Name
Global FinTech Guide
Country _ Name
Poland
SectionTitle
DLT and cryptocurrencies
Body
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.

Introduction

Attitude of the country towards financial services using crypto currencies

State institutions strongly engage in and support the financial innovation sector.
The Working Group on the Development of Financial Innovation was established on the initiative of the Financial Supervision Authority (Komisja Nadzoru Finansowego), the Ministry of Finance and the Ministry of Development in response to dynamic technological changes in the financial services market.

The purpose of the group is to identify legal, regulatory and supervisory barriers to the development of financial innovation in Poland and to prepare proposals for solutions that could eliminate or reduce the identified barriers.

For the first time in 2021, the Financial Supervision Authority has also launched a virtual sandbox to support the development of the Polish market for financial innovation. It was the first stage of development of the offer of the Polish Financial Supervision Authority concerning technological support for FinTech entities in the form of virtual domain sandboxes. In 2023, the Financial Supervision Authority with the Central Securities Depository launched the Virtual Sandbox DLT (Blockchain).

Notably, in June 2025, the Financial Supervision Authority approved the first Bitcoin-based ETF available on the Polish market. This milestone marks a significant step toward integrating crypto assets into the mainstream financial sector, indicating a gradual shift in regulatory attitudes and opening new opportunities for institutional investors seeking exposure to Bitcoin.

Despite the Polish government’s declared commitment to supporting financial innovation, as evidenced by the establishment of working groups and the launch of virtual sandboxes for FinTech and blockchain, the Ministry of Digital Affairs’ June 2025 decision to deny a leading cryptocurrency exchange access to the Polish identity verification system (mObywatel), on the grounds that cryptocurrencies are “incompatible with good practices”, underscores a major regulatory inconsistency.


Legal affairs

Obligations and requirements to provide financial services using crypto currencies described above

The Financial Supervision Authority has recently been focusing on the regulatory environment for cryptocurrencies related to the introduction of MiCA. Accordingly, it has been emphasizing education initiatives regarding the investor protection involving trading in cryptocurrencies. It has reminded that as of today, trading in cryptocurrencies is not regulated by law and therefore, there is a very high exposure to risk in this type of trading.

The Authority did not change it’s attitude towards crypto-assets, as it has informed on its website that new legal provisions will not change the risks associated with this type of trading, among other things; very high volatility of value, highly speculative character due to lack of efficient and proven valuation methods, lack of a clear and universally accepted economic value, operational risk of loss of access to own funds, linked to the early stage of development and high complexity of the technology used.

Additionally, the entry into force of the Regulation on the information accompanying transfers of funds and certain crypto-assets (TFR or Travel Rule) has further strengthened the regulation of entities operating in the crypto-asset market from an AML perspective. The provisions of the TFR regulation have already been addressed in a communication from the General Inspector of Financial Information, as mentioned below.

As with assessing the need for other FinTechs to comply with regulatory requirements, in this case again, it is necessary to analyse the nature of the services offered by a given company each time. For example, if the services provided by the FinTech will qualify as payment services it will be necessary to obtain the status of a payment institution in accordance with the provisions of the Payment Services Act (ustawa o uslugach platniczych), if the company will conduct business it will be necessary to obtain a license in accordance with the Financial Instruments Trading Act (ustawa o obrocie instrumentami finansowymi), etc.

As of today (under the AML Act). activity in the field of virtual currency exchanges may be performed upon the entry in the register of virtual currency activities. The entry in the register is subject to a fee of PLN 616 (approx. EUR 130).

As of today, following the entry into force of the MiCA regulation, it is no longer possible to register new virtual currency exchange activities under the AML Act in the register of entities providing crypto-assets services, which is conducted by National Fiscal Administration in Katowice (VASP Register). The VASP Register is closed to new applicants, and new market entrants must comply with the licensing requirements set out by MiCA. Under the MiCA regulation, obtaining a CASP (Crypto-Asset Service Provider) license is mandatory to legally operate in the crypto-asset market across the EU, including Poland. In Poland, the Financial Supervision Authority is designated as the competent authority to issue such licenses. However, due to delays in enacting the national Crypto-Assets Market Act (Ustawa o rynku kryptoaktywów), Financial Supervision Authority is not yet legally authorized to process or grant CASP license applications. As a result, submitted applications remain unreviewed, and no CASP licenses are currently being issued in Poland.

The Financial Supervision Authority has published a position statement summarising the communications to date on the issuance and trading of cryptocurrencies and has taken the view all along that trading in cryptocurrencies comes with risks.
On 30 December 2024, the TFR regulation came into force. This regulation requires entities operating in the crypto market to transmit detailed information about the originator and beneficiary of crypto-asset transfers, increasing transparency and anti-money laundering obligations. In practice, this means that businesses must implement procedures to verify ownership of wallets and adopt appropriate technical and organizational measures. In the context of TFR implementation, businesses should review the European Banking Authority (EBA) guidelines.

According to the General Inspector of Financial Information’s October 2024 communication, from 30 December 2024, entities dealing with virtual currencies must comply with the TFR Regulation on information accompanying transfers of funds and certain crypto-assets. This introduces new AML and counter-terrorism financing requirements, including verifying ownership or control of unhosted wallets involved in transfers and providing information on the originator and beneficiary. To comply, businesses will need to implement appropriate technical and organisational measures. The TFR applies to entities registered in the VASP Register. Both current operators and those seeking MiCA authorisation should follow the European Banking Authority’s guidelines.

Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

The introduction of a definition of virtual currencies in the Anti-Money Laundering and Countering the Financing of Terrorism Act (Ustawa o przeciwdzialaniu praniu pieniedzy oraz finansowaniu terroryzmu) ('AML Act') made it possible to consider them as a type of property right. Thanks to this, revenue from the disposal of property rights may be taxed as income from business activity or additional sources. Entities operating cryptocurrency exchanges are obligated institutions under the AML Act and must therefore comply with all the obligations set out therein.

As part of the National Risk Assessment on Money Laundering (Krajowa Ocena Ryzyka Prania Pieniedzy oraz Finansowania Terroryzmu), it was noted that over the past few years, there have been significant changes in both the risks and vulnerabilities of money laundering and terrorist financing in Europe. More and more information are emerging about the use of new financial solutions to commit the above-mentioned crimes. Among other things, the dynamic development of crypto-actives also entails an increase in the level of risk in the above area. It is worth noting that in the 2022 Supranational Risk Assessment on Money Laundering and Terrorist Financing, the European Commission estimated the risk of money laundering as well as the risk of terrorist financing for crypto-actives at the highest level on a 4-point scale. At the same time, from 2021 onwards, legislative changes are under way in the European Union, in particular as part of the so-called AML/CTF package, which are intended to, among other things, mitigate this risk (e.g. implementing the MiCA regulation).
Crypto-assets will also be regulated under the AML Regulation, which will cover, among other things, risk mitigation measures related to anonymous instruments and transactions involving unhosted addresses, as well as enhanced due diligence measures for cross-border correspondent relationships involving crypto-assets.

The regulatory framework regarding crypto-assets has significantly changed since 30 December 2024, that is after the MiCA regulation took effect. The regulation envisages new developments in the area of the crypto-asset market sector, in particular with regard to effective supervision and investor protection. Taking measures to achieve the aforementioned objectives will ensure the development of the market as well as ensure security in the long term by expanding supervisory competences. Accordingly, Polish legislators are working on the Crypto-assets Market Act, however, as of now, it is in the preliminary stages of work.
The most important change will be to subject companies providing crypto-services to the supervision of the Financial Supervision Authority. Specifically, MiCA provides a comprehensive licensing procedure for these entities, conducted before the Polish supervisory authority, which is similar to the existing licensing procedure to which domestic payment institutions are currently subjected. Therefore, in order to obtain a license, crypto-asset providers will have to meet precautionary requirements (i.e. have a specified capital reserve, and corporate governance measures undertaken). Accordingly, under MiCA, crypto-asset services providers are now obliged to maintain professional secrecy.

Poland has implemented an interim period of 18 months that is allowed under MiCA – therefore, the businesses provide services regarding crypto-currencies, and are currently registered in VASP Register, will function without any additional obligations imposed upon them until 1 July 2026. After that day, the VASP Register, will cease to exist. All other entities however, will be subject to the licensing procedure as indicated in MiCA.

The Crypto-assets Market Act introduces administrative penalties for violations of MiCA and related laws, which may be imposed by the Financial Supervision Authority, as well as criminal sanctions that fall within the competence of judicial authorities.
The Crypto-assets Market Act will also aim at digitalizing trading measures, mainly introducing the possibility of making declarations of intent in electronic form with regard to services involving cryptocurrencies or their public offerings. It is envisaged that the declaration of intent so made shall have the force of a declaration of intent equal to that of a declaration made in writing under pain of nullity.


Economic conditions

Market size for financial services using crypto currencies and biggest companies in this business area

The cryptocurrency market in Poland continues to grow dynamically, although it is still difficult to precisely determine its exact value and growth rate, despite the steadily increasing number of people using cryptocurrency exchanges. The most commonly used exchanges in Poland in 2025 include: Binance, Kraken, Coinbase, Bybit, and Zondacrypto. However, it is worth noting that other platforms, such as KuCoin, Bitget, and Crypto.com, are also gaining in popularity


Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

N/A

Authors

Close

Choose country