Why was the original crypto bill vetoed in Poland?
Poland Resubmits Crypto Bill: No Changes Made After Veto-What’s Next?
Poland has re-tabled its crypto regulatory bill without amendments after a presidential veto, setting up a high-stakes legislative finish just as the EU’s MiCA regime takes hold. For exchanges, wallet providers, and token projects, the outcome will shape who supervises crypto in Poland, how fast licenses arrive, and whether firms can passport services across the EU on schedule.
Why Poland’s Unchanged Resubmission Matters for Crypto
The draft is primarily designed to align Polish law with the EU’s Markets in Crypto-Assets Regulation (MiCA) and the updated Transfer of Funds Regulation (TFR). Because MiCA is directly applicable EU law, Poland must still designate a national competent authority, set enforcement and penalty frameworks, and define transition rules for domestic firms.
- MiCA alignment: Creates a licensing framework for crypto-asset service providers (CASPs), establishes conduct-of-business, prudential, and custody standards, and sets market-abuse rules for crypto.
- Supervision: Poland is expected to empower a national authority (widely anticipated to be KNF, the Polish Financial Supervision Authority) to authorize and oversee CASPs.
- AML/travel rule: Integrates EU TFR obligations so Polish CASPs collect and transmit originator/beneficiary data for crypto transfers, including risk controls around unhosted wallets.
- Sanctions and enforcement: Sets administrative fines and remedial measures for non-compliance, necessary for effective MiCA/TFR application in Poland.
- Transition: Determines whether Poland grants the full MiCA transitional “grandfathering” (potentially up to July 2026) for firms already registered under Poland’s virtual currency activities register.
Resubmitting the bill without changes signals political urgency to meet EU timelines and avoid regulatory gaps. It also implies the governing camp is aiming for speed-either to secure an override of the veto or to bring stakeholders back to the original terms without reopening negotiations.
Legislative Path: Veto Override or Another Stalemate?
Under Poland’s Constitution, a presidential veto can be overridden by a three-fifths majority in the Sejm (lower house) with at least half of all deputies present (3/5 of 460 seats = 276 votes). If that threshold isn’t met, the bill fails and would need to be drafted again or renegotiated.
Scenarios and Implications
| Scenario | What Happens | Impact on Crypto Firms |
|---|---|---|
| Veto override succeeds | Bill becomes law as resubmitted | Clear designation of supervisor (likely KNF), known timelines, path to EU passporting stabilizes |
| Override fails; bill stalls | Regulatory uncertainty continues | Delays in Polish licensing; firms may seek licenses in other EU states to passport into Poland |
| Renegotiation/new draft | Compromise language, more time | Short-term uncertainty; potential for better-tailored rules but slower market clarity |
EU Timeline Check: MiCA and TFR Milestones
MiCA is already partially in force across the EU, with the remainder effective for CASPs and trading platforms. TFR’s crypto travel rule also applies EU-wide, pushing data-sharing standards into everyday operations.
| Item | EU Timeline | Poland Relevance |
|---|---|---|
| MiCA stablecoin rules (ART/EMT) | In effect since mid-2024 | Issuers face EBA/ESMA standards; need national enforcement tools |
| MiCA CASP regime | Applicable since late 2024 | Licensing, conduct, custody, market-abuse rules require a designated supervisor |
| Transitional “grandfathering” for existing firms | Up to July 2026 (member-state option) | Poland’s bill likely sets terms; clarity affects domestic players’ runway |
| TFR (crypto travel rule) | Applicable since late 2024 | Polish CASPs must transmit payer/payee data and manage unhosted wallet risks |
Operational Impact: Exchanges, Wallets, Token Issuers
Even as politics play out, EU rules are live. Firms should move as if the stricter interpretation will apply.
What to do now
- Map services to MiCA CASP categories: exchange, custody, execution, advice, portfolio management, OTC, and operation of a trading platform.
- Prepare a MiCA-ready application pack: governance and fit-and-proper documentation, safeguarding/custody controls, segregated client asset policies, incident response, complaints handling, outsourcing registers, and market-abuse monitoring.
- Travel rule compliance: implement counterparty due diligence, data collection, and screening workflows; address interactions with unhosted wallets using a risk-based approach.
- Token issuance: assess whether your asset requires a MiCA white paper; check utility vs. asset-referenced/e-money tokens; avoid treating large NFT collections as excluded by default.
- Licensing strategy: if timelines in Poland remain uncertain, consider applying in another EU jurisdiction to secure an EU passport, then service Poland cross-border once operational.
Poland-specific context
- Registration baseline: Poland maintains a register of virtual currency activities; firms already on it may benefit if Poland opts for the full MiCA transition period.
- Supervision landscape: KNF oversees financial markets; AML supervision involves the General Inspector of Financial Information (GIIF). The new law is expected to clarify roles for crypto under MiCA/TFR.
- Sanctions and consumer protection: Expect explicit administrative fines, mandatory disclosures, complaints-handling standards, and potential public warning powers.
Key Risks if the Bill Stalls Again
- Regulatory gap: EU rules apply, but Poland lacks fully specified national enforcement and licensing pathways.
- Passporting disadvantage: Polish firms may fall behind peers licensed in MiCA-ready EU jurisdictions.
- Stablecoin uncertainty: Issuers and distributors face higher compliance expectations without clear domestic supervision lines.
- Banking relationships: Without national clarity, some banks may maintain cautious stances toward crypto clients.
Conclusion: Prepare for MiCA Either Way, Hedge Jurisdictional Risk
By resubmitting an unchanged bill after the veto, Poland has forced a binary choice: secure a three-fifths override or head back to the drawing board. For crypto businesses, the prudent path is to implement MiCA-grade controls now, maintain Polish registration where applicable, and-if timing is critical-pursue a MiCA license in a jurisdiction with a fully operational regime, preserving EU-wide market access. Whether Poland’s Sejm overrides the veto or renegotiates, the firms that align early with MiCA, TFR, and robust AML controls will be best positioned to serve Polish users and passport across the EU in 2025-2026.




