🇵🇱Poland

Detailed overview

Poland at a glance

Poland combines a unique crypto-regulatory vacuum with an otherwise conventional financial-services regime and a restrictive, state-monopoly gambling market. MiCAR applies directly, but Poland has not passed an implementing law, so the KNF cannot license CASPs and the only lawful route is passporting in from another Member State. Payments run under the Payment Services Act with the KNF as supervisor. Gambling runs under the Gambling Act, supervised by the Ministry of Finance. The złoty is the currency, and Poland sits outside the euro area and banking union, so there is no ECB/SSM role.

Crypto regime under MiCA — a national vacuum:

• MiCA + national implementing law — Regulation (EU) 2023/1114 (MiCAR) applies directly, but Poland is the only EU state with no implementing law in force; the Crypto-Assets Market Act was vetoed twice (1 December 2025 and 12 February 2026) and a Sejm override failed (18 April 2026)
• Competent authority — none is designated for CASPs, non-ART/EMT offerors or ART issuers; the KNF is competent only for EMT issuers, under existing supervision
• The KNF statement of 10 February 2026 — entities under the Polish transitional regime lose the right to provide crypto services after 1 July 2026 until they obtain MiCA authorisation; CASPs authorised in other Member States may passport into Poland under Article 65; non-compliance attracts administrative sanctions and KNF website blocking; the 1 July 2026 deadline applies regardless of Polish legislation
• Pre-MiCA heritage — the Register of Virtual Currency Activity (RDWW), kept under the AML Act since 2021, with roughly 1,300 registered VASPs; closed to new entries since 30 December 2024, conferring no passport, and expiring 1 July 2026
• Practical reality — a two-tier market: foreign passported CASPs operate freely while Polish-only VASPs are barred after 1 July 2026; Polish firms have relocated or applied in other Member States (commonly Czechia, Lithuania, Cyprus or Estonia), partnered with licensed entities, or wound down
• Directors' exposure — providing crypto-asset services without authorisation after 1 July 2026 exposes directors to personal liability
• AML/CFT — the AML Act and the GIIF apply; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027
• TFR / DORA — the Travel Rule (Regulation (EU) 2023/1113) and DORA (Regulation (EU) 2022/2554) apply directly
• Tax — administered by KAS: individual disposals of "virtual currency" are taxed at a flat 19% under the PIT Act (Article 30b, since 2019), filed on form PIT-38; crypto-to-crypto swaps are tax-neutral; there is no holding-period benefit and no tax-free threshold, and losses carry forward. Corporate income tax is 19% (9% for small taxpayers); this regime predates MiCA and is unaffected by the veto

Payments and e-money regime (KNF-led):

• PSD2 — Directive (EU) 2015/2366; transposed by the Payment Services Act, supervised by the KNF
• Payment Institution licensing — full National Payment Institution (KIP) with initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) or EUR 125,000 (other payment services); a lighter Small Payment Institution (MIP) route operates domestically only, with no passport and monthly transaction limits
• EMD2 / E-Money Institution — Directive 2009/110/EC; EUR 350,000 initial capital; stablecoin (EMT) issuers must be EMIs or credit institutions
• Instant Payments Regulation (Regulation (EU) 2024/886) — euro instant-payment obligations apply to euro payments where offered; Poland's domestic currency is the złoty
• DORA (Regulation (EU) 2022/2554) — applicable from 17 January 2025
• PSD3 / PSR — Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions
• Banking — Poland is outside the banking union, so the KNF is the sole banking supervisor and there is no ECB/SSM role
• Currency: złoty (PLN); NBP is the central bank

Gambling regime — a state monopoly with turnover tax:

• Gambling Act of 19 November 2009 — amended in 2016 (effective 1 April 2017) after the 2009 "Black Jack Gate" scandal, taking a restrictive approach
• Regulator — the Ministry of Finance (minister competent for public finance), with KAS and the Customs and Fiscal Service on enforcement
• State monopoly — online casino, poker, bingo, slot-type games, number games, cash lotteries and slot machines outside casinos are reserved to the state-owned Totalizator Sportowy (Total Casino / totalcasino.pl)
• Private operators — only online mutual (sports) betting and promotional lotteries are open to private operators, under a six-year licence requiring an EEA seat, a ".pl" domain and local supervisory access
• Tax — mutual betting is taxed at 12% of turnover (stakes), a notably heavy, stake-based burden; player winnings are taxed at 10% (a proposed rise to 15% from 2026 was vetoed)
• Capital — PLN 4,000,000 (casino) or PLN 2,000,000 (mutual betting / bingo hall)
• Enforcement — a register of illegal gambling domains with ISP and payment blocking; minimum age 18
• No EU passport — gambling is licensed nationally

Last verified: July 2026. Reference rate: EUR 1 ≈ PLN 4.3; USD 1 ≈ PLN 3.7.

Poland is the EU's outlier: MiCAR applies, but no national law is in force, so the KNF cannot license CASPs and the only lawful route is passporting in from another Member State. Payments run under the Payment Services Act, and gambling is a restrictive state monopoly with a turnover-based betting tax.

Is there a crypto licence in Poland?

Not from Poland. MiCAR applies directly, but Poland has no implementing law, so the KNF is not the designated CASP authority and cannot process applications. The lawful route to the Polish market is a CASP authorisation obtained in another Member State and passported in under Article 65.

The legal foundation:

• Regulation (EU) 2023/1114 (MiCAR) — directly applicable, but requiring national designation of a competent authority to license CASPs
• Crypto-Assets Market Act — the would-be national implementing law, vetoed twice and not in force following the failed override
• AML Act — AML/CFT obligations and the legacy RDWW virtual-currency register
• Regulation (EU) 2023/1113 — Travel Rule for crypto-asset transfers

Structure (in practice):

• Because no Polish CASP licence can be issued, firms incorporate and authorise in a Member State with an operational regime, meeting MiCAR own-funds floors there — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3)
• They then passport into Poland under Article 65 by notifying the home regulator
• The KNF remains the competent authority only for EMT issuers

Operational reality:

• Polish-only VASPs lose the right to serve clients after 1 July 2026; the RDWW register expires and confers no passport
• Foreign CASPs serve Poland freely by passport, producing a two-tier market; directors face personal liability for unauthorised provision after the cut-off
• Several draft implementing acts remain in the legislative pipeline, but even if one is adopted, the KNF would need months to stand up a licensing process

Official CASP roadmap: There is no Polish CASP roadmap — no national law designates a competent authority, so the KNF cannot grant CASP authorisations. Firms obtain a CASP licence in another Member State and passport into Poland under Article 65 MiCAR; the KNF is competent only for EMT issuers. See the KNF and its statement of 10 February 2026 on the MiCA transition.

Payments & E-money (KNF — PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and e-money operators wanting a large domestic market and a flexible small-institution entry route.

What it is: Authorisation as a national payment institution, small payment institution or e-money institution under the Payment Services Act, supervised by the KNF (full PIs and EMIs passport across the EEA).

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, smaller domestic payment firms (via the MIP route), and e-money issuers.

Covers: The payment services under the Payment Services Act — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Polish entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management.

Headline figures

• Primary instruments: Payment Services Act (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
• Regulator: KNF (authorisation and supervision)
• Entry capital: national payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000; the small-payment-institution route is lighter (domestic only, no passport)
• Banking: outside the banking union — the KNF is the sole banking supervisor, with no ECB/SSM role
• Reform pipeline: PSD3 / PSR — political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
• Currency: złoty (PLN); NBP is the central bank

Is there a gambling licence in Poland?

Yes, but narrowly. Online casino, poker and slots are a state monopoly run by Totalizator Sportowy; private operators may obtain only online sports-betting and promotional-lottery licences, taxed heavily on turnover.

The legal foundation:

• Gambling Act of 19 November 2009 — amended in 2016 (effective 1 April 2017), restrictive in approach
• Ministry of Finance — licensing and supervision, with KAS on fiscal enforcement
• State monopoly — Totalizator Sportowy operates online casino, poker, bingo, slot-type games and number lotteries

Structure:

• Private operators are limited to online mutual (sports) betting and promotional lotteries under a six-year licence
• Land-based casinos operate under concession (one per 250,000 inhabitants); bingo halls and betting shops are separately licensed
• Strict domain and payment blocking targets unlicensed offshore operators

Gambling — Online betting licence (Ministry of Finance)

Best for sportsbook operators able to absorb a 12% turnover tax and meet local technical and AML requirements.

What it is: A six-year Ministry of Finance licence to offer online mutual (sports) betting to Polish players.

Who it suits: Established sportsbook operators (such as the strong local incumbents) able to meet integrity, technical and responsible-gambling requirements.

Covers: Online fixed-odds and mutual betting; promotional lotteries are separately permitted.

Operational requirement: An EEA-registered seat, a ".pl" domain, age verification, AML/CFT, responsible-gambling tools, local server and data-archiving obligations, and supervisory access.

Headline figures

• Primary instruments: Gambling Act of 19 November 2009 (amended 2017)
• Regulator: Ministry of Finance (with KAS enforcement)
• Tax: mutual betting taxed at 12% of turnover (stakes); player winnings at 10%
• Capital and term: PLN 2,000,000 (mutual betting); six-year licence; minimum age 18
• Monopoly: online casino, poker and slots reserved to the state-owned Totalizator Sportowy

Costs and timelines at a glance

• Crypto: no Polish CASP procedure — MiCAR applies but no national law designates a competent authority; firms authorise in another Member State and passport in under Article 65; the KNF is competent only for EMT issuers; RDWW register expires 1 July 2026
• Payments primary instruments: Payment Services Act (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA
• Payments regulator: KNF (sole banking supervisor — no ECB/SSM, outside the banking union)
• Reform pipeline: PSD3 / PSR — agreement November 2025, compromise texts April 2026, adoption expected during 2026
• Gambling: Ministry of Finance betting licences (six-year term); 12% turnover tax; online casino a state monopoly (Totalizator Sportowy)
• Tax: corporate income tax 19% (9% for small taxpayers); individual crypto disposals taxed at a flat 19% (PIT-38), crypto-to-crypto tax-neutral
• Currency: złoty (PLN); outside the euro area and banking union
• FX: EUR 1 ≈ PLN 4.3; USD 1 ≈ PLN 3.7

Who Poland suits and who it does not

Suitable for

• Crypto firms that authorise elsewhere and want access to a large, crypto-active Polish market (millions of holders) by passporting in under Article 65
• EMT (stablecoin) issuers, where the KNF is the competent authority
• Payment, remittance, acquiring and wallet operators wanting a large domestic market — including smaller firms using the lighter small-payment-institution route
• E-money issuers and investment firms wanting a KNF authorisation with EEA passporting
• Sportsbook operators able to absorb a turnover-based betting tax and meet local technical rules

Not suitable for

• Firms wanting a Polish CASP licence — none can be issued while no national implementing law is in force
• Polish-only VASPs relying on the RDWW register — it expires on 1 July 2026 and confers no passport
• Directors continuing unauthorised crypto provision after the cut-off — they face personal liability and KNF website blocking
• Operators seeking a private online casino, poker or slots licence — those are reserved to the state monopoly
• Betting operators sensitive to tax — mutual betting is taxed at 12% of turnover, a heavy stake-based burden