Poland’s cryptocurrency market has, for years, moved faster than the law around it. 2026 marks a turning point: the EU-wide transitional period under the MiCA regulation has formally ended, but the Polish law implementing it still hasn’t come into force. Here’s what that means in practice for investors and for businesses providing crypto-asset services.

In Poland, cryptocurrencies are not recognized as legal tender, but they are not prohibited either. Under long-standing practice of the tax authorities, they are treated as property rights. That classification directly drives how gains and losses are taxed (see the tax section below, and our dedicated, more detailed guide to cryptocurrency taxation).

The lack of a single, comprehensive national act defining crypto-assets has long been the weak point of the Polish system. 2026 is supposed to change that, but as explained below, the legislative process is still not finished.

The VASP register and AML obligations

The key legislative act regulating crypto-related activity in Poland has been the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing (Journal of Laws 2018, item 723, the “AML Act”). It requires registration in the register of virtual currency activities maintained by the General Inspector of Financial Information (GIIF), commonly referred to as the VASP (Virtual Asset Service Provider) register or “license”. Registration covers entities operating crypto accounts and exchanges, fiat-to-crypto and crypto-to-fiat exchange services, and intermediation in those activities.

Important for 2026: the VASP register alone is no longer a sufficient basis for lawfully providing crypto-asset services. The EU transitional period under MiCA for entities that were operating lawfully before December 30, 2024, ended on July 1, 2026. From that date, crypto-asset services should, in principle, only be provided by entities holding a CASP (Crypto-Asset Service Provider) authorization issued under MiCA.

MiCA: where implementation in Poland stands in 2026

The MiCA regulation (EU) 2023/1114 has applied at the EU level since June 30, 2024 (for asset-referenced tokens and e-money tokens) and since December 30, 2024 (for the remaining provisions, including rules for crypto-asset service providers). The problem is that MiCA requires each member state to designate a national supervisory authority (in Poland’s case, this is meant to be the Financial Supervision Authority, KNF) and to pass a national crypto-asset market act that actually lets firms apply for a CASP authorization.

As of the time of writing (July 2026), that Polish act still has not entered into force. The Council of Ministers adopted a draft act on the crypto-asset market on May 8, 2026, following earlier legislative delays, but the process in the Sejm and Senate has not yet concluded with a final, binding law. The result is a kind of regulatory gap: the EU transitional period for the existing VASP register has already ended, while the national CASP licensing mechanism is not yet fully operational.

This situation is highly fluid and could change overnight once the act is finally passed and published in the Journal of Laws. If you run or plan to run a crypto-asset business (exchange, wallet provider, exchange service), check the act’s current status before making business decisions, ideally with a legal advisor.

Cryptocurrency taxation: a quick recap

The tax rules have been stable since the 2019 amendment and are unaffected by the MiCA turbulence described above:

  • income from the disposal of cryptocurrencies is income from money capital, taxed at a flat 19% rate (PIT-38, due by April 30);
  • exchanging one cryptocurrency for another is tax-neutral: taxable income only arises on disposal for fiat currency, goods, services, or another property right;
  • trading in cryptocurrencies (buying, selling, exchanging) is exempt from VAT (following the line of case law from CJEU judgment C-264/14, Hedqvist) and from the civil-law transaction tax (PCC) (statutory exemption since 2020, Article 9(1a) of the PCC Act).

For the full, detailed breakdown, see our dedicated guide to cryptocurrency taxation in Poland.

Comparison with other EU countries

It’s worth seeing how other EU countries treat crypto investors:

  • Slovakia applies a reduced 7% tax rate if the investor holds assets for 12 months before selling;
  • Portugal taxes income from assets held for less than a year at 28%, and exempts assets held longer than 12 months;
  • Germany does not tax gains if the assets were held for more than 12 months.

Poland, unlike these countries, offers no relief for long-term holding: the 19% rate applies regardless of the holding period.

Cryptocurrencies and B2B contractor status under the 2026 PIP law

Income from cryptocurrency investments is a separate source of income (money capital) and has no direct bearing on whether your B2B cooperation shows the hallmarks of subordination under the 2026 PIP law. Still, if you operate as a sole trader, it’s worth keeping the two sources strictly separate: crypto income should be settled on its own (PIT-38), not folded into your B2B business revenue. Mixing the two can needlessly complicate your paperwork in the event of an inspection. For more on B2B reclassification itself, see here.

FAQ

Do I need any authorization to trade cryptocurrencies as a private investor?
No. The obligation to register in the VASP register / obtain a CASP authorization applies to entities providing services (exchanges, wallets, exchange services), not to private investors buying and selling crypto for their own account.

Does the KNF already supervise the crypto market in Poland? Eventually, yes, but full licensing supervision over the crypto-asset market (issuing CASP authorizations) will only become possible once the national crypto-asset market act enters into force. As of July 2026, that process is not yet complete.

Bibliography and Legal Basis

  • Act of March 1, 2018, on Counteracting Money Laundering and Terrorist Financing (Journal of Laws 2018, item 723).
  • Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets (MiCA).
  • CJEU judgment of October 22, 2015, in case C-264/14, Skatteverket v David Hedqvist.

Have questions about whether your crypto business complies with Polish law, or want to check if you need an authorization? Book a free consultation with our team.

Author: MojaFirma team.

*This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific contract and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.*