of MiCA, adapting the national legal order to the new EU regulations, but potential legislative delays could lead to regulatory chaos.

📌 Transition period – Poland shortened the transition period to the end of June 2025, and therefore had to implement the relevant regulations before 30 December 2024 in order to effectively limit the EU ‘grace period’.
📌 Risk of companies leaving – as it is still not possible to apply for a licence in Poland, cryptocurrency companies may move their operations to other EU countries where the procedures are already being implemented.

Summary – how to prepare your company for MiCA?

MiCA is a revolution for the crypto market in Poland. Every company operating in this sector should as soon as possible:

✅ Check whether it is subject to MiCA and what licences it will need to obtain,
✅ Prepare to implement organisational and capital requirements,
✅ Monitor legislative progress and adapt to new regulations,
✅ Consider seeking legal assistance in the process of obtaining a CASP licence.

Failure to comply with the new regulations will mean that you will have to either close down or move your business to another EU country.
If you run a company related to the cryptocurrency market, contact us now to prepare for the changes!