Poland enters the final two months before the MiCA deadline (July 1st, 2026) without a national law that allows the KNF — Poland's financial supervision authority — to process CASP license applications. On February 12th of this year, the president vetoed for the second time the "Cryptocurrency Market Law", leaving the local ecosystem in regulatory limbo.
The problem in one sentence
Without the law, the KNF has no legal basis to issue CASP licenses. Without CASP license, no provider can operate in the European Union from July 1st, 2026.
Who is affected
According to sector estimates, more than 1,500 VASPs are currently registered in Poland. All of them operate today under the old regime, which expires on June 30th. Those that were registered before December 30th, 2024 are entitled to the grandfathering clause, which allows them to continue operating until the granting or refusal of a MiCA license — but this does not help if the KNF cannot even review applications.
The way out: passporting via another Member State
MiCA was designed with the principle of the single European passport. A CASP licensed in any Member State can offer services in all 27 countries of the bloc without additional licenses.
Polish providers who want to maintain regular operations can seek authorization in jurisdictions with functional regimes — Lithuania and Estonia are the most cited, with operational MiCA frameworks and agile review processes. Once licensed, they do passporting to legally serve Polish customers.
What this means for ON3X
ON3X obtained VASP registration in Poland before the grandfathering deadline, which placed us among the players authorized to continue operating during the transition. In parallel, our compliance team is monitoring the veto proceedings and has already mapped continuity routes via EU passporting, ensuring that European users have no interruption whatsoever in accessing platform services.
The Polish case also serves as a warning to the ecosystem: compliance is not a detail, it is critical infrastructure. Players who delayed compliance until the last quarter are now exposed to the worst scenario — operate illegally or cease activities.
Next steps
The Polish Parliament may attempt to override the veto with a qualified majority, or a new version of the law may be presented. Until then, the market watches closely how the EU will treat Member States that fail to implement MiCA within the deadline — with potential for sanctions and reverse passporting restrictions.