Over a thousand Polish firms operating in the crypto market face a critical July 1, 2026 deadline to secure a new EU license, but Poland lacks the authority to issue them.
Unlicensed Cryptocurrency Operations in Poland
July 1, 2026, marks a pivotal date for the Polish crypto asset market, as the EU’s transitional period under the MiCA (Markets in Crypto-Assets) regulation expires. After this date, all entities providing crypto asset services within the European Union will require a new CASP (Crypto-Asset Service Provider) license.
Currently, Poland lacks a designated authority to issue these licenses, has no penalties for operating without one, and Zondacrypto will not obtain one.
Registration and Activity Levels
As of now, 1841 entities are registered for virtual currency activities with the Izba Administracji Skarbowej (Tax Administration Chamber) in Katowice, with 1208 remaining formally active. Experts note that registration requirements have historically been minimal, with companies able to register with as little as 5,000 zł in capital.
This has resulted in registrations from companies with no real activity, individuals, or entities providing services exclusively abroad, including the defunct Cinkciarz.pl exchange.
Limited Operational Entities
Legal counsel Kuba Szpringer estimates that only up to one-quarter of registered entities are actually conducting crypto asset activities. The vast majority are unlikely to meet the requirements for a CASP license.
In an optimistic scenario, fewer than 50 entities will be prepared to complete the full licensing process, either in Poland or abroad.
Stricter CASP Licensing Requirements
The requirements for a CASP license are significantly more stringent than the previous VASP (Virtual Asset Service Provider) registration. These include advanced technological standards, capital requirements, corporate governance principles, and comprehensive compliance procedures.
Applicants cannot have prior regulatory concerns, supervisory warnings, or doubts about their financial credibility.
Zondacrypto’s Licensing Issues
BB Trade Estonia OÜ, the owner of the Zondacrypto exchange, previously operated under an Estonian VASP license issued by the Financial Intelligence Unit. This license expires with the end of the MiCA transitional period and is not equivalent to a CASP permit.
Przemysław Kral, the company’s CEO, publicly stated readiness for MiCA and submitted applications in Cyprus and Estonia. However, the Cypriot regulator, CySEC, rejected the application, with Kral suggesting someone requested the denial, though details were not provided. The Estonian application remained unresolved.
Concerns Over Financial Stability
In July 2025, BB Trade Estonia OÜ was added to the Estonian Financial Intelligence Unit’s list of entities that have not fulfilled their obligations, due to a missing auditor’s report regarding its own funds.
Lawyer Łukasz Chacia suggests Estonian authorities had concerns about Zonda’s operations, and the auditor refused to confirm the company’s required capital. It is speculated that BB Trade Estonia OÜ may never have had access to its declared financial resources, a point indirectly acknowledged by CEO Kral, who revealed the exchange lacks the keys to a wallet containing over 4,500 bitcoins – keys held by Sylwester Suszek, founder of BitBay, who disappeared in 2022.
Regulatory History and Reputation
Legal expert Artur Bilski notes that CASP requirements are rigorous, and regulators consider the entire history of an entity, including past warnings and accusations. The Polish Financial Supervision Authority warned against Zonda as early as 2018 and reported potential criminal activity to prosecutors.
Professor Witold Srokosz confirms that MiCA regulations allow for the denial of a license based on an assessment of the exchange owner’s reputation and the assurance of safe operations.
Criminal Investigation into Zondacrypto
On April 17, 2026, the Regional Prosecutor’s Office in Katowice launched an investigation into Zondacrypto, alleging misleading customers about the ability to buy and store fiat and cryptocurrencies, and facilitating the transfer of funds in a way that obscured their origin.
The investigation covers activities throughout the country since 2022 and is being handled by the Central Bureau of Cybercrime in Wrocław. Estimated losses exceed 350 million zł and continue to rise with new reports.
Growing Number of Complaints
Prosecutor Michał Binkiewicz reported a surge in complaints from across the country, primarily regarding the inability to withdraw funds from the exchange. The Prosecutor’s Office expanded the network for receiving reports to district prosecutor’s offices in Silesia and issued recommendations to regional prosecutor’s offices nationwide to expedite the identification of all victims.
Authorities also warned against fraudulent offers of assistance in recovering funds appearing on social media.
Past Operational Issues
Professor Srokosz points out that in 2025, Zonda frequently held client funds for extended periods, citing anti-money laundering procedures. Recoveris analysis, published by money.pl and Wirtualna Polska in April 2026, showed a 99% decrease in bitcoin holdings in the exchange’s hot wallets between August 2024 and March 2026 – from 55.7 BTC to just 0.18 BTC.
Regulatory Vacuum in Poland
Poland is the only major EU economy that has not yet enacted legislation to implement MiCA into national law. The bill on crypto assets was passed twice by the Sejm (Parliament) and twice vetoed by President Karol Nawrocki.
As a result, no authority has been designated to issue CASP licenses, and the Financial Supervision Authority cannot accept license applications. No partner agency has been designated for supervisors from other EU countries, meaning Poland has no formal channel for receiving information about irregularities in the domestic market.
MiCA’s Applicability and Lack of Penalties
The absence of a law does not invalidate the EU’s MiCA regulation. From July 1, 2026, operating a crypto asset business without a CASP license will be illegal under EU law. However, Poland has not implemented penalties for violating this prohibition.
The only potential basis for liability is Article 60(1) § 1 of the Code of Petty Offences, which provides for a restriction of freedom or a fine for conducting business without the required permit.
Potential Responses and Risks
Lawyer Aleksander Wilner suggests some entities may consider this penalty disproportionate to potential profits from continued unlicensed operation. However, he warns that documented violations of MiCA will be considered in any future license application in the EU.
Banks may also step in, terminating accounts of entities operating in crypto without a valid regulatory basis. Without accounts in PLN and EUR, a retail-focused business model will not be viable.
Possible Scenarios After July 1
Entities registered as VASPs that do not obtain a CASP license will face several options: some, especially exchanges managing client funds, will be obligated to return those funds and cease operations. Others, without direct access to client funds, will simply discontinue certain services.
Some entities are seeking licenses in more liberal EU jurisdictions, with Latvia actively courting Polish crypto firms.
Collaboration and Consolidation
Wojciech Ługowski suggests a scenario involving collaboration with a larger, licensed entity, providing services as a partner or subcontractor. This allows retaining a customer base but requires significant organizational and financial investment.
Michał Królik predicts market consolidation after July 1, 2026, with users and capital moving to regulated platforms with CASP licenses.
Reverse Solicitation and Limitations
Some may attempt to use “reverse solicitation” – an exception allowing non-EU entities to serve EU clients only if the client initiated contact without any marketing directed at EU residents. However, legal experts emphasize this exception is narrow and impractical for entities actively operating in the domestic market.
