MiCA Implementation in Central and Eastern Europe

When we last examined MiCA implementation across Central and Eastern Europe in late 2025, the focus was largely on preparation. Regulators were building licensing frameworks, transitional periods were still running, and many firms were waiting to see how national authorities would interpret and apply the new rules.

Six months later, the conversation has changed. Across the region, MiCA has moved from implementation to enforcement. Transitional periods are closing, licensing applications are being reviewed, and regulators are beginning to demonstrate how they intend to supervise crypto-asset service providers in practice.

Although MiCA was designed to create a single regulatory framework across the European Union, the experience on the ground remains far from uniform. Slovakia has completed its transition and is operating under a fully functioning MiCA regime.

At the same time, DAC8 is adding a new layer of tax transparency across the region. For CASPs, compliance in 2026 is no longer limited to obtaining a MiCA licence. Firms must also prepare for crypto transaction reporting, customer due diligence requirements, and cross-border information exchange.

The result is a regulatory landscape that is becoming increasingly defined by execution rather than legislation. While the rulebook may be harmonised, supervision, licensing pathways, and operational realities continue to differ from one jurisdiction to another.

Below, we examine where Poland, Czechia, Slovakia, and Hungary stand today and what crypto businesses should know as MiCA enters its next phase.

Poland:

Poland has become one of the most unusual cases in the European Union.

While MiCA applies directly as EU law, Poland remains the only Member State without a domestic MiCA implementing act. Two attempts to pass the Crypto-Assets Market Act were vetoed by President Karol Nawrocki, and a third draft remains under consideration.

The result is a regulatory paradox. The Polish Financial Supervision Authority (KNF) is expected to act as the competent authority, but there is currently no legal mechanism allowing it to process CASP authorisation applications.

Existing businesses registered in Poland's virtual currency activity register before 30 December 2024 may continue operating until 1 July 2026 or until they receive a MiCA authorisation or refusal elsewhere in the EU. New market entrants, however, face a much more difficult situation. No new VASP registrations are being accepted, effectively closing the domestic route to market entry.

For many firms, the practical solution has been to obtain authorisation in another Member State and passport services into Poland under MiCA. Unless the implementing legislation is adopted before July 2026, Polish businesses could face significant uncertainty as the transition period expires.

Poland illustrates a broader reality of MiCA implementation: harmonised legislation does not necessarily produce harmonised supervision.

Czech Republic:

Czechia has emerged as one of the most active MiCA jurisdictions in Central Europe.

The Czech National Bank (CNB) has been authorised to process MiCA applications since February 2025 and has already begun issuing authorisations. In February 2026, the regulator granted its first MiCA licences, signalling that the framework is fully operational.

The country remains within its transitional period until 1 July 2026, although only firms that met specific eligibility requirements can benefit from those arrangements. Existing providers were required to submit applications by the relevant deadlines in order to continue operating during the transition.

What makes Czechia particularly interesting is the volume of activity. The CNB is managing a significant pipeline of applications while simultaneously preparing the market for full MiCA supervision. For applicants, this means authorisation is possible, but timelines may be longer than expected as regulators work through a growing backlog.

As the transition period comes to an end, Czechia's focus is shifting from preparation to execution. The challenge is no longer understanding MiCA. It is demonstrating readiness to operate under it.

Slovakia:

Slovakia is one of the clearest examples of successful MiCA implementation in Central and Eastern Europe.

The country chose a shorter 12-month transitional period, which ended on 30 December 2025. Unlike many jurisdictions that extended implementation timelines, Slovakia followed its original roadmap and moved directly into full supervision.

The National Bank of Slovakia (NBS) now operates a fully functioning MiCA authorisation regime supported by Act No. 248/2024 on crypto-assets and detailed reporting requirements under Opatrenie No. 3/2025.

The framework follows MiCA's three-tier capital structure, requiring minimum own funds of €50,000, €125,000, or €150,000 depending on the services offered. Licensed firms must comply with ongoing prudential reporting, cybersecurity obligations, and DAC8 tax reporting requirements.

One feature that distinguishes Slovakia is its emphasis on regulatory engagement. The NBS continues to offer pre-application discussions, helping firms understand expectations before formally submitting an application.

The result is a system where regulatory expectations are clear, timelines are predictable, and supervision is already functioning as intended.

Hungary:

Hungary is no longer focused on MiCA implementation. It is focused on MiCA enforcement.

The country opted for a shortened six-month transitional period, making it one of the earliest jurisdictions to move fully into the new regulatory framework. As a result, firms operating in Hungary today must either hold a MiCA authorisation or rely on a valid passport from another EU Member State.

The Hungarian National Bank (MNB) serves as the competent authority and has built its supervisory approach around governance standards, ownership structures, cybersecurity controls, outsourcing arrangements, and DORA-related requirements.

For firms considering Hungary, the message is straightforward. Legacy national arrangements are no longer relevant. Businesses must comply with MiCA in full and demonstrate that they can meet the regulator's supervisory expectations.

Hungary's early transition means that much of the uncertainty seen elsewhere in Europe has already passed. The market has entered a period where ongoing compliance matters more than implementation planning.

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The DAC8 Factor

MiCA is only part of the compliance picture in 2026.

Across Central and Eastern Europe, crypto businesses must also prepare for DAC8 reporting obligations. The framework requires CASPs to collect information on users, determine tax residency, maintain reporting systems, and submit transaction data to tax authorities.

For many firms, this represents a second compliance challenge running alongside MiCA authorisation. Obtaining a licence is no longer enough. Businesses must also demonstrate that they can satisfy increasingly complex tax reporting requirements.

The first reporting cycle will cover data collected from 2026 onward, making preparation a priority for licensed firms across the region.

Conclusion

Poland, Czechia, Slovakia, and Hungary demonstrate that MiCA may be a single European regulation, but implementation still varies significantly between jurisdictions.

Slovakia and Hungary have already completed their transitions and are operating under full supervisory regimes. Czechia is actively issuing licences while managing a growing application pipeline ahead of the July 2026 deadline. Poland remains the exception, with MiCA applying directly but no domestic licensing framework yet available.

For CASPs, the transition period is rapidly coming to an end. The focus has shifted from understanding MiCA to proving compliance under it. At the same time, DAC8 is adding a new layer of reporting and transparency obligations that firms cannot afford to ignore.

The direction of travel is clear. In 2026, operating a crypto business in Europe is no longer just about obtaining a licence. It is about building the governance, reporting, and compliance infrastructure needed to operate under permanent regulatory supervision.

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