DAC8 reporting in Poland starts with an unusual regulatory backdrop.
DAC8 reporting in Poland starts with an unusual regulatory backdrop.
EU Member States were required to apply the DAC8 rules from 1 January 2026.
Poland’s implementing act entered into force only on 18 March 2026.
The Polish legislation addresses this gap directly: the new framework also covers relevant reportable crypto-asset transactions carried out from 1 January 2026.
As a result, the first reporting period effectively covers the whole of 2026, with the first reports due by 30 June 2027.
There is another Polish twist.
Poland currently has no domestically authorised MiCA CASPs, as the domestic MiCA licensing framework is still not operational. The transitional period for previously registered Polish VASPs ended on 1 July 2026.
But this does not mean that there are no entities potentially subject to DAC8 reporting.
DAC8 is broader than MiCA-authorised CASPs and also covers certain Crypto-Asset Operators. And entities operating during the transitional period may still have reporting obligations relating to their 2026 activity.
In other words: Poland’s MiCA licensing gap does not create a corresponding DAC8 reporting gap.
Source: Polish Act of 13 February 2026 implementing DAC8: