Changes in the Polish Draft Act implementing MiCA and further legislative stages

A revised version of the Draft Act on the Crypto-Assets Market (Draft Act), implementing the Markets in Crypto-Assets Regulation (MiCA) into Polish law, was published last week on the portal of the Government Legislation Center. The Draft Act was then forwarded to the Standing Committee of the Council of Ministers, indicating the final stage of the government's internal legislative process. 

What changes does the new version of the Draft Act present?

Transition Period Structure

The amended Draft Act establishes a two-tier transition framework for Virtual Asset Service Providers registered as of December 29, 2024. Entities will receive a four-month transition period from the Act's entry into force. Entities that submit complete authorization applications within the first three months after the Draft Act takes effect will receive an extended nine-month transition period (and thus an extended period of five months).

Next Steps

The Draft Act's progression through the Standing Committee of the Council of Ministers represents the near-completion of Poland's MiCA implementation process. Market participants should monitor the legislative timeline and begin preparation for authorization applications under the new framework.

The full and up-to-date version of the Draft Act can be found here: https://buff.ly/y9JbOWm