MiCA transitional period

Article 143(3) of MiCA lets a firm that provided crypto services under national law before 30 December 2024 continue until 1 July 2026, or until it is granted or refused a CASP authorization, whichever comes first. Each member state could shorten that period or not apply it at all, and the national choices range from 5 to 18 months, as the overview by Freshfields shows. ESMA publishes the list of grandfathering periods each member state reported.

Article 143(6) adds a second option: a member state may offer a simplified authorization procedure to firms it already supervised. Germany uses it for entities that already hold a license for the crypto service in question. Austria, the Netherlands and Italy did not plan such a simplified procedure for their firms.

Germany and Austria ended their periods on 31 December 2025, and Italy on 30 December 2025, according to the same Freshfields overview. In Germany section 50 of the KMAG set that date for firms with a license under the Banking Act, and BaFin confirmed the shortened deadline in a notice of 8 July 2026. The Netherlands closed its window on 1 July 2025, six months after the regulation began to apply. Ireland used Article 143(3) to cut its period to 12 months, which ended in December 2025, as A&L Goodbody reports; the Central Bank of Ireland is the competent authority there.

Luxembourg kept the full 18 months, from 30 December 2024 to 1 July 2026, for providers registered with the CSSF, as Elvinger Hoss explains. Cyprus also ran to 1 July 2026 for firms in its old national register. Poland is the special case: firms in its national register could operate until 1 July 2026, but Poland had no law naming a MiCA authority, so a Polish firm had nowhere to apply. The page on MiCA in Poland follows that story up to the end of the period.

ESMA set out what it expects at the end of the transitional periods in a statement of 17 April 2026. A provider without authorization needs an operational wind-down plan, must give its clients prior notice and must move their crypto assets to an authorized CASP or to a self-hosted wallet. The provider may not route services through an unauthorized firm by outsourcing. A firm from outside the EU may serve EU clients only under the narrow reverse solicitation exemption.

The French supervisor AMF added a warning for investors in its summary of the ESMA statement: MiCA protection applies only to the authorized EU legal entity, so a client should check which company the contract is with. For a bank or asset manager that uses a crypto provider for custody or execution, the same check belongs in the outsourcing file.

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The MiCA deadline for crypto-asset service providers was 1 July 2026, the last day of the longest national transitional period under Article 143(3). ESMA wrote in its statement of 17 April 2026 that after this date any entity providing crypto-asset services to EU clients without a MiCA license is in breach of EU law and must cease those services. BaFin and the German Financial Intelligence Unit followed on 8 July 2026 with a notice (in German) that only providers with a MiCA license may serve clients in the EU and that licensed CASPs must run full customer due diligence on clients who move over from unlicensed providers.

The MiCA transitional period ended on 1 July 2026 at the latest, and member states could shorten it under Article 143(3): Germany and Austria ended it on 31 December 2025, Ireland in December 2025 and the Netherlands on 1 July 2025.

A crypto provider without the required MiCA license has to stop serving EU clients, wind down in an orderly way, tell its clients in advance and move their crypto assets to an authorized provider or to a self-hosted wallet. ESMA asked national authorities to check that these plans exist and are carried out.

ESMA keeps an interim MiCA register of authorized CASPs, and the national authorities keep their own lists. The page on European crypto exchanges shows how to read the register.