Is Crypto Legal in Poland?

Poland's AML Act is the Act of 1 March 2018 on counteracting money laundering and terrorist financing (Dz.U. 2018 poz. 723), in force since 13 July 2018; its latest consolidated text is Dz.U. 2025 poz. 644, as later amended.

Under Art 2(1) pkt 12 of the AML Act of 1 March 2018 (Dz.U. 2025 poz. 644), obliged institutions include businesses providing exchange between virtual currencies and means of payment, exchange between virtual currencies, and intermediation in either exchange.

The AML Act of 1 March 2018 covers businesses keeping virtual-currency accounts (Art 2(1) pkt 12 lit. d), defined in Art 2(2) pkt 17 lit. e as an electronic set of identification data giving authorised persons the ability to use virtual-currency units, including to exchange them.

Payment institutions, small payment institutions and e-money institutions under the Payment Services Act of 19 August 2011 are supervised by KNF (Act on financial market supervision, Art 1(2) pkt 5, Dz.U. 2026 poz. 935); handling only fiat funds is not one of the virtual-currency services listed in AML Act Art 2(1) pkt 12.

Poland's pre-MiCA regime is the register of virtual-currency activity under Arts 129m–129z of the AML Act of 1 March 2018, kept for the Minister of Finance by the Director of IAS Katowice (not GIIF); it has accepted no new entries since 30 December 2024, and since 1 July 2026 an entry confers no right to provide crypto-asset services.

Poland has no MiCA implementing act as of 14 October 2026: the Act on the crypto-asset market passed the Sejm three times (prints 1424, 2064, 2529) and was vetoed by the President on 1 Dec 2025, 12 Feb 2026 and 11 Jun 2026; each override vote failed (5 Dec 2025, 17 Apr 2026, 4 Sep 2026). No Polish competent authority is designated for crypto-asset service providers, so no Polish CASP authorisation can be obtained (Ministry of Finance, 9 June 2026); KNF would have been the authority under the vetoed acts.

Virtual-currency activity under the AML Act of 1 March 2018 may be carried on by a natural person, a legal person or an organisational unit without legal personality (Art 129n(1)); a Polish company is not required, although the register has accepted no new entries since 30 December 2024.

The AML Act of 1 March 2018 sets no minimum capital requirement for entry in the virtual-currency register: Arts 129n–129o require only a clean criminal record and knowledge or experience; the register has accepted no new entries since 30 December 2024.

The AML Act (Art 129n) requires that a natural person running virtual-currency activity, or the partners, representatives and management of a legal entity, its managers and beneficial owner, have no final conviction for listed intentional offences — including against economic trading, money and securities, property, documents, for profit — or an intentional fiscal offence.

Applications to the virtual-currency register were filed only electronically via the ePUAP platform to the Director of IAS Katowice (AML Act Art 129r(1); Dz.U. 2021 poz. 1964), not to GIIF; no new entries have been possible since 30 December 2024.

Register applications are examined by the minister responsible for public finance (AML Act Arts 129p–129q), whose tasks were delegated to the Director of IAS Katowice by the ordinance of 25 October 2021 (Dz.U. 2021 poz. 1964); GIIF does not review them.

Entry in the virtual-currency register (AML Act Art 129r) has not been possible since 30 December 2024, and IAS Katowice states that an entry does not entitle anyone to act as a crypto-asset service provider (CASP) or VASP in or outside Poland.

The AML Act fixed the processing time: the register organ (Director of IAS Katowice) had to make the entry within 14 days of receiving the application and declaration (Art 129r(3)); GIIF had no role, and no new entries have been possible since 30 December 2024.

Entry in the virtual-currency register carried a stamp duty of PLN 616, paid with the application (IAS Katowice); the register has accepted no new entries since 30 December 2024.

No Polish authority, including KNF, has been designated as the MiCA competent authority for crypto-asset service providers or ART issuers; KNF is competent only for e-money token issuers (KNF communiqué updated 23 June 2026), because the implementing act was vetoed three times (1 Dec 2025, 12 Feb 2026, 11 Jun 2026).

The MiCA Art 143(3) transitional period for firms serving Polish clients under national law before 30 December 2024 ended on 1 July 2026 (KNF, MF); no Polish statute set a period, no notification to KNF was available, and since 1 July 2026 only CASPs authorised in another member state and passported under MiCA Art 65 may serve Poland.

GIIF (Generalny Inspektor Informacji Finansowej) is Poland's financial intelligence unit: obliged institutions, including virtual-currency businesses, notify it of suspected money laundering or terrorist financing (AML Act Art 74); it controls their AML compliance (Art 130(1)) and publishes the UN terrorism lists on which obliged institutions freeze assets (Arts 117–118).

KNF does not license or supervise VASPs: virtual-currency businesses were entered in a register kept by IAS Katowice, GIIF controls their AML compliance (AML Act Art 130(1)) with KNF acting only for institutions it already supervises (Art 130(2) pkt 1 lit. b), and KNF is not the MiCA authority for CASPs (KNF, 23 June 2026).

The current consolidated text of the AML Act of 1 March 2018 is Dz.U. 2025 poz. 644 (Marshal of the Sejm's notice); earlier consolidated texts are Dz.U. 2019 poz. 1115, 2020 poz. 971, 2021 poz. 1132, 2022 poz. 593 and 2023 poz. 1124.

Under Art 2(1) pkt 12 of Poland's AML Act of 1 March 2018 (consolidated Dz.U. 2025 poz. 644), businesses providing virtual-currency exchange, intermediation or account-keeping (custody) services are obliged institutions, and Art 129m makes that activity conditional on entry in the register of virtual-currency activity; the register has accepted no new entries since 30 December 2024.

Under Art 129n(1) of Poland's AML Act (consolidated Dz.U. 2025 poz. 644), virtual-currency activity may be carried on by a natural person, a legal person or an organisational unit without legal personality.

Art 129n of Poland's AML Act (consolidated Dz.U. 2025 poz. 644) bars from virtual-currency activity anyone finally convicted of listed offences (incl. offences against property, economic trading and money circulation, or intentional fiscal offences); the clean-record rule extends to partners, management-board members, persons directing the activity and beneficial owners.

Under Art 129o of Poland's AML Act (consolidated Dz.U. 2025 poz. 644), natural persons carrying on virtual-currency activity must have knowledge or experience in it, deemed met by completing a training course on its legal or practical aspects or by at least one year of documented work in that activity.

The competent organ for Poland's register of virtual-currency activity is the minister responsible for public finance (AML Act Art 129p), who by ordinance of 25 October 2021 (Dz.U. 2021 poz. 1964) designated the Director of the Revenue Administration Regional Office (IAS) in Katowice to keep the register.

Entry in Poland's register of virtual-currency activity (AML Act Arts 129m–129z) is a regulated-activity entry, not a prudential licence: its statutory conditions are a clean criminal record (Art 129n) and knowledge or experience (Art 129o), the register has taken no new entries since 30 December 2024, and IAS Katowice states that entry does not authorise acting as a MiCA crypto-asset service provider.

Poland's AML Act of 1 March 2018 (consolidated Dz.U. 2025 poz. 644) contains no client-asset segregation rule for virtual-currency custodians; segregation is required of crypto-asset service providers by MiCA Art 75(7), applicable since 30 December 2024, but no CASP is authorised in Poland (ESMA interim register, last update 31 Aug 2026), so the rule reaches Polish clients only through CASPs authorised in other member states.

Poland's AML Act treats keeping virtual-currency accounts (Art 2(2) pkt 17(e)) only as an AML-obliged activity (Art 2(1) pkt 12(d)) and sets register conditions limited to a clean criminal record and knowledge or experience (Arts 129n–129o), with no custody or prudential standards for custodians.

The KNF was to be Poland's MiCA competent authority under the Act on the crypto-asset market, but that act was vetoed three times (1 Dec 2025, 12 Feb 2026, 11 Jun 2026) and as of 14 October 2026 no Polish authority is designated for crypto-asset service providers; the KNF is competent only for e-money-token issuers (KNF communiqué updated 23 Jun 2026).

MiCA Title III (asset-referenced tokens) and Title IV (e-money tokens) have applied directly in Poland since 30 June 2024 (Regulation (EU) 2023/1114 Art 149(3)); in Poland the KNF is competent only for e-money-token issuers, and no authority is designated for asset-referenced-token issuers (KNF communiqué updated 23 Jun 2026).

Under MiCA Art 48(1) only an issuer authorised as a credit institution or electronic money institution that has notified a crypto-asset white paper to its competent authority may offer an e-money token; in Poland the KNF is that authority for EMT issuers (communiqué updated 23 Jun 2026), and ESMA's interim register lists one Poland-home EMT issuer, a KNF-supervised e-money institution.

MiCA Art 16(1) requires an asset-referenced-token issuer to be authorised by the competent authority of its home member state (or be a credit institution under Art 17), but Poland has designated no authority for ART issuers — the KNF's MiCA competence covers only e-money-token issuers (communiqué updated 23 Jun 2026) — so no ART issuer can be authorised in Poland.

MiCA Art 18 requires an asset-referenced-token issuer to apply to its home-state competent authority with, among other items, a crypto-asset white paper (Art 18(2)(k)) and a description of its governance arrangements (Art 18(2)(f)); in Poland no authority is designated to receive such applications (KNF communiqué updated 23 Jun 2026).

Poland's Act of 1 March 2018 on counteracting money laundering and terrorist financing (Dz.U. 2018 poz. 723, in force 13 July 2018) transposes Directive (EU) 2015/849; the Act of 30 March 2021 (Dz.U. 2021 poz. 815) amended it to transpose Directive (EU) 2018/843 (AMLD5).

Art 2(1) pkt 12 of Poland's AML Act makes obliged institutions of businesses exchanging virtual currencies for means of payment, exchanging between virtual currencies, intermediating in such exchange, or keeping virtual-currency accounts; the Act's virtual-currency definition excludes electronic money and financial instruments (Art 2(2) pkt 26).

Poland's register of virtual-currency activity, kept by the Director of IAS Katowice for the Minister of Finance (Dz.U. 2021 poz. 1964), has accepted no new entries since 30 December 2024; IAS Katowice publishes an archived version as at 2 July 2026 and states that entry does not authorise acting as a crypto-asset service provider.

Poland's register of virtual-currency activity is published by IAS Katowice at gov.pl/web/ias-katowice/rejestr-dzialalnosci-w-zakresie-walut-wirtualnych; the older gov.pl/web/kas register address now redirects to the gov.pl homepage.

The KNF supervises Poland's financial market but has not been designated as MiCA competent authority for crypto-asset service providers or asset-referenced-token issuers; its MiCA competence is limited to e-money-token issuers (KNF communiqué updated 23 Jun 2026), because the Act on the crypto-asset market was vetoed and each override vote failed (5 Dec 2025, 17 Apr 2026, 4 Sep 2026).

Poland's national crypto regime is limited to the AML Act of 1 March 2018 (consolidated Dz.U. 2025 poz. 644); MiCA has applied directly since 30 December 2024, but Poland has no implementing act or competent authority for CASPs, and the Ministry of Finance stated on 9 June 2026 that no crypto-asset service authorisation can currently be obtained in Poland.

Poland's Act on the crypto-asset market, meant to implement MiCA, passed the Sejm three times (26 Sep 2025, 18 Dec 2025, 15 May 2026) and was vetoed each time (1 Dec 2025, 12 Feb 2026, 11 Jun 2026), with override votes failing; a deputies' bill (process 3173) entered the Sejm on 18 Jun 2026 with no further stage as of 14 October 2026.

The KNF is Poland's financial-market supervisor but does not supervise virtual-currency firms for AML: Art 130(1) of the AML Act gives control of obliged institutions to the General Inspector of Financial Information (GIIF), and the KNF controls only obliged institutions it supervises (Art 130(2) pkt 1 lit. b).

By ordinance of 25 October 2021 (Dz.U. 2021 poz. 1964) the Minister of Finance delegated to the Director of IAS Katowice the keeping of the register of virtual-currency activity, deciding applications, updating and deleting entries, and imposing the Art 153b AML Act fines on unregistered firms.

The General Inspector of Financial Information (GIIF) is Poland's financial intelligence unit under the AML Act (Art 12(5)); obliged institutions, including virtual-currency firms, must notify the GIIF of circumstances indicating suspected money laundering or terrorist financing within 2 working days of confirming the suspicion (Art 74).

Poland's AML Act defines virtual currency (Art 2(2) pkt 26) as a digital representation of value that is not legal tender, international unit of account, electronic money, financial instrument, bill of exchange or cheque, and is exchangeable for legal tender and accepted as a medium of exchange.

Polish virtual-currency firms (AML Act Art 2(1) pkt 12) must apply customer due diligence when establishing business relationships and for occasional transactions in virtual currency worth EUR 1,000 or more (Art 35(1) pkt 2 lit. c), and must notify the GIIF of suspected money laundering or terrorist financing (Art 74).

Buying, selling and holding virtual currencies is not prohibited in Poland; the AML Act regulates only businesses providing virtual-currency exchange, intermediation or account-keeping services (Art 2(1) pkt 12).

AML/CFT compliance of registered Polish virtual-currency firms is controlled by the General Inspector of Financial Information (GIIF) under Art 130(1) of the AML Act, not by the KNF, whose control extends only to obliged institutions it otherwise supervises (Art 130(2) pkt 1 lit. b).

Customer due diligence under Poland's AML Act (Art 34(1)) comprises identifying and verifying the customer, identifying the beneficial owner and verifying their identity, assessing the purpose of the business relationship, and ongoing monitoring including transaction analysis and, where justified, source-of-funds checks.

Carrying on virtual-currency activity in Poland without entry in the register is subject to a fine of up to PLN 100,000 (AML Act Art 153b), imposed by the Director of IAS Katowice under the ordinance of 25 October 2021 (Dz.U. 2021 poz. 1964).

Firms in Poland's virtual-currency register could not obtain MiCA CASP authorisation from the KNF or any Polish authority, because none is designated; the transitional period for them ended on 1 July 2026 (KNF communiqué updated 23 Jun 2026), and the Ministry of Finance confirmed on 9 June 2026 that no such authorisation is currently obtainable in Poland.

Poland's primary crypto AML statute is the Act of 1 March 2018 on counteracting money laundering and terrorist financing (Dz.U. 2018 poz. 723); its current consolidated text is Dz.U. 2025 poz. 644 (Marshal of the Sejm notice of 9 May 2025).

Poland's AML Act covered virtual-currency exchange, intermediation and account-keeping businesses from its original 2018 text (Art 2(1) pkt 12); the AMLD5 amendment, the Act of 30 March 2021 (Dz.U. 2021 poz. 815), added the register of virtual-currency activity and its entry conditions (Arts 129m–129z).

Virtual-currency firms have been obliged institutions under Poland's AML Act since it entered into force on 13 July 2018; the register of virtual-currency activity (Arts 129m–129z) took effect on 31 October 2021 under the Act of 30 March 2021 (Dz.U. 2021 poz. 815), and crypto travel-rule obligations apply only since 30 December 2024 under Regulation (EU) 2023/1113.

Since 30 December 2024 Regulation (EU) 2023/1113 applies directly in Poland (IAS Katowice communiqué), so crypto-asset transfers between service providers must carry originator and beneficiary information regardless of amount, for domestic and cross-border transfers alike.

There is no reduced-information tier for crypto-asset transfers up to EUR 1,000 under Regulation (EU) 2023/1113, which applies directly in Poland; the only EUR 1,000 rule for crypto is that a provider must verify whether a self-hosted address is owned or controlled by its client for transfers exceeding EUR 1,000.

Poland's EUR 1,000 crypto threshold is a customer-due-diligence trigger, not a travel-rule tier: virtual-currency firms must apply CDD to occasional transactions in virtual currency worth EUR 1,000 or more (AML Act Art 35(1) pkt 2 lit. c), while the TFR requires full originator information on every crypto transfer.

Keeping virtual-currency accounts — electronic sets of identifying data that let holders use and exchange virtual-currency units — is an AML-obliged activity in Poland (AML Act Art 2(1) pkt 12(d) with Art 2(2) pkt 17(e)).

Administrative penalties under Poland's AML Act include a ban, for no longer than one year, on the person responsible for an obliged institution's breach holding a managerial post (Art 150(1) pkt 4).

Administrative penalties under Poland's AML Act include publishing information on the obliged institution and the scope of its breach in the Public Information Bulletin of the Ministry of Finance (Art 150(1) pkt 1).

Administrative penalties under Poland's AML Act include revoking a licence or permit or deleting the institution from the register of regulated activity (Art 150(1) pkt 3), which for virtual-currency firms means deletion from the register of virtual-currency activity.

Fines on Polish virtual-currency firms under the AML Act reach up to twice the benefit gained or loss avoided, or up to the equivalent of EUR 1,000,000 where that amount cannot be set (Art 150(2)); the higher PLN 20,868,500 / EUR 5,000,000 / 10%-of-turnover caps (Art 150(3)) do not apply to Art 2(1) pkt 12 firms.

Since 1 July 2026 crypto-asset services may be offered to clients in Poland only by CASPs authorised in another EU member state: ESMA's interim register (last update 31 Aug 2026) lists no CASP with Poland as home state and 180 of 370 CASPs notifying cross-border services into Poland.

The KNF is not the registration or AML supervisory authority for Polish virtual-currency firms: the register is kept by the Director of IAS Katowice for the Minister of Finance (AML Act Art 129p; Dz.U. 2021 poz. 1964) and AML control lies with the GIIF (Art 130(1)).

Polish virtual-currency firms never registered with the KNF: entry was in the register kept by IAS Katowice (AML Act Art 129m; Dz.U. 2021 poz. 1964), which closed to new entries on 30 December 2024, and entry there never amounted to a licence.

No crypto-asset service provider is authorised in Poland: ESMA's interim MiCA register (CASPS.csv, last update 31 Aug 2026) lists none of 370 CASPs with Poland as home member state.

MiCA applies directly in Poland, but the national implementing act was first vetoed on 1 December 2025, not by Q2 2024; after vetoes on 1 Dec 2025, 12 Feb 2026 and 11 Jun 2026 and three failed overrides, no implementing act is in force as of 14 October 2026.

KNF issued no transitional measures for VASPs: the MiCA Art 143(3) transition applied directly and ended on 1 July 2026, and KNF states it cannot extend it; registered VASPs have had no right to provide crypto-asset services in Poland since then.

The President vetoed the Act on the crypto-asset market on 1 December 2025, 12 February 2026 and 11 June 2026 and the Sejm failed to override each veto (5 Dec 2025, 17 Apr 2026, 4 Sep 2026), so no Polish MiCA competent authority exists for CASPs and none can be authorised in Poland.

Under Arts 117–118 of Poland's AML Act (Dz.U. 2025 poz. 644), obliged institutions, including virtual-currency service providers (Art 2(1) pkt 12), must apply special restrictive measures (asset freezing and a ban on making assets available) to persons and entities on the UN Security Council terrorism lists announced by the General Inspector of Financial Information (GIIF) and on GIIF's own list; EU sanctions regulations apply directly alongside.

Under Art 119 of Poland's AML Act, obliged institutions, including virtual-currency service providers, freeze the assets of persons and entities on the lists in Art 118 without prior notice to them and pass all related information to the General Inspector of Financial Information (GIIF) without delay, within 2 working days of the freeze.

Polish penalties for failing to apply EU asset freezes under Regulations 765/2006 (Belarus) and 269/2014 (Ukraine) to persons on Poland's national list are set by the Act of 13 April 2022 on special solutions to counter support for aggression against Ukraine, not the AML Act: a head of a customs and tax office may impose a fine of up to PLN 20,000,000 (Art 6).

Under Art 150(2) of Poland's AML Act, a fine on a virtual-currency service provider may reach twice the benefit gained or loss avoided through the breach or, where that amount is not determinable, the equivalent of EUR 1,000,000; the higher caps of EUR 5,000,000 or 10% of turnover in Art 150(3) do not apply to Art 2(1) pkt 12 entities.

Under Art 156 of Poland's AML Act, a person acting for an obliged institution, including a virtual-currency service provider, who fails to notify the General Inspector of Financial Information of a suspected money-laundering or terrorist-financing offence, or gives it false data, faces 3 months to 5 years' imprisonment (a fine if unintentional).

Poland's Act of 1 March 2018 on counteracting money laundering and terrorist financing (consolidated text Dz.U. 2025 poz. 644) implements Directive (EU) 2015/849 as amended (4AMLD and 5AMLD) and lists providers of virtual-currency exchange, intermediation and account services as obliged institutions in Art 2(1) pkt 12.

Polish obliged institutions, including virtual-currency service providers, must notify the General Inspector of Financial Information (GIIF) of circumstances suggesting money laundering or terrorist financing without delay and within 2 working days of confirming the suspicion (AML Act Art 74), and must report assets frozen under Art 119 to GIIF within 2 working days.