Poland has no MiCA supervisor yet: what now?

On 8 November 2026 Poland still had no law designating a supervisor for MiCA. MiCA's transitional period ended on 1 July 2026, but the Polish act to implement the regulation has stalled three times on a veto by President Karol Nawrocki. In the ESMA register of 5 November, none of the 397 entries has Poland as home country. Providers from other EU countries may serve Poland, and many do: 188 entries list Poland as a country where the service is provided.

Poland and MiCA in short

• 1 July 2026: the end of the transitional period under Article 143(3) of MiCA. Polish providers that worked under the old national register lost their basis. The KNF says the period cannot be extended by a law or by a decision of the KNF itself.
• No supervisor: according to the KNF (as of 23 June 2026), no national authority in Poland has been designated to supervise MiCA activity, except for issuers of e-money tokens.
• The law: on 15 May 2026 the Sejm passed a law on the crypto market; the president sent it back on 11 June (veto). On 4 September the Sejm did not reach the required majority.
• The register: of the 397 entries in the ESMA file (5 November 2026), none has Poland as home country. Germany has 125, Portugal 1.
• Cross-border: providers with an authorisation or notification in another member state may operate in Poland, according to the KNF itself.
• What is still pending: a proposal by Polish members of parliament (print 3173, 17 June) is still at the first stage in the Sejm file. On 8 September the president announced a second proposal of his own.

What happened since May

The dates below come from the public Sejm file (api.sejm.gov.pl), unless stated otherwise.

It was the third veto on a crypto law: earlier vetoes followed on 1 December 2025 and 12 February 2026 (requests in Sejm prints 2048 and 2267). According to GazetaPrawna, the president's chancellery says the second presidential proposal is almost identical to the first one of 6 May 2026 (print 2528).

The arithmetic of 4 September

Overriding a veto takes a majority of three fifths of the members present. According to GazetaPrawna, 442 were present, and three fifths of 442 is 265.2, so 266 votes. There were 241 votes in favour, 198 against and 3 abstentions. That is 266 minus 241 = 25 votes short.

What the KNF says

The KNF has explained the consequences for investors and companies in two documents. This is what they say.

• No designated authority. As long as the law is not in place, no Polish authority has been designated for crypto-asset service providers and issuers of crypto-assets other than e-money tokens. The KNF does have competence for issuers of e-money tokens.
• No Polish authorisation possible. An authorisation procedure in Poland can only begin once the law has designated a competent authority.
• The old Polish register gives nothing after 1 July. The KNF refers to a notice from the tax authority in Katowice of 19 June 2026: an entry in the Polish register of virtual currencies is not an authorisation under MiCA, and after 1 July it no longer gives the right to carry out that activity, in Poland or elsewhere.
• Cross-border work is possible. A provider authorised in another country may operate in Poland under Article 65 of MiCA: the supervisor of the home country forwards the notification, and the provider may start on the day of confirmation, at the latest on the fifteenth calendar day after the notification.

What the ESMA register shows

The register is a csv file that ESMA publishes itself (as of 5 November 2026: 397 entries, 394 legal entities). We counted the file ourselves.

This only says what the official list shows: it contains no provider with Poland as home country. An empty place in a register has more than one explanation, so we make no statement about individual providers.

The other side is the list of countries where the services are offered. In the file, 188 of the 397 entries (187 legal entities) list Poland as a country where the service is provided. For a Polish user, the offer with a MiCA authorisation or notification therefore comes from providers in other countries.

What ESMA says about providers without authorisation

On 23 June 2026 ESMA published a statement ahead of the end of the transitional period. It says that providers without authorisation must wind down their EU activity in an orderly way. They may no longer take on new clients and must stop marketing. Services must be limited to selling or transferring crypto-assets, redistributing holdings or closing positions. Custody of client assets is only allowed for as long as needed for an orderly exit. They must tell clients clearly and repeatedly what the plan is, with a final date after which remaining positions are closed automatically.

ESMA also warns clients: anyone who uses a provider without a MiCA authorisation has no right to the MiCA safeguards, including protection of client assets. ESMA advises checking in the ESMA register whether your provider has an authorisation, and if not, acting quickly: transfer to an authorised provider or to your own wallet.

This applies across the whole EU and is separate from the Polish legislative process. The KNF refers to this statement in its notice of 23 June.

What does this mean for you as a European investor?

Do you live in Poland? Check the provider you use in the MiCA register, and see whether Poland is on the list of countries where the service may be provided. If the provider is authorised in another country, it falls under the supervisor of that country: the register names it for each entry. A Polish supervisor for MiCA matters does not exist at the moment, so you cannot go there with a MiCA question about a provider. If your provider is not in the register, follow the ESMA advice above.

Do you hold assets with a provider from the Polish register of virtual currencies? Then what the KNF and the tax authority in Katowice said applies: after 1 July that entry is no longer an authorisation. Read your provider's messages carefully and keep them.

Self-custody. Anyone who uses their own wallet does not have this problem; see our explainer on choosing a wallet.

Tax. The bills are about supervision, not tax. For tax per country, see crypto tax in Europe.

Do you live in another EU country? Nothing changes for you. The same register check applies everywhere; see also our piece MiCA register: 397 entries, 16 more from Germany.

What is not certain yet

• The KNF's current position. The notice we read was updated on 23 June 2026. We found no newer notice on a designated authority.
• The president's second proposal. According to GazetaPrawna it was filed on 8 September. In the list of Sejm prints (read on 8 November) we did not find it under the keyword kryptoaktywa. Whether it already has a print number, we cannot say.
• The proposal by the members of parliament (print 3173). The Sejm file only shows the filing on 18 June. That is the state of the Sejm website; it may lag behind.
• The Official Journal. We did not search the Dziennik Ustaw. The Sejm file of the law of 15 May ends with "not passed again"; we found no other new law.
• Vote counts. The figures for 4 September come from GazetaPrawna; the Sejm file only confirms that the law was not passed again.

This article is not investment advice. Crypto can lose a lot of value and you can lose your entire stake.

Frequently asked questions

Is crypto banned in Poland without a MiCA supervisor?

That is not stated in the sources we read. The rules concern the companies that provide services: Polish providers cannot get a MiCA authorisation at the moment, and providers from other EU countries may work there with an authorisation or notification.

How do I check whether my exchange has a MiCA authorisation?

Look up the provider in the ESMA register, or in our register of MiCA authorisations. Check the official name, the supervisor and whether Poland or your country is among the countries where the service is provided.

Why is Poland not on the list of home countries?

Because Poland has not yet designated an authority that can grant authorisations. According to the KNF, a Polish procedure can only begin once the law does so.

What happens to my crypto if my provider stops?

ESMA expects providers without authorisation to inform their clients clearly, with a final date after which remaining positions are closed. Move your assets in good time or transfer them to an authorised provider or your own wallet.

When will there be a Polish law?

That cannot be said. There are two proposals, but the sources we read do not show a date for a vote.

Sources

Read on 8 November 2026.

• KNF, Information on the end of the transitional period for crypto-asset service providers (updated 23 June 2026).
• UKNF, Position on the absence of a designated supervisor for the crypto market (pdf, undated in the document).
• ESMA, Public statement ESMA75-113276571-1710 (23 June 2026).
• ESMA, interim MiCA register, csv with providers (as of 5 November 2026, MiCA page).
• Sejm, process 2363, law on the crypto market and print 3173 (read 8 November 2026).
• GazetaPrawna, Wielki spór o kryptowaluty wraca do Sejmu (8 September 2026).