The adoption of blockchain technology and asset tokenization is advancing at a rapid pace, but the real engine driving its global development is the existence of a clear, consistent and innovation-friendly legal framework.
Some countries have already established themselves as regulatory benchmarks, establishing specific rules for cryptoassets, DLT infrastructures and token issuance with legal backing. In this article we show you relevant information about blockchain regulation in Poland, which you can use as a guide if you are looking to operate internationally or evaluate different strategic locations.
Current legislation on blockchain and virtual assets in Poland
MiCA Regulation (Markets in Crypto-Assets Regulation)
Establishes the EU’s first comprehensive legal framework for regulating cryptoasset issuers and service providers (CASPs). Covers stablecoins, utility tokens, electronic money tokens (EMTs), asset referenced tokens (ARTs), and custody or exchange platforms. Requires prior authorization, governance requirements, solvency, transparency, and user protection.
MiFID II (Markets in Financial Instruments Directive II)
The MiFID II Directive regulates security tokens and cryptoasset derivatives that qualify as financial instruments in Poland. Platforms offering these assets must obtain investment firm licenses, comply with prudential requirements, and submit to transparency and investor protection rules under the supervision of the KNF.
Polish Prevention of Money Laundering Act
Cryptoasset service providers (VASPs) are subject to the Polish Act on the Prevention of Money Laundering. Since the transposition of AMLD5, they are obliged to register in the national registry, apply KYC (know your customer) procedures, monitor transactions and report to GIIF.
Cryptoassets Sandbox in Poland and DLT Pilot Regime
Poland participates in the European Blockchain Sandbox. The KNF also manages an Innovation Hub that allows blockchain startups and companies to test solutions in asset tokenization, EMT/ART stablecoins and DeFi, in a supervised environment, although they are not formal regulatory sandboxes with legal exemptions. Also, Poland participates in the EU DLT Pilot Regime.
Tokenization makes it possible to digitally represent real-world assets through blockchain, but for it to have legal value, a regulatory framework recognizing this operation is essential. Poland adopts its own approach, establishing specific rules for the issuance, custody or trading of tokens. In this block we explain how asset tokenization is regulated from a legal point of view, taking an advanced jurisdiction such as Poland as an example.
Regulation of asset tokenization in Poland
Asset tokenization in Poland is based on the European legal framework. If the tokens represent financial instruments, such as stocks, bonds or fund shares, they are subject to MiFID II and the supervision of the KNF. These tokens require a license for issuance and trading on regulated markets. On the other hand, utility tokens and stablecoins EMT (electronic money tokens) or ART (asset referenced tokens) are governed by the MiCA Regulation, fully in force since the end of 2024.
Poland is part of the DLT Pilot Regime, which allows operating blockchain-based market infrastructures for trading tokenized financial instruments. Several projects in the country are already exploring this framework to develop secondary markets on DLT. In addition, the KNF promotes participation in the European Blockchain Sandbox, fostering innovation in tokenization and stablecoins.
The tokenization of non-financial assets, such as real estate or art, has no specific regulation, but is legally recognized in private law. Depending on their structure, these tokens may be subject to tax or civil regulation. In the field of tokenized financial instruments, the European DLT Pilot Regime legally recognizes DLT registries for the issuance, trading and settlement of securities. For non-financial assets such as real estate or art, DLT registries have contractual value between the parties but do not replace mandatory public registries: real estate still requires registration in the Polish Land and Mortgage Register (Księga Wieczysta), so tokenization of real estate represents economic rights or participations, not direct registry ownership.
Regulatory bodies and authorities for digital assets in Poland
Financial Supervisory Commission (KNF)
The KNF (Komisji Nadzoru Finansowego) is the leading authority in cryptoasset and blockchain regulation in Poland. It oversees CASPs, token issuance, exchanges, custodians and digital asset markets. It applies MiFID II to security tokens and ensures compliance with AML/CFT rules. It is expected to be the competent authority under MiCA for CASP licensing once the national implementing legislation, currently blocked by the presidential veto of the Cryptoasset Market Act, is passed.
National Bank of Poland (NBP)
NBP (Narodowy Bank Polski) participates in studies on the possible issuance of a CBDC and in the assessment of the impact of cryptoassets on financial stability. It collaborates with the KNF in the supervision of stablecoins that may have systemic effects, in aspects such as reserves, liquidity risks and monetary policy.
General Inspectorate for Financial Information (GIIF)
The GIIF (Generalny Inspektor Informacji Finansowej) is Poland’s financial intelligence unit. It monitors AML/CFT compliance of VASPs and CASPs through periodic and non-periodic inspections, analyzes suspicious transaction reports and coordinates the implementation of AML directives in the Polish jurisdiction. The VASP register was managed by the Director of the Tax Administration Chamber in Katowice (Izba Administracji Skarbowej w Katowicach), not by the GIIF; the register was closed to new registrations on October 1, 2025. The GIIF cooperates with the KNF and other authorities to protect the integrity of the financial system.
Launching a business based on digital assets requires more than just technology: it is also necessary to comply with legal requirements such as licensing, registration and regulatory obligations. These conditions ensure that the business model is viable and sustainable over time, and that it meets transparency and fraud prevention standards. In this section we explore what licenses are typically required and what compliance criteria blockchain companies operating in Poland must follow.
What licenses and requirements are needed to trade cryptoassets in Poland?
CASP License (MiCA) – Legislative deadlock in Poland
MiCA is an EU regulation directly applicable in Poland as of December 30, 2024, but Poland is, as of today, the only EU member state that has not enacted the necessary national legislation to implement it operationally. The Cryptoassets Market Act – the regulation that would have designated the KNF as the competent authority and enabled the CASP authorization process – was vetoed twice by the President of Poland (December 2025 and February 2026) and the second veto was not overcome in Parliament.
As a result, the KNF is currently unable to process CASP license applications or issue authorizations in Poland. Companies operating as registered VASPs before December 30, 2024 can continue on a transitional basis until July 1, 2026. After that date, those who do not have a CASP authorization – obtained in Poland after the law is passed, or by passport from another member state with an operational regime such as Lithuania or Estonia – will have to cease their activities. Foreign companies that already have a CASP license in another Member State may provide services in Poland by notifying the KNF, but Polish companies currently have no mechanism for obtaining a passport.
Investment Firm License (ESI)
Platforms in Poland that offer derivative financial products on cryptoassets (futures, options, CFDs) must be licensed as Investment Firms under MiFID II, as these products are considered financial instruments. The granting of this license is also the responsibility of the KNF, which supervises the correct application of MiFID II and MiCA in the field of cryptoassets.
AML/KYC Compliance
Crypto companies operating in Poland must comply with the Prevention of Money Laundering and Terrorist Financing Act, which incorporates AMLD5 obligations. This includes KYC processes, transaction monitoring, identification of beneficial owners and reporting suspicious activity to the General Inspectorate for Financial Information (GIIF), the Polish financial intelligence unit. Strict compliance with AML/CFT regulations is mandatory to obtain and retain authorization as a CASP.
Other regulatory requirements
In addition to complying with MiCA and AML/CFT, crypto companies in Poland must apply the provisions of the DORA (Digital Operational Resilience Act) Regulation. This regulation imposes the adoption of ICT risk management policies, cybersecurity, operational continuity plans and digital resilience testing. It also requires oversight of technology providers and adequate training of personnel. Compliance with DORA is indispensable to operate legally in Poland under the MiCA framework.
Are you exploring developing your blockchain project in Poland?
At Metlabs we help companies like yours and offer comprehensive support in the development of blockchain projects and tokenization of assets such as real estate, carbon credits, commodities, intellectual property, financial instruments, franchises and more, fully aligned with blockchain regulation in Poland and international regulatory standards.
Contact us and find out how we can help you meeting all your business model needs, from technical validation and structuring to design, development and implementation of custom blockchain solutions, ready to scale from day one.