Poland’s Senate now holds a bill that would let the interior minister freeze the crypto-assets of people and companies on a national sanctions list, with the freeze applying the day after the decision is posted, before any court has looked at it. The Sejm, the lower house, passed the Act on restrictive measures (government bill, Sejm print 3003) on Friday 6 November by 240 votes to 202, with one abstention and 17 MPs not voting, according to KryptoPortal and BitHub, which both report the Sejm record. The Senate received the text on Monday 9 November and has 30 days to deal with it.
The Poland crypto freeze is not the country’s long-delayed MiCA law. That one, the crypto-asset market act, has been vetoed three times by President Karol Nawrocki. The result is an odd position for an EU member state: Poland could soon have a law that names crypto-assets among the things the state can freeze, while it still has no authority that can license a crypto exchange under the EU’s Markets in Crypto-Assets Regulation.
For most holders nothing changes. The national list had 554 entries in September, mostly people and firms tied to Russia and Belarus. What the bill changes is the work of exchanges and banks serving Polish clients, who would have to freeze on a national list, next day, under fines that can reach 5% of a company’s revenue.
What the Sejm passed on 6 November, and where it stands now
The vote took place at the Sejm’s 68th sitting. BitHub, in a report dated 7 November, gives the split by group: the governing coalition of KO, PSL and Lewica voted for, joined by Polska 2050, Razem and 14 of the 15 MPs of the Centrum club. PiS, Rozwój Plus and Konfederacja voted against, together with two small clubs, Demokracja Bezpośrednia and Konfederacja Korony Polskiej.
Cointelegraph, writing on 10 November, gave the same 240 to 202 result and said the bill went to the Senate on the Monday. Bitcoin Magazine reported the same tally, with 17 MPs absent from the vote.
The bill is a government text, prepared by the Foreign Ministry and adopted by the Council of Ministers, according to the Prime Minister’s office page dated 4 August. The Sejm held its first reading on 3 September. The interior minister would keep the national list and sign the freezing decisions, while a new team on restrictive measures under the foreign minister would coordinate the authorities’ work on EU sanctions.
Freeze first, appeal later: what the bill does with crypto
The core of the text is a national sanctions list kept by the interior minister. He can add a name on his own initiative or at the request of other bodies. BitHub counts 15 of them, among them the financial supervisor KNF, the president of the central bank NBP, the financial intelligence unit GIIF, the internal security agency ABW and the head of the National Revenue Administration.
Once a person or company is listed, their “financial means” are frozen. The bill spells out what that covers: cash, bank accounts, shares, bonds, derivatives and, explicitly, crypto-assets as defined in article 3 of MiCA. The freeze reaches assets a listed person owns, holds or controls. Nobody may make new money or assets available to them, and listed companies are shut out of public tenders.
Timing is the contested part. A listing takes effect the day after it is published in the Public Information Bulletin (BIP), the government’s official notice site. There is no request for reconsideration. The listed person can go to the administrative courts, at two levels, but the bill switches off the usual power of a court to suspend the contested decision while the case runs. In practice the freeze stays in place until a final judgment.
Some money can still be released. Frozen funds can be released for food, rent, mortgage payments, medicine, taxes and reasonable legal costs, according to BitHub and KryptoPortal.
Who is listed, and on what grounds
The listing grounds are tied to states under EU sanctions. A person can be listed for supporting such a state, for links with people who support it, for serious human rights abuses, or for starting or financing information manipulation that threatens Polish national security. The government calls the last one a new ground: direct or indirect support for foreign interference and manipulation in the information space. KryptoPortal notes that ordinary journalism and political statements are excluded unless they are a deliberate part of such a campaign.
The opposition reads that differently. On 29 October Konfederacja’s Krzysztof Bosak called the bill defective, dangerous and unconstitutional and warned of censorship, Eska reported. He asked where public debate or marketing ends and “interference in the information space” begins. BitHub notes that critics see the word “indirectly” as too wide for a measure that hits before a judge rules. A foreigner who ends up on the list is also added to Poland’s register of undesirable persons.
Fines of up to 5% of revenue for firms that fail to freeze
The obligation to act falls on intermediaries such as banks, crypto exchanges and custodians. They must freeze what they hold for a listed client and must not release it. BitHub lists the penalties; the company fines match those in the government draft as KPMG summarised it in July 2025.
| Measure | Who applies it | Amount or term |
|---|---|---|
| Administrative fine on a person | Head of a tax-customs office | Up to 20 million zloty |
| Fine on a company | Court | 10,000 to 200 million zloty, or 5% of the previous year’s revenue |
| Hiding or moving assets that must be frozen under EU sanctions | Criminal court | 6 months to 8 years in prison |
Compliance would be checked by the financial intelligence unit GIIF and by the KNF at the firms they already supervise, Bitcoin Magazine reported on 10 November.
Exchanges, not wallets: how a crypto freeze would be enforced
Nothing in the bill describes how the authorities would obtain private keys, KryptoPortal and Bitcoin Magazine both note. Enforcement runs through exchanges and other obliged firms that can stop a transfer, not through the user’s wallet. BitHub adds that EU exchanges and crypto exchange offices would have to block a listed client’s funds as banks do, and that wallets where only the owner holds the keys are harder to reach. In practice, the bill’s channels cover coins held for a listed person by a platform; it says nothing specific about coins the person keeps in self-custody.
Why Poland wants a crypto freeze law now
Poland already has a national sanctions list. It was set up by a law of 13 April 2022, passed weeks after Russia’s full invasion of Ukraine; the Sejm adopted it with no votes against, Rzeczpospolita reported at the time. As first published, that law did not mention crypto-assets. On 3 September 2026 Mroczek told MPs the list had 554 entries: 435 people and 119 companies, of which 99 were linked to Russian capital and 20 to Belarusian capital, KryptoPortal reports.
The new act gathers scattered rules in one text and widens the list to more people and firms already under EU sanctions. It also transposes Directive (EU) 2024/1226, which requires member states to treat the breach of EU sanctions as a crime, with penalties set at national level. That directive explains the prison terms and the turnover-based fines; it does not require next-day national freezes before a court rules, which is a Polish choice.
The timing matches a wider EU push against sanctions evasion through crypto. On 8 November Coindaro reported that the EU set up a crypto sanctions task force aimed at Russia’s evasion routes, without a new ban. Poland’s bill is a national tool on top of that EU work.
Poland’s MiCA saga: three vetoes and still no regulator
The sanctions bill uses MiCA’s definition of a crypto-asset. It does not touch the question that has blocked Polish crypto regulation for a year: who supervises the companies.
MiCA, the EU regulation that licenses crypto-asset service providers (CASPs) such as exchanges and custodians, needs a national authority in each member state. Poland’s government chose the KNF for that job in a separate text, the crypto-asset market act. It has not survived the president’s desk.
| Date | Step | Source |
|---|---|---|
| Nov 2025 | Parliament completes passage of the first crypto-asset market act | Notes from Poland |
| 1 Dec 2025 | Nawrocki vetoes it; the Sejm fails to override in December | Notes from Poland |
| 12 Feb 2026 | Second veto, of a version that cut the KNF fee cap from 0.4% to 0.1% of revenue | Notes from Poland |
| 17 Apr 2026 | Second override attempt fails: 243 for, 263 needed | Forsal |
| 15 May 2026 | Sejm passes a third version, 241 to 200 | xyz.pl |
| 11 Jun 2026 | Third veto | Parkiet, KryptoPortal |
| 1 Jul 2026 | End of the MiCA transitional period for existing firms | MiCA art. 143(3), KNF |
| 4 Sep 2026 | Override fails: 241 for, 198 against, 3 abstentions; 266 votes needed | Parkiet |
| 8 Sep 2026 | President’s office announces its own crypto-market bill | Money.pl |
Nawrocki called the second version “practically identical” to the first, Notes from Poland reported on 13 February, after his first veto on 1 December 2025. In April a second override vote got 243 votes where 263 were needed, Forsal reported. The third version, passed on 15 May by 241 votes to 200, took on an amendment from the presidential chancellery on market reports by the KNF and the finance minister. Nawrocki vetoed it on 11 June.
On 4 September the Sejm tried for a third time to override him. With 442 MPs voting, the government side needed 266 votes and got 241, 25 short, Parkiet reported. Finance minister Andrzej Domański answered on X with a pun aimed at PiS, “Kryptosrebrniki”, and wrote that more would follow. Four days later Zbigniew Bogucki, head of the President’s Chancellery, announced a second presidential crypto-market bill, with the third government text as its foundation, Money.pl reported. We found no report of a Sejm vote on it since.
The practical effect is that Poland has no designated MiCA authority for crypto-asset service providers, as the KNF itself stated, and the transitional period for firms already active ended on 1 July 2026. The KNF is competent only for issuers of e-money tokens. Under MiCA, a firm licensed in one member state can offer its services across the EU, and the KNF confirmed that such cross-border activity in Poland stays possible, so a Polish client can still use an exchange licensed elsewhere. A company based in Poland has no authority at home to apply to. Our guide to the MiCA regulation explains how licences and passporting work.
What it changes for exchanges and crypto users
This section is Coindaro’s reading of the text as reported, not a statement from the government.
For an ordinary holder in Poland or elsewhere in the EU, nothing changes unless their name is on the list. The list is short and so far aimed at Russian and Belarusian interests. The bill does not create a new tax, a reporting duty for individuals or a limit on self-custody.
For exchanges, brokers and custodians with Polish clients, the change is concrete. They would have to screen a national list on top of the EU’s consolidated list, and act from the day after a listing is posted. A platform licensed in another member state, for example one of the firms Consob has authorised in Italy such as YouHodler, which got its MiCA licence in October, would be in the same position for its Polish users as a bank in Warsaw. Fines of up to 5% of revenue make the screening a board-level matter.
For listed people, the weak point is time. A freeze that cannot be suspended while the case runs can last as long as the court case. Supporters point to the two levels of administrative court review. Bosak’s answer is that the bill in effect removes real court oversight, and the speech-related listing ground makes that sharper.
Senate deadline in early December, then the president
The Senate has 30 days from 9 November, so until about 9 December. It can pass the bill as it is, amend it or reject it. If it does nothing within that time, the bill counts as adopted in the Sejm’s wording, Cointelegraph notes, citing the Polish Constitution. If senators amend it, the text goes back to the Sejm, which votes on the amendments.
Then the president has 21 days to sign, veto or send the law to the Constitutional Tribunal, as the Constitution sets out and BitHub recalls. If he signs, it enters into force 30 days after publication. The arithmetic of a veto is already known from the crypto-market fight: an override needs three fifths of MPs voting, and 240 votes, the bill’s tally on 6 November, would have fallen well short on 4 September, when 266 were needed.
Nawrocki has not said anything about this bill in the reports published so far. His camp, PiS, voted against it. When he first vetoed the crypto-market act in December 2025, his office said its provisions threatened “the freedoms of Poles, their property, and the stability of the state”, Cointelegraph reported. Critics of the freeze-first design now argue on the same ground.
The next steps are the Senate sitting that takes up the bill, any amendment to the pre-court effect of a listing, and then the president’s 21-day window. For the separate MiCA question, the next step is whether the Sejm takes up the president’s own crypto-market bill. Newcomers can read our glossary entry on MiCA for the basics.