MiCA Poland: Key CASP License Updates & Regulatory Changes (March 2025)

The landscape of crypto-asset regulation in Poland is evolving rapidly as the government fine-tunes its approach to MiCA (Markets in Crypto-Assets Regulation) implementation. Although the Polish Cryptoasset Act has not yet been officially adopted, recent statements from Deputy Minister of Finance, Jurand Drop, at the European Financial Congress shed light on significant upcoming changes that could impact businesses seeking a CASP (Crypto-Asset Service Provider) license.

As first reported by Gazeta Prawna, the Polish Ministry of Finance is introducing key amendments following extensive public consultations. With over 700 pages of public consultation feedback, Polish authorities are now reshaping the draft legislation to better reflect industry needs, creating a more flexible and business-friendly regulatory framework. 

Below, we break down the key proposed changes, their implications for CASPs, and how Poland is positioning itself as a competitive jurisdiction for crypto businesses under MiCA.

 

1. Cryptocurrency Lending Ban Removed

One of the biggest concerns in the original draft of the Polish Cryptoasset Act was a proposed ban on cryptocurrency lending. However, following recommendations from the Polish Financial Supervision Authority (KNF), the regulator responsible for overseeing MiCA CASP licensing, this restriction has been removed.

This is a major win for the industry, as crypto lending is a fundamental service offered by many platforms. Its removal signals that Polish regulators are willing to listen to market participants and adapt legislation accordingly.

2. Extended Transition Period for VASPs

Originally, the draft law required all existing VASPS virtual service asset providers (VASPs) to submit full licensing documentation to the KNF by June 30, 2025. However, in response to industry concerns, the government has extended the transition period:

• Instead of a fixed deadline, VASPs will now have four months from the law’s effective date to comply (we still don’t know when the law is effective from)
• This means that, depending on when the bill is enacted, businesses could have up to nine months in total to meet regulatory requirements.

This flexibility will help crypto firms avoid rushed compliance efforts, allowing them to strategically prepare and adapt to the evolving regulatory framework.

3. Adjusted Recovery and Buy-Back Plan Requirements

Another major revision focuses on recovery and buy-back plans, a requirement under MiCA designed to protect investors and ensure market stability.

• The initial draft of the law imposed overly stringent conditions, which could have disproportionately burdened smaller CASPs.
• After reviewing industry feedback, the Ministry of Finance has decided to revise these obligations to create a more balanced regulatory approach.

This update ensures that while investor protection remains a priority, businesses won’t face unnecessary regulatory hurdles that could limit market growth.

4. Greater Transparency for CASPs

Transparency and consumer protection remain central to Poland’s approach to MiCA implementation. Minister Drop emphasized that crypto users must have full access to information about the entities they interact with.

To achieve this, new measures will require CASPs to:

• Provide clear, structured information about their services and operational risks.
• Maintain strong compliance frameworks to ensure investor confidence.
• Operate in a way that fosters a safe, progressive, and open ecosystem for the cryptoasset market.

This approach aligns Poland with broader MiCA objectives, ensuring that the country remains both competitive and investor-friendly.

 

What These Changes Mean for Crypto Businesses in Poland

Poland’s revised approach to MiCA implementation offers a more balanced regulatory framework, benefiting existing VASPs, new CASPs and investors. These adjustments demonstrate that regulators are:

✅ Listening to market feedback and adjusting laws accordingly.
✅ Creating a more business-friendly environment while maintaining investor protections.
✅ Positioning Poland as an attractive jurisdiction for crypto businesses seeking a MiCA CASP license.

However, it’s important to note that the Cryptoasset Act has not yet been officially published, and further modifications may still occur. Businesses should stay informed and be ready to adjust once the final version of the law is enacted.

For companies planning to register as CASPs in Poland, these updates highlight the importance of regulatory preparedness. With a longer transition period and clearer compliance requirements, businesses now have more time to align with MiCA obligations and implement robust compliance frameworks.

 

How Complium Can Help

At Complium, we specialize in MiCA CASP licensing in Poland, helping businesses navigate the complexities of regulatory compliance. Our team provides:

Strategic Guidance – Assessing how MiCA regulations impact your business.
Application Support – Ensuring a smooth, compliant CASP registration process.
Regulatory Compliance Assistance – Implementing AML compliance.
Ongoing Advisory Services – Helping you stay ahead of regulatory changes.

With Poland emerging as a leading EU crypto hub, now is the time to prepare for MiCA compliance and secure your CASP license.

Need assistance with your CASP application? Contact us today for expert support!