Regulation (EU) 2023/1114 (MiCA) gave national VASP registrants an 18-month transitional window to obtain CASP authorisation from a competent authority in their home member state. That window closed on 1 July 2026 for member states that adopted the full period, including France, Malta, Luxembourg, and Estonia. The regulation is now fully in force across all EU member states.
Article 143(3) of MiCA set the grandfathering rule. Providers operating lawfully under national law before 30 December 2024 could continue until authorised or for a maximum of 18 months. Several member states adopted shorter windows. The Netherlands, Finland, Latvia, Hungary, and Slovenia closed their periods on 30 June 2025. Sweden's period closed on 30 September 2025.
Of the 1,200-plus firms that held national VASP registrations at the start of the transitional period, approximately 210 have obtained full CASP authorisation. The remaining 83 percent must now cease providing crypto-asset services to EU clients. These firms no longer hold legal standing under Article 143(3). Exchanges, custodians, and portfolio managers without authorisation face enforcement action by national competent authorities.
ESMA has confirmed no further grandfathering extensions are available under MiCA. Any entity providing crypto-asset services without authorisation after 1 July 2026 is in breach of EU law. National competent authorities retain discretion over enforcement timing. Some mid-application firms have sought informal tolerance from their home regulators, but the MiCA text contains no safe harbour for this situation.
Licentium advises on MiCA authorisation matters and maintains a partner network of licensed advisers across EU member states. Firms seeking authorisation, facing enforcement inquiries, or assessing their status under Article 143(3) may contact us. Work we undertake includes CASP authorisation applications, MiCA compliance gap analysis, VASP-to-CASP conversion, and engagement with national competent authorities.
Source: ESMA, Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114, accessed 30 June 2026