The MiCA transitional arrangement established under Article 143 of Regulation (EU) 2023/1114 expired on 1 July 2026. From that date, any person providing crypto-asset services to clients located in the EU without a valid MiCA authorisation granted by a competent national authority is in breach of EU law and must cease EU client operations. This is a final enforcement threshold, not a proposed or consultation-stage measure.
Article 143(3) of MiCA allowed member states to apply a national transitional regime permitting entities authorised under pre-MiCA law to continue providing crypto-asset services during a grace period ending no later than 1 July 2026. ESMA's Public Statement of 23 June 2026 (ESMA75-113276571-1710) clarifies that non-authorised crypto-asset service providers must wind down activities in an orderly manner, prioritising the return of client assets and minimising disruption to investors. The statement specifies that competent authorities should monitor wind-down plans and that non-authorised providers may not acquire new EU clients after 30 June 2026.
Exchanges, custody providers, portfolio managers, and transfer-service operators that had operated under national licences in Ireland, Germany, France, or other member states without converting to MiCA authorisation must now halt EU client onboarding. Entities holding assets for EU retail clients are required to return those assets promptly and provide written notice of wind-down. Authorised CASPs with a valid MiCA licence are unaffected and may continue EU operations, including cross-border expansion through the MiCA passport.
Some member state competent authorities retain enforcement discretion during the initial post-1 July period, but ESMA's statement confirms there is no legal basis for extension beyond 1 July 2026 at EU level. Entities that submitted MiCA authorisation applications before the deadline and are awaiting a decision occupy a procedural position that varies by member state and may require national-level clarification. The European Commission launched a targeted consultation on the MiCA review in May 2026, a separate process that does not affect current enforcement deadlines.
Licentium advises crypto-asset businesses on MiCA authorisation, wind-down structuring, and cross-border passporting strategy. We maintain a partner network with regulatory counsel across multiple EU member states. Operators assessing their position after the 1 July deadline may contact us. Work we undertake includes MiCA authorisation advisory, CASP regulatory mapping, cross-border licensing strategy, and investor-protection compliance for crypto-asset service providers.