Maximum EU-wide MiCA transition period ends

On July 1, 2026, the maximum MiCA transition period ended throughout the European Union. The last possible date for Article 143 grandfathering expired. A provider without MiCA authorization or other valid basis had to cease services, even if its State had not completed national measures. Some countries had finished earlier.

What the transitional regime allowed

MiCA began implementing its service-provider regime on December 30, 2024. Entities that were already providing services under national law could continue for a limited period if their State permitted it. The European maximum ended on July 1, 2026.

States could shorten or not use the transition. Therefore, a company registered in one country should not assume that it could operate until July in all of them. The date depended on the State of origin and the legal basis on which it served clients.

Grandfathering was not a MiCA license nor did it confer a passport. It allowed temporary continuation under national rules. The European authorization required a new evaluation of governance, capital, custody, conduct and systems.

What should happen upon expiration

ESMA called for executable exit plans. An unauthorized entity had to stop attracting clients and organize closure or transfer. Continuing to operate out of inertia could constitute an unauthorized service.

Customers needed clear notice, deadlines and options. They could migrate to an authorized CASP, withdraw to a self-custodied wallet or close positions. The company had to avoid unnecessary forced sales and explain commissions and consequences.

An orderly exit includes support, reconciliation, and record retention. Disabling the interface without returning assets misses the point. If there are blocked balances or AML procedures, there must be ways to resolve them.

Authorization, registration and brand name

Users could check providers in the ESMA registry and national authorities. An old AML registration did not equate to MiCA authorization. The entity had to appear with its company name and authorized services.

The brand name may differ from the entity. An international group may have one authorized subsidiary and others not. The contract, domain and notice to the client must identify which company provides the service.

Public lists also allow you to check the State of origin and whether an authority has communicated a subsequent withdrawal of authorisation or warning.

One license doesn’t cover everything either. MiCA lists custody, exchange, execution, advisory and other services. Offering an activity outside the permit or a product regulated by another regulation may require additional authorization.

Reverse solicitation and European clients

Foreign platforms could not use reverse solicitation as a business model. The exception is narrowly interpreted when the client exclusively initiates the service. Advertising, affiliates or promotion in the Union may prevent invoking it.

A user who accesses on their own initiative does not make the company an authorized CASP or obtain all the protections of MiCA. Nor does it allow you to actively offer other assets afterwards without analyzing the scope.

Consequences for custody and passporting

After the transition, the common authorisation allows passporting between States. For businesses, it reduces multiple registrations, but requires ongoing notification and compliance. Supervisors can investigate complaints and withdraw permits.

For clients, MiCA provides rules on segregation, conflicts and information. It does not ensure the value of cryptoassets or convert balances into guaranteed deposits. Market risk remains.

Outlook from 2026

As of August 7, 2026, the deadline has expired in all States. The question is no longer how much grandfathering remains, but whether the entity is authorized, has exited, or invokes another valid basis.

The milestone eliminated the last transitional patchwork, but not all supervisory differences. Companies and users must verify the registration and the specific service. “Registered in Europe” was no longer a sufficient description.