MiCA transitional period (grandfathering)

When MiCA's rules for crypto-asset service providers began to apply on 30 December 2024, many firms were operating legally under national registration regimes, such as Spain's registry of virtual currency providers at the Bank of Spain. Article 143 of MiCA allowed them to keep providing services in their member state until they were granted or refused a CASP authorisation, and in any case no later than 1 July 2026.

Member states could shorten or skip the period. Some, like the Netherlands, chose six months, while others allowed the full eighteen, which created incentives to seek authorisation in faster or more flexible jurisdictions. ESMA urged firms to apply early and authorities to plan orderly wind-downs for those that would not be authorised.

The transitional period has ended. Firms without MiCA authorisation can no longer serve EU clients, except on a strict reverse solicitation basis, and users of providers that did not obtain a licence had to move their assets. National registrations under the old AML regime no longer suffice on their own.