ESMA published a statement in April 2026 confirming the end of the MiCA grandfathering period for crypto-asset service providers. Under Article 143(3) of Regulation (EU) 2023/1114 (MiCA), entities providing crypto-asset services in accordance with applicable national law before 30 December 2024 were permitted to continue operating under transitional arrangements. Those arrangements expire on 1 July 2026. Any CASP that has not obtained MiCA authorization by that date must cease providing crypto-asset services to clients in the European Union.
Article 143(3) of MiCA sets the outer transitional deadline at 18 months from MiCA's application date of 30 December 2024, placing the hard stop at 1 July 2026. Member States were permitted to set shorter national grandfathering periods. Some jurisdictions established earlier deadlines. CASPs must verify the specific deadline applying in each Member State where they are active. ESMA's April 2026 statement confirms that no extension is available under the regulation and that national competent authorities are expected to begin enforcement from that date.
CASPs operating under transitional arrangements without a submitted or pending MiCA authorization application must cease EU-facing services by 1 July 2026. Banks and investment firms providing crypto-asset services under Article 60 of MiCA are subject to a parallel notification regime with a separate timeline. Clients holding assets or positions with an unauthorized CASP after 1 July 2026 face operational risk if the CASP winds down services without adequate notice.
The treatment of CASPs with pending authorization applications after 1 July 2026 varies by Member State. Where a CASP has submitted a complete application and a final decision has not been issued, some national competent authorities may permit continued provision pending the decision; others may not. CASPs with cross-border activity should map their exposure by jurisdiction. ESMA's statement does not create a uniform pending-application safe harbor across the EU.
Licentium advises on MiCA authorization, the CASP licensing process, and cross-border compliance for digital asset businesses operating in the European Union. Our partner network includes regulated practitioners in multiple Member States. Please contact us if you require guidance on MiCA compliance ahead of the 1 July 2026 deadline. Work we undertake includes: MiCA CASP authorization applications, regulatory gap analysis, EU passporting strategy, crypto-asset whitepaper preparation, and cross-jurisdictional compliance mapping.
Source: ESMA, Statement on the End of Transitional Periods under MiCA, April 2026