Poland has become the only EU member state where crypto firms are unable to obtain a MiCA license, due to unresolved national implementation issues. This creates a gap in the EU passporting framework, as firms domiciled in or planning to register through Poland cannot access the single-market license that MiCA is designed to provide, effectively locking them out of regulated EU crypto operations.
For Armada's crypto repo desk, any counterparty that had planned to use Poland as its MiCA licensing jurisdiction is now in regulatory limbo, which raises counterparty risk and compliance questions. Armada's onboarding and KYC processes should verify that EU-based counterparties have a valid, operative licensing jurisdiction. This is particularly relevant for market makers or institutional holders with Eastern European operational footprints who may have assumed Polish licensing was available.