CASP Transitional Period Ended 1 July 2026 — What Comes Next

The transitional period — design and reality

MiCA Article 143 created an 18-month transitional window from MiCA application date (30 December 2024) to 1 July 2026 during which crypto-asset service providers authorised or registered under pre-MiCA national frameworks could continue operations while applying for MiCA CASP authorisation. The window’s purpose was operational — avoiding a hard regulatory cliff for hundreds of pre-existing crypto businesses, allowing orderly migration to the new framework.

The reality of the transition has been messier than the framework anticipated. Three factors created friction.

First, application volumes substantially exceeded NCA processing capacity. The principal pre-MiCA jurisdictions — Estonia, Lithuania, Poland, Czech Republic — each had hundreds of registered VASPs that needed to migrate. NCAs designed for handling dozens of applications per year suddenly faced volumes 5-10x higher. Backlogs accumulated. Some applications submitted in early 2025 still under review as the deadline approached.

Second, member states adopted different transitional windows. The MiCA default was 18 months but Article 143 permitted member states to legislate shorter periods. France adopted a 6-month window (effective deadline June 2025). Italy and Germany adopted 12-month windows (effective deadline December 2025). Several other member states adopted bespoke shorter periods. Operators registered in shortened-window jurisdictions faced compressed migration timelines that some did not anticipate.

Third, the substance gap between pre-MiCA and MiCA frameworks was bigger than operators expected. Estonian FIU registration was AML-focused; MiCA authorisation required full prudential, conduct, governance, and ICT-resilience documentation. Lithuania VASP register was similarly lighter than MiCA CASP. Operators that started transitional migration in 2024 with their pre-MiCA documentation discovered substantial additional work required for the MiCA-compliant file.

Status as of 1 July 2026

The post-deadline status of crypto-asset service providers in the EU divides into four categories.

Authorised CASPs — operators with granted MiCA Article 59 authorisation operate under full MiCA framework. Most early movers (operators that applied 2024-2025 in well-resourced jurisdictions) are in this category. Approximately 200-300 CASPs across EU member states had granted authorisation by mid-2026.

Applications under active review — operators with substantive applications under NCA review at the deadline operate under supervisory discretion. NCAs typically permit continued operations during review subject to ongoing compliance and progress toward grant. Most NCAs have communicated grace policies covering operators with active applications. Approximately 400-600 applications across EU member states under review at 1 July 2026.

Late applications or applications post-deadline — operators that did not file by the transitional deadline can still apply for CASP authorisation but must cease EU customer operations during the application phase. Some have continued operations from non-EU jurisdictions while applying for EU CASP authorisation; the practical viability depends on customer geography.

Service cessation — operators that cannot or chose not to migrate must wind down EU customer operations. Customer crypto-assets returned, fiat balances closed, ongoing contracts terminated. The wind-down process is substantive and creates significant customer-protection responsibility through the closing period.

Estonia — the largest pre-MiCA migration

Estonia had the largest pre-MiCA VASP population — over 600 FIU-registered providers at peak in 2019, reduced through Estonia’s 2020-2022 tightening to approximately 200 active providers at MiCA application date. Estonia’s experience captures the transitional dynamics in microcosm.

Many Estonian VASPs were structurally light businesses — registration was relatively cheap and the substance bar permissive through 2018-2020. The MiCA CASP requirements (capital floor by service class, substantive governance, AML-MLRO substance, prudential infrastructure) substantially exceeded the pre-MiCA framework. Several dozen Estonian VASPs determined that MiCA compliance was uneconomic and chose service cessation rather than authorisation.

The Estonian FIU/Finantsinspektsioon transition was relatively smooth for operators that committed to migration early. Estonia adopted the 18-month default transitional window. Operators that filed substantive applications by Q1 2025 typically received grants by end-2025 or early 2026. The post-deadline position: roughly 100-120 Estonian-domiciled CASPs operating under MiCA authorisation, down from the pre-MiCA peak.

Lithuania — the volume player

Lithuania’s pre-MiCA VASP register was comparable to Estonia in scale but with different operator profile. Lithuanian VASPs tended to be larger international operations using Lithuania as an EU operating base rather than as a primary market. The Bank of Lithuania (Lietuvos Bankas) had been investing in MiCA implementation capacity from 2023 onwards.

Lithuania adopted the 18-month default window. The Bank of Lithuania communicated processing capacity and a structured queue for transitional applications throughout 2025. Most substantive applications filed in 2025 received decisions before the deadline. Several operators chose to consolidate operations through different EU member states — moving from Lithuania to Ireland, Malta, or Netherlands — rather than continue Lithuanian operations under the MiCA framework.

The post-deadline Lithuanian CASP population is approximately 80-100 operators, down from 200+ pre-MiCA. The shift reflects both genuine MiCA-compliance economics and competitive pressure from member states with more developed financial-services ecosystems.

France — the early closer

France’s 6-month transitional window was the shortest among major EU member states. Operators previously registered as PSAN (Prestataire de Services sur Actifs Numériques) under the 2019 PACTE law framework had until 30 June 2025 to obtain MiCA CASP authorisation or cease operations.

The AMF (Autorité des Marchés Financiers) communicated the deadline clearly through 2024 and 2025. Several major French operators (Bitstamp, Coinhouse, others) migrated successfully through the compressed window. Other operators concluded the timeline was unachievable and either chose service cessation or relocated EU operations to longer-window member states.

The post-June-2025 position: approximately 30-40 French-domiciled CASPs operating under MiCA. France’s smaller domestic crypto-services market and aggressive transitional timing produced a more concentrated post-MiCA market than Estonia or Lithuania.

Germany — BaFin’s measured approach

Germany adopted a 12-month transitional window (effective deadline 30 December 2025) for crypto-asset service providers previously holding BaFin’s crypto-custody licence (Kryptoverwahrgeschäft under Section 1(1a) KWG). BaFin had been a comparatively strict pre-MiCA supervisor — the existing licensed population was small (approximately 20-30 entities) and substantively-compliant. The MiCA transition was relatively smooth.

Several German operators chose to use the transition as opportunity for restructuring — corporate consolidation, capital restructuring, service-scope adjustment. BaFin’s measured approach allowed substantive engagement throughout the transition. The post-December-2025 position: approximately 25-35 German-domiciled CASPs under MiCA authorisation.

What comes next for the post-MiCA market

The MiCA framework is now substantively the only regulatory framework for crypto-asset services in the EU. The pre-MiCA frameworks are fully wound down (or in extended wind-down for record-retention purposes). Three trends define the post-MiCA market.

Consolidation around well-resourced jurisdictions — Ireland, Netherlands, Malta, Luxembourg, and Germany have emerged as the principal CASP host jurisdictions. These member states have the regulatory infrastructure to process MiCA applications efficiently and the financial-services ecosystems to support CASP operations. Estonia and Lithuania remain significant but with reduced operator populations.

Capital and substance economics shifted upward — MiCA’s prudential, governance, and operational requirements substantially exceed pre-MiCA frameworks in most member states. Smaller operators have exited; larger operators have invested in substantive compliance infrastructure. The barrier to entry for new CASP applications is materially higher than the pre-MiCA equivalent.

Active enforcement against unauthorised operators — NCAs and ESMA have signalled continued enforcement against crypto-asset service providers operating in the EU without MiCA authorisation. Cross-border cooperation has intensified. Payment-processor cooperation requirements increase the operational difficulty of operating EU-customer crypto services without authorisation.

For operators that completed MiCA migration by 1 July 2026, the post-transitional position is operationally stable and competitively favourable. For operators that missed the window, the path forward is either fresh CASP application with operations suspended during review, or exit from the EU customer market.