The transitional period under Article 143(3) of Regulation (EU) 2023/1114 (MiCAR) expired on 1 July 2026. Entities that had been providing crypto-asset services in reliance on national virtual asset service provider (VASP) registrations across EU member states are no longer permitted to continue those services without a MiCAR crypto-asset service provider (CASP) authorisation issued by a competent national authority.
Article 143(3) MiCAR granted a maximum 18-month grace period from the date MiCAR became fully applicable, 30 December 2024, extending to 1 July 2026. The Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg confirmed on 1 July 2026 that registration under the Law of 12 November 2004 on anti-money laundering and counter-terrorist financing no longer constitutes a sufficient legal basis for providing crypto-asset services within MiCAR scope. The same position applies across all EU member states by operation of Article 143(3).
Entities affected include spot trading platforms, custodian wallet providers, portfolio managers of crypto-assets on behalf of clients, operators of multilateral trading facilities for crypto-assets, and other service providers falling within the CASP service categories listed in Annex I to MiCAR. Any such entity without a CASP authorisation as of 1 July 2026 must cease providing those services until authorisation is granted. Applications are submitted to the competent national authority of the member state of establishment; in Luxembourg, the CSSF is the designated authority.
Several national competent authorities reported backlogs in processing CASP authorisation applications ahead of the 1 July 2026 deadline. Entities that submitted complete applications in good time but had not yet received a decision face residual legal uncertainty under member state law. MiCAR does not provide an automatic extension of the transitional period. The European Securities and Markets Authority maintains a public CASP register, which is the reference point for identifying entities holding valid authorisations across the EU.
Licentium advises on MiCAR authorisation and compliance obligations across EU jurisdictions. Our partner network includes advisers active with national competent authorities in Luxembourg, Ireland, Lithuania, and Malta. If this development affects your business or you require guidance on CASP authorisation, contact us at www.licentium.io. Work we undertake includes CASP licence applications, MiCAR readiness assessments, VASP-to-CASP transition structuring, AML/CTF compliance programme design, and ongoing regulatory liaison.
Source: CSSF, MiCA: Transition period for virtual asset service providers ended on 1 July 2026, 1 July 2026