The MiCA transitional regime expires on 1 July, and ESMA has confirmed in its 17 April statement that there is no extension. From then, providing crypto-asset services to EU clients without a CASP authorisation is a breach of EU law, and unauthorised firms must cease.
The Article 143 grandfathering that let pre-2024 providers keep trading while their applications ran closes on the date, or on the grant or refusal of a licence, whichever comes first, so a pending application buys no extra time. With authorisations running to months rather than weeks, any firm not licensed by now will not be by the deadline.
ESMA expects unauthorised CASPs to have executed orderly wind-downs by 1 July: prior notice to clients and the transfer of client assets to an authorised CASP or a self-hosted wallet. National regulators are to be ready to act on unauthorised provision from the end of July, with penalties under MiCA running to 5 million euro or 5% of annual turnover, alongside cease-and-desist orders and licence revocation. France’s AMF has warned of criminal prosecution for those still operating without authorisation after the date.
