The transitional period under Article 143(3) of Regulation (EU) 2023/1114 (MiCAR) expired on 1 July 2026. This grandfathering clause permitted crypto-asset service providers operating under pre-existing national authorisations to continue providing services within their home member states from 30 December 2024 until the earlier of the date they received or were refused a MiCA authorisation, or 1 July 2026. With no further extension available, all national transitional permissions ceased as of that date.
The basis for the grandfathering regime was Article 143(3) of MiCAR, which granted member states the discretion to allow entities already licensed under domestic frameworks to continue operations during the transitional window. ESMA issued a public statement in June 2026 calling on all unauthorised CASPs to wind down EU-facing services ahead of the deadline and reminding national competent authorities of their enforcement obligations.
Crypto-asset service providers, including exchanges, custodians, portfolio managers, and transfer service operators, that have not received a MiCA authorisation from a national competent authority must now cease accepting EU clients or executing transactions for existing EU clients. Providers that continue operating without authorisation breach Article 59 of MiCAR and may be subject to supervisory action and administrative fines under Article 111.
Member states granted varying grandfathering window lengths under Article 143(3), ranging from 12 to 18 months from 30 December 2024. Belgium and Bulgaria opted for the full 18-month period, meaning those national windows ran until 30 June 2026. Entities that applied for authorisation before the expiry date and remain pending may qualify for continued operation under applicable member state law; applicants should verify the applicable national transitional rules.
Licentium advises crypto-asset service providers on MiCA authorisation requirements across EU member states, including identifying the appropriate national competent authority, preparing authorisation applications, and assessing ongoing compliance obligations once authorised. Work we undertake includes crypto regulatory compliance, MiCA authorisation advisory, CASP licensing, virtual asset service provider licensing, and ESMA regulatory guidance.
Source: ESMA, Public Statement on the End of MiCA Transitional Periods, June 2026