
Briefing
Poland’s lower house of parliament, the Sejm, has approved the Crypto-Asset Market Act (Bill 1424), establishing a comprehensive licensing regime for all Crypto Asset Service Providers (CASPs) under the oversight of the Polish Financial Supervision Authority (KNF). This legislative action, designed to align with the European Union’s Markets in Crypto-Assets Regulation (MiCA), introduces rigorous compliance requirements and significant penalties, including fines up to 10 million Polish zlotys (approximately $2.8 million USD) and potential two-year prison terms for violations. Entities operating within Poland will face a six-month transitional period to secure the necessary KNF licenses once the bill is enacted.

Context
Prior to this Act, Poland’s crypto regulatory landscape primarily relied on Anti-Money Laundering (AML) legislation, lacking a comprehensive framework for digital assets. This created a fragmented environment where direct supervision by financial authorities was limited, and specific licensing for crypto service providers was absent. The prevailing challenge for market participants involved navigating an evolving legal status for cryptocurrencies, which were treated as taxable assets rather than legal tender, with regulatory oversight mainly focused on AML compliance and taxation.

Analysis
This Act fundamentally alters business operations for CASPs by instituting a mandatory licensing framework, requiring extensive disclosures on corporate structure, capital adequacy, internal controls, and Anti-Money Laundering (AML) procedures. Regulated entities must now integrate robust compliance systems to meet these heightened standards, affecting product structuring, internal governance, and risk management protocols. The introduction of severe criminal liabilities, including substantial fines and imprisonment, elevates the stakes for non-compliance, compelling a re-evaluation of existing operational models to ensure full adherence. This legislative move signals a shift towards a more regulated and institutionalized digital asset market within Poland, demanding significant investment in compliance infrastructure.

Parameters
- Legislative Body ∞ Polish Parliament (Sejm)
- Regulatory Act ∞ Crypto-Asset Market Act (Bill 1424)
- Supervisory Authority ∞ Polish Financial Supervision Authority (KNF)
- Jurisdiction ∞ Poland (aligning with EU MiCA)
- Targeted Entities ∞ Crypto Asset Service Providers (CASPs), including exchanges, issuers, and custody providers (domestic and foreign)
- Key Requirement ∞ Mandatory KNF licensing for all CASPs
- Penalties for Violations ∞ Fines up to 10 million Polish zlotys (approx. $2.8 million USD) and up to two years imprisonment
- Compliance Period ∞ Six-month transitional period post-enactment

Outlook
The Act’s progression to the Senate and Presidential review marks the next critical phase, with potential for further amendments or even a Presidential veto due to industry backlash over its perceived restrictiveness. This action sets a significant precedent for national interpretations of MiCA, potentially influencing other EU member states in their domestic implementations. The heightened regulatory burden could foster a more secure, albeit potentially less innovative, market by driving out smaller entities and consolidating power among larger, compliant players. The industry will closely monitor the KNF’s licensing efficiency and the ultimate impact on Poland’s competitive standing in the global digital asset landscape.