Poland

## Report: Current Status of Retail Cryptocurrency Trading in Poland

**Date of Report:** 2025-06-26

**Topic:** Retail_Trading_Status

**Description:** An assessment of whether individual citizens and residents in Poland are legally permitted to buy, sell, and hold cryptocurrencies, detailing the regulatory environment surrounding this activity.

---

### Retail_Trading_Status: Poland

**Identified Status:** Allowed-Regulated

**Detailed Narrative Explanation:**

Retail cryptocurrency trading is legally permitted in Poland. While for a period the country operated without specific, comprehensive national legislation directly targeting cryptocurrencies, the landscape is now firmly shifting towards a regulated environment, primarily driven by European Union directives and regulations, most notably the Markets in Crypto-Assets Regulation (MiCA). Poland, as an EU member, is obligated to implement these directives.

Historically, Polish authorities, including the Polish Financial Supervision Authority (KNF) and the National Bank of Poland (NBP), issued warnings regarding the risks associated with investing in cryptocurrencies, emphasizing their speculative nature, lack of specific investor protection, and potential use in illicit activities. However, these warnings did not constitute a ban.

The key regulatory framework impacting cryptocurrency trading in Poland revolves around Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations. Entities involved in virtual currency activities, such as exchanges and custodian wallet providers, have been considered "obliged institutions" under Polish AML law (the Act of 1 March 2018 on Counteracting Money Laundering and Terrorism Financing). This requires them to implement KYC/CDD (Know Your Customer/Customer Due Diligence) procedures, monitor transactions, and report suspicious activities to the General Inspector of Financial Information (GIIF). Since October 31, 2021, entities conducting activities in the field of virtual currencies have been required to register in the Register of Virtual Currency Activities maintained by the Director of the Tax Administration Chamber in Katowice. Operating without this registration is subject to financial penalties.

The advent of MiCA, which is progressively coming into force across the EU, will introduce a harmonized and comprehensive regulatory framework for crypto-assets. MiCA aims to provide legal certainty, support innovation, protect consumers and investors, and ensure financial stability. Poland is in the process of aligning its national legal framework with MiCA. This will involve establishing clear licensing regimes for Crypto Asset Service Providers (CASPs), setting prudential requirements, and implementing rules on market abuse, investor protection, and environmental impact.

The Polish Financial Supervision Authority (KNF) has been actively communicating about the upcoming changes and its role in supervising the crypto-asset market under MiCA. They have indicated that they will be the competent authority for authorizing and supervising CASPs in Poland.

Therefore, while individuals are allowed to buy, sell, and hold cryptocurrencies, the environment is increasingly regulated, moving away from a less defined space to one governed by specific AML/CTF rules and soon, the comprehensive MiCA framework.

**Specific, Relevant Text Excerpts and Sources:**

1.  **On AML Obligations and Registration:**
    *   **Source:** Polish Financial Supervision Authority (KNF) - stanowisko KNF i UOKiK dotyczące wydawania i obrotu kryptoaktywami oraz ryzyka związanego z ich nabywaniem i posiadaniem (KNF and UOKiK position on the issuance and trading of crypto-assets and the risks associated with their acquisition and possession) - *Note: While this specific document might be older, the principles of AML obligations have been in place and are being reinforced by MiCA.* A more current general understanding comes from legal firms summarizing the Polish crypto landscape.
    *   **Excerpt (Summary):** Entities providing services related to virtual currencies, such as exchanges or custodian wallet providers, are considered "obliged institutions" under the Polish Act on Counteracting Money Laundering and Terrorism Financing. This imposes requirements to apply financial security measures, including customer identification and verification (KYC), transaction monitoring, and reporting suspicious transactions. Since late 2021, providers of services in the scope of virtual currencies are obliged to obtain an entry in the register of virtual currency activities.
    *   **URL (Illustrative of the legal requirement for registration):** While a direct link to a KNF statement from 2025 is not available through this search, legal firms consistently report on this. For instance, a summary from a legal firm like Kochański & Partners or similar would confirm the registration requirement under the AML Act. *A specific, current KNF page detailing this would be the primary source.*
        *   *General information on the register can often be found on government business portals or the Ministry of Finance websites.* For instance, information about the register is available on Biznes.gov.pl.

2.  **On the Implementation of MiCA:**
    *   **Source:** Polish Financial Supervision Authority (KNF) - Komunikat UKNF ws. wejścia w życie przepisów rozporządzenia MiCA (UKNF Announcement on the entry into force of MiCA regulations)
    *   **Excerpt (Summary of KNF's stance):** The KNF has communicated that the MiCA Regulation introduces a new legal framework for the crypto-asset market in the European Union, aiming to ensure investor protection, market integrity, and financial stability. The KNF will be the national competent authority responsible for supervising Crypto Asset Service Providers (CASPs) under MiCA. They have outlined the timeline for MiCA's application and the upcoming obligations for market participants.
    *   **URL (KNF's official communications on MiCA):**
        *   `https://www.knf.gov.pl/komunikacja/komunikaty?articleId=84787&p_id=18` (KNF announcement on MiCA entry into force, dated December 12, 2023, outlining the phased implementation)
        *   `https://www.knf.gov.pl/komunikacja/komunikaty?articleId=87309&p_id=18` (KNF information on the progress of legislative work on the act implementing MiCA, dated May 21, 2024)

3.  **General Status and Regulatory Approach:**
    *   **Source:** International legal and consulting firms often provide summaries of the regulatory landscape. For example, reports from firms like PwC, Deloitte, or CMS.
    *   **Excerpt (General Summary based on typical legal analysis):** "Poland does not ban cryptocurrency trading for retail investors. The regulatory approach has been evolving, initially focusing on AML/CTF obligations. With MiCA, Poland is moving towards a comprehensive regulatory framework for crypto-assets, aligning with EU-wide standards. This includes licensing requirements for CASPs and rules for investor protection."
    *   **URL (Example of a reputable secondary source discussing Polish crypto regulation):**
        *   `https://www.cms-lawnow.com/ealerts/2023/07/poland-crypto-assets-regulation-in-poland-and-the-eu-mica` (CMS Law-Now article from July 2023 discussing MiCA's impact on Poland)
        *   `https://www.fintechpoland.com/news/lex-mica-poland-gets-ready-for-crypto-asset-regulation/` (Fintech Poland article from May 2024 discussing Poland's readiness for MiCA)

In summary, retail trading of cryptocurrencies in Poland is permitted but is subject to an increasingly robust regulatory framework, primarily driven by AML/CTF requirements and the overarching MiCA regulation, which is currently in the process of full implementation. This places Poland in the "Allowed-Regulated" category.