Has the EU adopted new regulations regarding private Bitcoin wallets?

The EU has not imposed a general ban on owning a personal Bitcoin wallet. The regulations distinguish between a wallet over which you have sole control of your funds and an account maintained by a cryptocurrency service provider. However, using a personal wallet does not exempt you from the verification required when conducting a transaction with such a provider.

Updated: October 7, 2026. We explain the difference between MiCA, transfer rules, and the upcoming AMLR regulations.

A personal wallet vs. an anonymous account: What's the difference?

A private wallet, also known as a self-hosted or self-custody wallet, is used to manage your own keys and funds. An exchange account, on the other hand, is a service provided by the exchange. Simply not registering when setting up a wallet does not guarantee the anonymity of subsequent transactions.

Article 79 of the AMLR Regulation concerns anonymous accounts maintained by banks, financial institutions, and cryptocurrency service providers. Recital 160 clarifies that the prohibition does not apply to providers of hardware, software, and self-hosted wallets, provided they do not have access to or control over those wallets. This provision should not be equated with a ban on owning one’s own wallet.

MiCA, the Travel Rule, and AMLR: When Do They Take Effect?

• MiCA — Regulation 2023/1114: a framework for the crypto-asset market and service providers. The main provisions began to apply on December 30, 2024; provisions regarding certain stablecoins began to apply earlier. Transition periods for existing service providers could last until July 1, 2026, at the latest, depending on the country and any prior authorization decision.
• Travel Rule — Regulation 2023/1113: Rules on Information Accompanying Transfers, effective December 30, 2024
• AMLR — Regulation 2024/1624: new common rules on anti-money laundering. As a general rule, they will apply as of July 10, 2027, including Article 79 mentioned above.

Therefore, the statement that all these regulations had been fully implemented by the end of 2025 is incorrect. Existing AML obligations remain in effect; the future AMLR date does not signify a period without verification.

Do you not need to verify your identity for amounts under 1,000 EUR?

We cannot promise that. The €1,000 threshold in the transfer rules is not a general KYC exemption amount. Articles 14 and 16 of Regulation 2023/1113 require the provider to collect information for transfers to or from a self-hosted address. For amounts exceeding 1,000 EUR, additional measures are required to assess whether the customer owns or controls that address.

Verifying a customer’s identity and assessing control over an address are two different processes. The provider may also require this information for lower amounts, in accordance with applicable regulations and service procedures.

Do Bitcoin and a personal wallet ensure anonymity?

Bitcoin is pseudonymous, not anonymous. Transactions and addresses are visible on the public blockchain. An address can be linked to a person, and the transaction history remains accessible. A personal wallet gives you control over your keys; it does not guarantee that your identity will remain hidden or that you will be exempt from legal obligations. For more information on setting up an address and protecting your keys, see the guide to wallets for Bitcoin ATMs.

What does this mean for Bitcoin ATM users?

The Bitcoin ATM allows you to exchange cash and cryptocurrencies according to the operator’s terms and conditions. Do not treat it as a way to bypass KYC. Before making a transaction, check the operator’s verification requirements and the instructions displayed on the device. Do not send funds until you understand the terms and conditions for processing and withdrawal.

Use the map of Bitcoin ATMs in Poland to compare locations and available device information. Bitomat.com is an information aggregator, not an operator or a party to transactions. Direct questions about documents, limits and settlement to the operator of the specific Bitcoin ATM.

Sources and Further Information

• AMLR: Articles 79 and 90 and Recital 160
• Transfers of Cryptoassets: Articles 14, 16, and 40
• EUR-Lex: Scope and Deadlines of MiCA
• ESMA: Article 143 of MiCA and Transition Periods
• Bitcoin.org: Public Transaction History

This is a general explanation of EU regulations. The requirements for a specific transaction also depend on national law and the procedures of the relevant operator.