United Kingdom vs Poland
Crypto regulation comparison
United Kingdom
Poland
The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').
Cryptocurrency is legal and regulated in Poland. Crypto capital gains are taxed at a flat 19% rate. The KNF (Polish Financial Supervision Authority) oversees crypto-related financial services, and VASPs must register for AML compliance. Poland has a growing crypto community and several domestic exchanges. MiCA applies from December 2024.
Key Points
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Key Points
- Flat 19% tax on crypto capital gains (PIT-38 annual declaration)
- Crypto-to-crypto transactions are not taxable events; only fiat conversions trigger tax
- VASPs must register in the AML register maintained by the Tax Administration Chamber
- KNF oversees market conduct and consumer protection for crypto services
- MiCA framework applicable from December 2024
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)