MiCA in Limbo: What the Presidential Veto Means for CASP Licensing in Poland

MiCA in Limbo: What the Presidential Veto Means for CASP Licensing in Poland
January 2026

Introduction
The EU Markets in Crypto-Assets Regulation (MiCA) came into force on 30 December 2024. Designed to harmonise crypto regulation across the EU, it introduced a unified framework for crypto-asset service providers (CASPs). While many Member States have advanced their national implementation, Poland now finds itself in legal uncertainty. In December 2025, the President of Poland vetoed the national crypto-assets bill that would have implemented MiCA domestically.

This article explains:
- What the veto means for Polish crypto firms,
- The current legal status of VASP registrations,
- The impact on MiCA obligations and EU market access,
- What steps firms should take now,
- How APOG supports crypto businesses during this regulatory void.

The Legal Situation in Poland (as of January 2026)
MiCA is directly applicable in all EU Member States. Key rules—such as the Travel Rule and AML obligations—have been in effect since 30 December 2024. Title V of MiCA (CASP authorisation) will fully apply from 30 June 2025.
However, Poland has not passed a national law to implement MiCA. On 1 December 2025, the President vetoed the proposed Crypto-Assets Market Act. Parliament failed to overturn the veto. As a result:
- Poland has no designated supervisory authority (i.e., KNF cannot yet receive CASP applications),
- The VASP register under the AML Act remains active, but is insufficient for MiCA purposes,
- There is no legal framework for applying the shortened transitional period under Article 143(6) MiCA,
- No CASP licence can currently be granted in Poland.

Can Firms Still Operate with VASP Status?
MiCA allows legacy VASPs to continue operations until 1 July 2026, provided they were legally active before 30 December 2024. However:
- VASP registration under the AML Act does not confer passporting rights within the EU,
- Without national implementation, there is no certainty around the enforcement of MiCA standards,
- Operating under VASP only may expose firms to reputational and supervisory risk.

MiCA Obligations That Still Apply (Even Without Polish Law)
Regardless of the national legislative gap, the following obligations under MiCA already apply:
- AML and Travel Rule (since 30 December 2024),White paper requirements for crypto-asset offerings,
- Conduct of business rules, including conflict-of-interest policies, disclosure duties, and safeguarding of client funds,
- Organisational requirements such as governance, complaints handling, and ICT risk management (including DORA alignment).

Recommended Actions for Crypto Firms in Poland

1. Prepare a full CASP licence application, including governance, AML, ICT, and prudential modules.
2. Align with MiCA standards voluntarily to demonstrate compliance-readiness.
3. Monitor developments from KNF, the Ministry of Finance, and European Supervisory Authorities (ESAs).
4. Consider alternative EU jurisdictions if business continuity or passporting is urgent.

How APOG Supports Firms During the Transition
At AP Outsourcing Group, we help crypto firms navigate regulatory uncertainty with confidence. Our services include:
- CASP licence readiness: full application packs tailored to KNF or other EU NCAs,-AML outsourcing: KYC, GIIF reporting, Travel Rule compliance,
- MiCA compliance advisory,
- Crisis planning and interim compliance frameworks for operations during the legal gap.

Conclusion
Poland’s MiCA transition has entered a holding pattern. With the national law vetoed and no CASP licensing procedure in place, crypto firms face a regulatory vacuum. While VASP registration remains valid under Polish AML law, it is not MiCA-compliant and does not offer access to the EU market.Firms must act independently to comply with MiCA obligations and prepare licensing documents in advance. AP Outsourcing Group remains your partner in navigating MiCA—from strategy to execution.