MiCA Transitional Period Has Ended: The European Crypto Market After the Deadline

The transitional period under the Markets in Crypto-Assets Regulation (MiCA) ended on 1 July 2026, marking a hard reset for Europe’s digital asset market.

A MiCA licence refers to authorisation for crypto-asset service providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCA), which introduced a unified regulatory framework across the EU and EEA. The regime was implemented in phases: stablecoin rules (e-money tokens and asset-referenced tokens) applied from 30 June 2024, followed by the full CASP framework on 30 December 2024. Existing market participants were granted a transitional period to obtain authorisation, which ended on 1 July 2026. From that date, only CASPs authorised under MiCA may operate in the EU/EEA.

Market Outcome After 1 July 2026

By 1 July 2026:

• 244 CASP authorisations had been issued across the EEA
• An estimated 75–80% of pre-MiCA platforms are exiting or have exited the European market
• Greece, Hungary, Poland and Romania had not issued any MiCA licences by the deadline
• Germany, the Netherlands, and France lead the ESMA register
• Latvia issued 7 crypto authorisations in the last two months alone

Poland remains a special case, as it still lacks a full national framework aligned with pan-European licensing standards, and the proposed legislation has been rejected three times by the president. This has led to a cautious approach — some entities are limiting their activity, asking clients to transfer assets, or considering relocation to other European jurisdictions where licensing processes are already functioning.

ESMA Update: Requirements for Unauthorised Platforms

On 23 June 2026, the European Securities and Markets Authority (ESMA) set out requirements for platforms lacking MiCA authorisation (see ESMA statement for full details https://www.esma.europa.eu/sites/default/files/2026-06/ESMA75-113276571-1710_Public_Statement_MiCA_transitional_period_ends.pdf).

Unauthorised CASPs must immediately stop onboarding EU clients, cease marketing activities, and limit operations strictly to winding down positions and transferring or closing assets. Custody may continue only for the period strictly necessary for an orderly exit.

Cross-border structures cannot be used to bypass MiCA requirements. Non-EU providers cannot service EU clients, and authorised CASPs cannot outsource custody to unauthorised entities.

A More Concentrated Market

MiCA was designed to protect investors and raise compliance standards — but it has also sharply reduced the number of firms able to serve EU clients, with no sign that demand has fallen proportionally.

Authorised CASPs therefore operate with less competition than before, against steady demand. Whether displaced users move to authorised EEA platforms, switch to self-hosted wallets, or migrate to non-EU providers remains to be seen — but the structural position of authorised CASPs (strong demand, constrained supply, high barriers to new entry) is unusual and likely to persist. This has already prompted MiCA-authorised platforms to increase marketing efforts, even as uncertainty continues among traders about the status of unauthorised platforms and their assets.

Building a MiCA-Compliant Business

For firms assessing entry into the European market, a MiCA CASP licence is now the baseline requirement for operating in the EEA.

Capital requirements are moderate, ranging between €50,000 and €150,000 depending on licence class, with an annual supervisory fee of 0.6%, subject to a €3,000 minimum.

MiCA authorisation is not limited to capital thresholds. Firms must demonstrate to regulators:

• Appropriate governance arrangements
• Effective internal control and compliance systems
• Sound risk management frameworks
• Operational resilience and secure ICT infrastructure
• Financial soundness

Regulators assess these elements in full before granting authorisation.

At product level, crypto-asset issuers must comply with disclosure requirements through approved white papers, which must clearly explain both the underlying technology and associated risks before offering crypto-assets in the EEA.

In combination with the Digital Operational Resilience Act (DORA), MiCA signals a shift towards institutional standards aligned with traditional financial services regulation.

AMLA Advisory: ML/TF Risks During Market Reconfiguration

Alongside ESMA requirements, the EU Anti-Money Laundering Authority (AMLA) has highlighted ML/TF risks arising from the end of the MiCA transitional period and the resulting market consolidation (see the official AMLA advisory for full details). The exit of unauthorised virtual asset service providers (VASPs) and the transfer of customer relationships increase risks related to illicit flow concealment, sanctions evasion, and reduced transparency of asset movements.

Unauthorised VASPs must maintain full AML/CFT controls throughout the wind-down process, including customer due diligence (CDD), transaction monitoring, and suspicious activity reporting until all regulated activity ceases.

AMLA confirms that customers migrating from unauthorised VASPs must not be subject to blanket de-risking. CASPs must apply a risk-based approach with proportionate CDD and individual assessment of incoming clients.

For supervisors and Financial Intelligence Units (FIUs), AMLA emphasises enhanced cross-border coordination and improved visibility over transfer flows between exiting VASPs and receiving CASPs to support consistent supervision and detection of emerging risks.

How ECOVIS ProventusLaw Is Supporting Crypto Platforms

At ECOVIS ProventusLaw, we advise firms navigating MiCA implementation across the EEA. Market participants — including Match Networks Ltd., Proof Space Pte. Ltd., Aethir Network Foundation Company, Trek Technologies SIA, Trek Labs UAB (Backpack Token) and others — are restructuring their operating models, securing token approvals, and transitioning towards fully regulated institutional frameworks.

ECOVIS ProventusLaw is a specialised fintech and financial regulatory law firm in Lithuania and the wider Baltic region, advising on crypto licensing since 2014 and having secured more than 40 FinTech licences end-to-end. The firm’s practice covers banking, payments, e-money, investment firms, and crypto-asset regulation, including tokenisation, digital assets, and institutional finance. It operates across Lithuania, Latvia, and Estonia and is part of the ECOVIS International network, present in more than 90 countries.

For crypto businesses, regulatory integration has become a core commercial requirement for operating in a newly filtered, high-value market of 450 million European consumers. Firms that build structural maturity today will be best positioned for the next phase of European digital finance.