The regulation, which took effect on 18 March 2026, implements EU tax transparency rules and allows authorities to withdraw registration numbers from non-compliant operators until they provide financial security in the form of cash, bank guarantees, or Treasury bonds.
Poland has issued an executive regulation under the amendment to the Law on the Exchange of Tax Information with Other Countries, primarily incorporating into domestic legislation the provisions of the Amending Directive to the 2011 Directive on Administrative Cooperation (DAC8 – Directive 2023/2226).
It was published in the Official Journal of Laws (No. 355/2026) on 17 March 2026 and entered into force on 18 March 2026. The regulation establishes clear procedures for how authorities will accept guarantee deposits from crypto operators.
The DAC8-implementing law introduces a guarantee deposit mechanism for crypto-asset operators that fail to comply with reporting obligations, even after enforcement actions by the Head of the National Revenue Administration.
In such cases, the operator’s individual registration number may be withdrawn. Reinstatement is only possible once the operator provides a guarantee deposit—determined by the authority—ranging from PLN 100,000 to PLN 1 million, serving as a safeguard to ensure future compliance.
Operators can submit their security deposits in three different forms.
Cash deposits must be transferred to the account of the office handling the accepting authority. For bank guarantees, operators need to submit documentation proving the guarantee has been granted. Alternatively, they can use Polish Treasury bonds with at least a three-year maturity period, which must be blocked through a registered certificate from a bank or brokerage house.
After receiving a deposit, authorities will issue a written confirmation to the crypto operator. For cash deposits specifically, this confirmation is only provided after the operator presents proof of the transfer order and authorities verify that funds have been received.
The return procedure requires operators to submit a formal request to the same authority that accepted the deposit. They must also provide evidence meeting the conditions specified in the Tax Information Exchange Act from 9 March 2017.
Returns vary by deposit type: cash deposits are transferred back to the operator’s designated account, bank guarantee documents are returned with a receipt, and Treasury bond blockades are released with official consent from the accepting authority.
This regulation implements EU Council Directive 2023/2226 (DAC8) from 17 October 2023, which amended administrative cooperation rules in taxation matters.
Earlier, Poland published the Act of 13 February 2026 amending the Act on the Exchange of Tax Information with Other Countries and certain related legislation in the Official Gazette on 17 March 2026, implementing the Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8) and Council Directive (EU) 2025/872 of 14 April 2025 (DAC9).
