Poland Compliance Report

Generated 2026-10-23

Partially Regulated

Regulatory Overview

Regulatory Status: Some rules exist but significant gaps; draft legislation or limited guidance
Key Regulator(s): Public Information Bulletin of the Ministry of Finance, Authority for Anti-Money Laundering and Countering the Financing of Terrorism, European Parliament and of the Council
Primary Legislation: Poland's AML Act is the Act of 1 March 2018 on counteracting money laundering an, Under Art 2(1) pkt 12 of the AML Act of 1 March 2018 (Dz.U. 2025 poz. 644), obli, The AML Act of 1 March 2018 covers businesses keeping virtual-currency accounts, Act on financial market supervision, Art 1(2, Poland has no MiCA implementing act as of 14 October 2026: the Act on the crypto, Virtual-currency activity under the AML Act of 1 March 2018 may be carried on by, The AML Act of 1 March 2018 sets no minimum capital requirement for entry in the, The AML Act (Art 129n) requires that a natural person running virtual-currency a, AML Act Art 129r(1, AML Act Arts 129p–129q, AML Act Art 129r, The AML Act fixed the processing time: the register organ (Director of IAS Katow, AML Act Art 74, AML Act Art 130(1, The current consolidated text of the AML Act of 1 March 2018 is Dz.U. 2025 poz.
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: Under Poland's PIT Act, selling virtual currency for legal tender (PLN or a foreign currency) is a paid disposal of virtual currency (Art 17(1f)), and the proceeds are capital revenue under Art 17(1) pkt 11 taxed at 19% under Art 30b(1a).. Under Art 17(1f) of Poland's PIT Act, exchanging virtual currency for goods, services or property rights other than virtual currency, or using it to settle other obligations, is a taxable paid disposal of virtual currency.. Exchanging one virtual currency for another is not a taxable event in Poland: Art 17(1f) of the PIT Act defines a paid disposal as an exchange for legal tender, goods, services or property rights other than virtual currency, and expenses linked to a crypto-to-crypto exchange are not deductible costs (Art 23(1) pkt 38d).. Income derived from activities such as mining, staking, or airdrops may be subject to different income tax rules (see "Income Tax on Crypto" below).. Income of Polish individuals from the paid disposal of virtual currency is taxed at a flat 19% (PIT Act Art 30b(1a)); the income is the difference between that year's disposal revenue and the costs determined under Art 22(14)–(16) (Art 30b(1b)).

Key Facts

aml 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. Ustawa z dnia 1 marca 2018 r. o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu (Act on Counteracting Money Laundering and Financing of Terrorism): URL (Polish AML Act on ISAP – Official Legislative System): https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20180000723
custody State after use of alcohol in Poland is defined by a blood alcohol content (BAC) from 0.2‰ to 0.5‰, or breath alcohol from 0.1 mg to 0.25 mg per 1 dm³. Polish law distinguishes between the “state after use of alcohol” and the “state of intoxication,” each with different procedures and sanctions depending on the result and evidence Polish Criminal Code §178a defines intoxication thresholds. State of intoxication is defined by a BAC above 0.5‰, or breath alcohol above 0.25 mg per 1 dm³. This classification triggers more severe legal consequences under Polish law [Citation from Polish Criminal Code §178a]. Driving a motor vehicle in a state of intoxication is governed by Article 178a of the Polish Criminal Code, which imposes penalties based on severity and prior offenses Article 178a specifies imprisonment up to 2 years for first offenses and up to 5 years for repeat or aggravated cases. Shared custody is a legal arrangement where a child alternates living with each parent according to a court‑approved schedule. While not explicitly defined in Poland’s Family and Guardianship Code, it is increasingly recognized through jurisprudence Shared custody is acknowledged when parents demonstrate cooperative ability and the child's best interests are served. Joint custody is the preferred option under Polish law, promoting continuous parental involvement as long as it serves the child’s best interest Polish courts prioritize joint arrangements when parents can cooperate effectively and geographical constraints are manageable. 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. As a UK citizen, rights in Poland are shaped by differing legal frameworks; understanding these differences is crucial for navigating custody disputes effectively Guidance on UK citizens’ rights emphasizes procedural awareness and legal representation.
enforcement Legal Basis: Article 29 of the Treaty on European Union (TEU) and Article 215 of the Treaty on the Functioning of the European Union (TFEU). Legal Basis: UN Security Council Resolutions, implemented via EU Regulations.
general Transferable securities: Such as shares in companies, bonds, or other forms of securitised debt, and any other negotiable instruments which give the right to acquire or dispose of any such transferable securities by subscription or exchange or which entail a cash settlement determined by reference to transferable securities, currencies, interest rates or yields, commodities or other indices or measures. Money-market instruments: Generally short-term debt instruments. Units in collective investment undertakings: Shares or units in investment funds. Options, futures, swaps, forward rate agreements, and any other derivative contracts relating to securities, currencies, interest rates or yields, emission allowances or other derivative instruments, financial indices or financial measures which may be settled physically or in cash. Derivatives relating to commodities that can be physically settled. Financial contracts for differences. Emission allowances consisting of any units recognised for compliance with the requirements of Directive 2003/87/EC (EU ETS allowances) which are transferable. Security Tokens: Tokens specifically designed to represent traditional securities (like shares, bonds, units in investment funds, or other equity/debt instruments) are considered financial instruments. These are the clearest cases. For example, a token that represents fractional ownership of a company's shares or a tokenized bond.
licensing 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. GIIF (Ministry of Finance page regarding Virtual Currencies - in Polish): https://www.gov.pl/web/finanse/dzialalnosc-w-zakresie-walut-wirtualnych (This page provides information on the register and requirements). 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. Crypto-to-crypto payments or accepting crypto as payment: If a "payment processor" facilitates payments directly in virtual assets, converts virtual assets for payment purposes, or provides services that involve the transfer or exchange of virtual assets, they would likely fall under the definitions of "virtual currency exchange service" or "virtual currency safekeeping wallet service" (if they hold keys) and thus require registration under the AML Act. If they merely provide technical infrastructure without ever controlling funds or keys, it might be more ambiguous, but a conservative interpretation would lean towards registration if they are integral to the crypto value transfer. 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.
sanctions Legal Basis: Article 29 of the Treaty on European Union (TEU) and Article 215 of the Treaty on the Functioning of the European Union (TFEU). Asset freezes: Prohibiting the making available of funds and economic resources (including virtual assets) to designated persons, entities, or bodies. Travel bans: For designated individuals. Trade restrictions: On certain goods and technologies (e.g., dual-use items, arms embargoes), and increasingly, services. Financial restrictions: Prohibitions on investment, lending, or providing financial services to specific entities or sectors. Virtual Assets: EU sanctions explicitly cover virtual assets within the definition of "funds" or "economic resources." For example, the EU's restrictive measures against Russia, Belarus, and other regimes have been updated to explicitly include crypto-assets within the scope of asset freezes and other financial restrictions. Example: Council Regulation (EU) 2022/328 (and subsequent amendments) concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine explicitly includes "crypto-assets" in the definition of "transferable securities" and "funds," thereby subjecting them to the asset freeze and other financial restrictions. 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.
securities Crypto-asset activity is not prohibited in Poland, but since 1 July 2026 crypto-asset services may be offered to Polish clients only by CASPs authorised in another EU member state: Poland has no MiCA competent authority for CASPs and ESMA's register lists no Poland-authorised CASP, while 180 of 370 listed CASPs notify services into Poland. The primary regulatory authorities include the Polish Financial Supervision Authority (KNF) for financial market oversight and the Dyrektor Krajowej Informacji Skarbowej (Director of the National Tax Information Office) for tax rulings 62023CC0018 Poland has implemented EU directives including the UCITS Directive and AIFMD framework, with the Polish Law of 27 May 2004 on investment funds and management of alternative investment funds governing fund structures 62023CC0018 A licensing regime exists for investment fund management, but digital asset-specific securities licensing is still being shaped by ongoing EU-level regulatory developments Prudential requirements of investment firms | EUR-Lex The practical reality is that Poland relies heavily on EU harmonized rules, and entities seeking to operate in the crypto-securities space must navigate both Polish national law and directly applicable EU regulations The Polish Legal System KNF (Komisja Nadzoru Finansowego) supervises Poland's capital market — including under the Act on trading in financial instruments, the Public Offering Act and the Investment Funds Act — as well as banks, insurers, pension funds and payment and e-money institutions (Act on financial market supervision, Art 1(2), Dz.U. 2026 poz. 935). The Ustawa z dnia 15 lutego 1992 r. o podatku dochodowym od osób prawnych (Law of 15 February 1992 on corporation tax), as amended by the Ustawa z 10 lutego 2017 r., is the core corporate income tax law governing tax exemptions for investment funds 62023CC0018 The Ustawa z dnia 27 maja 2004 r. o funduszach inwestycyjnych i zarządzaniu alternatywnymi funduszami inwestycyjnymi (Law of 27 May 2004 on investment funds and the management of alternative investment funds), as amended by the Law of 31 March 2016, governs investment fund establishment and management 62023CC0018
status 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 competent authority exists for CASPs, ART issuers or crypto-asset white papers (KNF covers only EMT issuers), and the pre-MiCA virtual-currency register has been closed to new entries since 30 December 2024. Potential for regulatory arbitrage: Entities may seek to operate in jurisdictions with more favorable regulatory conditions, leading to a fragmented market landscape. Need for harmonization with EU directives: As Poland aligns its regulations with EU-wide directives, such as the 5AMLD, there is a risk of delayed implementation or inconsistent application across member states. Consumer protection and market stability: The evolving regulatory environment may impact consumer confidence and market stability, necessitating balanced approaches that protect investors while fostering innovation. Foreigners - Check case status An Overview of Polish Law - GlobaLex Acquiring and renewing a driving licence Poland - Licensing Requirements for Professional Services
tax Under Poland's PIT Act, selling virtual currency for legal tender (PLN or a foreign currency) is a paid disposal of virtual currency (Art 17(1f)), and the proceeds are capital revenue under Art 17(1) pkt 11 taxed at 19% under Art 30b(1a). Under Art 17(1f) of Poland's PIT Act, exchanging virtual currency for goods, services or property rights other than virtual currency, or using it to settle other obligations, is a taxable paid disposal of virtual currency. Exchanging one virtual currency for another is not a taxable event in Poland: Art 17(1f) of the PIT Act defines a paid disposal as an exchange for legal tender, goods, services or property rights other than virtual currency, and expenses linked to a crypto-to-crypto exchange are not deductible costs (Art 23(1) pkt 38d). Income derived from activities such as mining, staking, or airdrops may be subject to different income tax rules (see "Income Tax on Crypto" below). Income of Polish individuals from the paid disposal of virtual currency is taxed at a flat 19% (PIT Act Art 30b(1a)); the income is the difference between that year's disposal revenue and the costs determined under Art 22(14)–(16) (Art 30b(1b)). Revenue from the paid disposal of virtual currency under Poland's PIT Act is revenue from exchanging virtual currency for legal tender, goods, services or property rights other than virtual currency, or from settling other obligations with it; virtual currency received in exchange for another virtual currency is not revenue (Art 17(1f)). Tax-Deductible Costs: This is a key and favorable aspect of Polish crypto taxation. Tax-deductible costs include all documented expenses related to the acquisition of virtual currencies. This can include: Expenses on equipment for mining virtual currency and on the electricity used to run it are not deductible costs of the paid disposal of virtual currency under Poland's PIT Act; only documented expenses directly incurred to acquire virtual currency and costs of disposing of it count (Art 22(14)).
travel rule The crypto travel rule in Poland is Regulation (EU) 2023/1113 (TFR), which applies directly in Poland from 30 December 2024 as confirmed by the Director of the Revenue Administration Regional Office in Katowice; the AMLR, Regulation (EU) 2024/1624, is a separate instrument that applies only from 10 July 2027. Crypto travel-rule obligations in Poland come from Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, which applies directly without national transposition; the Director of the Revenue Administration Regional Office in Katowice confirmed it applies in Poland from 30 December 2024. The new EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), established by Regulation (EU) 2024/1620, will directly supervise certain high-risk CASPs operating in Poland and other member states, with its seat in Frankfurt am Main, Germany Regulation - EU - 2024/1620 - EN - AMLAR - EUR-Lex Customer due diligence and suspicious-transaction reporting by Polish virtual-currency service providers are governed today by the AML Act of 1 March 2018 (Dz.U. 2025 poz. 644), which covers them as obliged institutions under Art 2(1) pkt 12; Regulation (EU) 2024/1624 (AMLR) replaces that directive-based framework only from 10 July 2027. The practical reality is that Poland's crypto travel-rule framework is now determined at the EU level through the AMLR package, with the European Commission and AMLA playing central roles in supervision and enforcement, while national authorities such as the Polish Financial Supervision Authority (KNF) retain responsibilities for other obliged entities not directly supervised by AMLA Regulation - EU - 2024/1620 - EN - AMLAR - EUR-Lex The primary AML/CFT instrument in Poland on 14 October 2026 is the Act of 1 March 2018 on counteracting money laundering and terrorist financing (consolidated text Dz.U. 2025 poz. 644); Regulation (EU) 2024/1624 (AMLR) of 31 May 2024, published in the Official Journal on 19 June 2024, applies only from 10 July 2027. Regulation (EU) 2024/1624 (AMLR) will be directly applicable in Poland without national implementing legislation, but it applies only from 10 July 2027; until then Polish AML/CFT obligations for virtual-currency service providers come from the AML Act of 1 March 2018 (Dz.U. 2025 poz. 644). Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets (the Transfer of Funds Regulation or TFR) is the key EU legal act governing travel-rule requirements for crypto-asset transfers, applying directly in Poland Regulation - 2023/1113 - EN - EUR-Lex - European Union

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-10-14. View full profile