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We, the representatives of Polish cryptocurrency market companies, out of concern for the protection of customers operating in the market, are calling for a veto of the cryptocurrency market bill in its current form.
While the law formally purports to implement the EU MiCA regulation, in practice it goes far beyond it. Instead of merely ensuring that the market operates in accordance with European law in a transparent and proportionate manner, it introduces dozens of pages of additional regulations, criminal sanctions unprecedented in other EU countries, and numerous administrative obligations, making the Polish draft the most restrictive law of this type in the entire European Union.
The effect will be to force Polish entities to emigrate to other jurisdictions. This means that millions of Polish customers will have to seek protection of their rights from foreign institutions.
A recent study by Kraken ("Forbes Poland," October 2025) shows that already 30.9% of Poles invest in cryptocurrencies - that's several million people, not only consumers, but also voters.
By comparison, there are only 321,000 active brokerage accounts in Poland.
The regulations prepared by the Finance Ministry, without taking into account the demands of the market, therefore affect several times as many people - all the more reason for them to be refined.
Meanwhile, more than 40 amendments were passed in the Sejm and more than 80 in the Senate, showing that the degree of preparation of the law at this advanced legislative stage was not sufficient.
We are in favor of establishing correct rules for the market, eliminating crooks and criminals from it; however, the solutions being introduced will not ensure this, and will make any innovation in the web3 market in Poland stifled.
This is not only a regulatory issue, but also an economic one.
It is about the international competitiveness of the Polish economy and the innovation of Polish companies.
Adopting this law in its current form would mean that Polish capital would be pushed out of its own market, and opportunities for Polish startups to expand abroad would be lost.
In practice, this means that companies operating in Poland today - financed with domestic funds, employing Polish specialists, creating jobs here and paying taxes - will be displaced by foreign entities (most often from Germany, Austria and the Netherlands).
Poles, on the other hand, in the situation of possible disputes, will have to settle them in foreign courts - not in their home country.
In our view, the current form of the law may violate numerous provisions of the Basic Law, including:
The Polish law introduces far-reaching over-regulation (so-called gold-plating), unprecedented in other EU countries.
As a result, our web3 market will become the least competitive in Europe.
Such regulations may violate, among other things:
The Union aims for uniform rules of the game throughout the Community - Polish regulations contradict this.
Poland has great potential to become a European fintech and blockchain hub, as long as the regulatory framework is proportionate and innovation-friendly.
We have some of the best IT specialists in the world, developed retail banking and modern payment systems. However, with the way the law is structured - this will not be possible.
Between 2012 and 2014, Poland was one of the leaders of the global cryptocurrency market.
Some of the first companies of its kind in Europe were established here, and the zloty was the third most frequently exchanged currency for bitcoins (after the yen and the US dollar).
The market has engaged in rule-making and self-regulation, including through:
Unfortunately, in response, the FSA launched a campaign to limit the development of the market - cryptocurrencies were discouraged, company accounts were closed, and some companies moved abroad.
Instead, hundreds of unverified entities were added to the 2021 registry, leading to foreign government intervention.
The market is actively participating in the consultations, but there is still a lack of dialogue and understanding from the government side that excessive oppressiveness destroys innovation.
Since President Donald Trump took power, the United States has supported the development of the web3 sector.
The European Union is moving in the opposite direction - and Poland is going even further, limiting this development.
On May 28, 2025, before the second round of the presidential election, the President made a public promise, saying:
"Poland must be a place where innovation, not regulation, is created."
As President, I will be the guarantor of ensuring that no zamordistic regulations that restrict your freedom come into force."
We kindly ask you to keep your word and work together to ensure that Poland is a country where innovation is created and economic freedom flourishes, not a place where entrepreneurs go to jail for minor mistakes.
We declare our readiness to cooperate in the creation of a new law - based on the EU+0 principle, i.e. without redundant, national regulations.
We also ask that the Office of the Financial Supervisory Commission (OCC) not continue to be the supervisor of the blockchain-based financial technology market.
The data show that the FSC is one of the most restrictive and least flexible regulators in the EU:
As a result, Polish startups have to license themselves abroad, paying taxes there and appealing to foreign courts.
We expect regulations that are fair, proportionate and predictable - in line with EU principles and the Polish Constitution.
Regulations that:
We ask the President to veto the bill and refer it for reworking,
or to submit our own bill, which we declare we can substantively support or co-author.
We would like to see Poland - despite the numerous regulations enforced by Brussels - become one of the most competitive markets in the world.
The whole world is moving toward modern finance, where the cost of capital is decreasing and settlements take seconds.
We want to join these trends, not go against them.
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