Poland Postpones CASP Licensing: What It Means for Crypto Businesses in 2026

The Presidential Veto That Changed the CASP Timeline

On December 1, 2025, Poland’s President Karol Nawrocki vetoed the long-anticipated Act on the Crypto-Assets Market. This legislation was intended to align Poland’s legal framework with the EU’s MiCA Regulation and introduce a formal process for obtaining the CASP Crypto license in Poland.

This development creates uncertainty for crypto-asset service providers (CASPs) who were preparing to transition from the existing VASP register to full MiCA compliance. While MiCA as an EU regulation is binding, its effective application still requires national implementation — including the appointment of a supervisory authority and licensing procedures.

Why the Veto Matters for CASP License Applicants

Without a national legal framework, it is currently impossible to apply for a CASP license in Poland. Until new legislation is introduced and approved, the country lacks the necessary mechanisms to accept or process licensing applications under MiCA.

President Nawrocki cited three main issues:

• Unclear domain-blocking powers, raising concerns about censorship and access to funds;

• Excessive length and complexity of the law, making it harder for startups to comply;

• High supervisory fees, which could restrict entry for small and medium-sized operators.

The result? Delays, uncertainty, and a postponed launch of the CASP framework until at least mid-2026.

What Crypto Businesses Can (and Should) Do Now

Despite the veto, companies already listed in the Polish Register of Virtual Currency Activity (RDWW) are still legally allowed to operate. Under MiCA’s transitional rules, these businesses can continue their services until July 1, 2026, as long as they maintain compliance with AML and reporting obligations.

Now is the time to:

• Update internal procedures to align with upcoming MiCA standards;

• Prepare documentation such as AML policies, terms of service, and compliance manuals;

• Evaluate licensing strategy to ensure quick onboarding once the new law is adopted.

At Lawskar, we help crypto businesses navigate this complex landscape. Whether you’re a VASP in Poland or planning to enter the market in 2026, our legal team will guide you through MiCA preparation, RDWW management, and the upcoming CASP transition.

Forecast: CASP Licensing in Poland from 2026

Poland is expected to revisit and revise its legislative proposal in early 2026. The updated version will likely address the concerns raised by the president, particularly regarding proportional regulation and equal market access for smaller players. Until then, the Sejm has limited options to fast-track licensing procedures.

However, crypto companies that act now — by reviewing compliance structures and refining their governance — will be the first in line when applications open.

Lawskar is already preparing clients for this next stage. We assist with:

• Gap analyses for MiCA alignment

• Ongoing compliance with Polish AML law

• Drafting and structuring policies for future license submissions

• Legal representation before Polish financial authorities

Ready for 2026? Your MiCA-Compliant CASP Launch Starts Today

The deferral of Poland’s crypto law doesn’t mean standing still. With the MiCA regulation fully applicable across the EU from June 2024, the competitive advantage will go to firms that are proactive, not reactive.

If your crypto project is targeting the Polish or broader EU market, now is the moment to build a legally sound foundation. Contact Lawskar today — our lawyers will ensure your company is ready to meet all CASP requirements the moment the framework is live.