The Article 143(3) transitional period under Regulation (EU) 2023/1114 (MiCA) expired on 1 July 2026, closing the final grandfathering window. Any entity providing crypto-asset services under pre-MiCA national authorization after that date, without a MiCA authorisation as a crypto-asset service provider (CASP), is operating outside the law and must immediately suspend those services.
Article 143(3) of MiCA allowed member states to permit pre-existing service providers to continue operating for up to 18 months from 30 December 2024, the date CASP provisions entered application. ESMA's April 2026 Statement on the End of Transitional Periods under MiCA confirms the maximum period has elapsed and that national competent authorities (NCAs) must now enforce full MiCA compliance. Providers with pending authorisation applications may continue only where an NCA grants individual permission under the second subparagraph of Article 143(3).
Exchanges, custodians, transfer service providers, and portfolio managers without MiCA authorisation must halt new client onboarding. Where NCA guidance requires it, they must also wind down or transfer existing client positions. Providers that received MiCA authorisation before 1 July 2026 gain cross-border passporting rights to offer services across the EU without additional national licensing steps.
Member states that adopted grandfathering periods shorter than 18 months completed their transitions earlier, meaning some providers have operated under full MiCA obligations since 2025. The EBA's public CASP register and ESMA's central register reflect current authorisation status. Firms should verify their own status and that of counterparties before settling post-deadline transactions. Pending authorisation files do not extend operating rights unless an NCA issues an explicit individual determination.
We may advise on MiCA authorisation strategy and have a partner network of EU counsel with direct NCA experience. If your organisation needs to assess its post-1 July position or advance an authorisation application, we invite you to contact us. Work we undertake includes MiCA CASP authorisation filings, cross-border passport notifications, regulatory capital analysis, and NCA liaison.
Source: ESMA, Statement on the End of Transitional Periods under MiCA, April 2026